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TMI Blog2020 (1) TMI 1239X X X X Extracts X X X X X X X X Extracts X X X X ..... in the case of Pavankumar M Sanghvi vs ITO I.T,A, No.2447/Ahd/2016, wherein the Hon'ble ITAT has held that genuineness of the transactions cannot be established merely on the basis of documentation filed by the assessee and further probe is required to ascertain whether what was apparent was real". (iii) "Whether on the facts and circumstances of the case and in law, the Ld.CIT(A] has erred in allowing the interest expenses of Rs. 26,45,096/- on the loan of Rs. 1,40,00,000/- which has been held to be in the nature of the accommodation entry and sham in the assessment order." 3. The brief facts of the case are that the assessee has filed its return of income for AY 2013-14 on 28/09/2013, declaring total income at Rs. 57,12,110/-. In this case, a survey u/s 133A of the Income Tax Act, 1961 was conducted by DDIT(Inv.),Unit-III(2), Mumbai on 25/03/2014 based on the information that the assessee had taken accommodation entries of bogus unsecured loans from various dummy concerns, who are engaged in the business of providing accommodation entries. During the course of survey action, the books of accounts of the assesse were examined and also, the assessee was asked to furnish the deta ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ain to give accommodation entries of unsecured loans to various persons. Therefore, he finally came to the conclusion that unsecured loans taken from the companies operated and controlled by the Praveen Kumar Jain are not explained and accordingly, made additions u/s 68 of the I.T.Act, 1961. Similarly, the Ld. AO has made additions towards interest paid on said loans amounting to Rs. 26,45,096/-, on the ground that when loan borrowed from those parties itself is not proved, consequent interest payment on said loans cannot be accepted as genuine transactions. 5. Aggrieved by the assessment order, the assessee preferred an appeal before the Ld.CIT(A). Before the Ld.CIT(A), the assesee has reiterated its submissions made before the Ld.AO. The assessee has filed elaborate written submissions on this issue, which has been reproduced at para 6.3 on pages 8 to 13 of Ld. CIT(A) order. The sum and substance of arguments of the assessee before the ld.CIT(A) are that the Ld. AO has never disputed the identity of the creditors, which is evident from the fact that the assessee has filed complete details, including name and address of the lenders along with their PAN numbers. The assesee, furth ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... rom creditors are non genuine transactions. Accordingly, he has deleted additions made by the Ld. AO towards unsecured loans taken from those parties. Similarly, the Ld.CIT(A) has deleted consequent interest disallowances made by the Ld. AO on the said loans, on the ground that once loans have been accepted as genuine transactions, consequent interest paid on said loans cannot be disallowed. The relevant findings of the Ld.CIT(A) are as under;- 6.4.9 From the assessment order it is observed that the Ld. AO has given a factual he bank accounts of the creditors there is only RTGS/Trf entries which no cash was introduced prior to advancing the loans lo the Ld. AO had not brought on record any evidence suggesting that the appellant had paid cash to the loan creditors in lieu of loans received from Them. It is also admitted fact that the unsecured loans under consideration have been repaid over a period of time and on same the appellant has paid interest and TDS thereupon, as per provisions of the Act, The Ld, AO has relied ion of Hon'ble Supreme Court in the case of Navodaya Castle P ltd and that of 'We Calcutta High Court in the case of Precision p Ltd. However, as the expla ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... t the Ld. AO was not justify in treating the loan received from above referred five creditors as unexplained cash credit u/s 68 of the Act. Hence, the impugned addition of Rs. 1,40,00,000/- is deleted. Accordingly Ground NO.2 is allowed. 6.4.11. The appellant has also challenged disallowance of interest expense of Rs. 26,45,096/-. The Ld. AO has disallowed the said interest expense in view of his action of treating unsecured loan of Rs. 1,40,00,000/- as unexplained credit u/s 68 of the Act. As discussed above, said addition of Rs. 1,40,00,000/- has been deleted and hence the consequential disallowance of interest pertaining to the same at Rs. 26,45,096/- is also deleted. Accordingly, the ground No. 3 raised in appeal is allowed." 7. The Ld. DR submitted that the Ld.CIT(A) was erred in deleting additions made by the Ld. AO towards unsecured loans of Rs. 1,40,00,000/- taken from companies/associates controlled and operated by Praveen Kumar Jain, who is a entry provider without appreciating the fact that the assesee had admitted during the course of survey proceedings that loans taken from those parties are accommodation entries. The Ld. DR, further submitted that the Ld.CIT(A) has ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... n the case of Dy. CITvs. M/s. Marathon Fiscal Pvt Ltd., 1TA No. 5783/Mum/2017, dated 28,08,2019 2 Decision of Hon. Mumbai ITAT in the case of Dy. CIT vs. M/s. Manba Finance Ltd,, ITA Nos. 1448, 1449 & 1467 / Mum/ 2017, dated 05.10.2018 3. Decision of Hon. Mumbai ITAT in the case of ACIT v. Shreedham Builders, ITA No, 5589/Mum/20l7 dated 22.06.2018,?53 CCH 0212 4. Decision of Hon'ble Mumbai ITAT in the case of DCIT v. M/s Jainam Investments, ITA No.s.6099/Mum/20l6 dated 10.08,2018, 2019-TIOL-213-ITAT-MUM 5. Decision of Hon. Mumbai ITAT in the case of DCIT v. Bairagra Builders P Ltd., ITA Nos. 4691 & 4692/Mum/2015 dated 14.09.2017 6. Decision of Hon. Mumbai ITAT in the case of AClT v A. S Motiwala dated 22.02. 2019, 2019-TIOL-676-1TAT-MUM 7 Decision of Hon, Mumbai ITAT in the case of ITO v. Anant Shelters (R) Ltd., 51 SOT 234(Mumbai) 8. Decision of Hon'ble Mumbai ITAT in the case of ITO vs. M/s ayuresh Logistics Pvt Ltd. dated 24/06/2019, 2019-TIOL-1421-ITAT-MUM 9. Decision of Hon.Mumbai ITAT in the case of DCIT v. M/s Gladiolus Property & Inv. Pvt. Ltd., ITA Nos2924/Mum/2017, dated 16.05.2019 10. Decision of Hon. Bombay High Court in the case of PCTT v. J M/s Skyla ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... it has paid interest on said loans after deducting necessary TDS applicable as per law. Further, these loans have been subsequently repaid over a period of time through proper banking channels. The assessee has also placed on record the retraction statement filed by Praveen Kumar Jain before the investigation wing and argued that once, the statement on which the additions was made was no longer in existence or retracted, then the same cannot be considered as reliable evidence to draw an adverse inference against the assessee, more particularly, when the assesee has discharged its onus by filing necessary evidences. 10. In this factual background, if you examine the case of the assesee, in light of provision of section 68 of the I.T.Act, 1961, we have to decide, whether the transactions between the assesse have passed the test laid down u/s 68 of the Act or not. The provisions of section 68 deals with a cases, where any sum found credited in the books of account of the assessee in any financial year for which the assessee, offers no explanation or explanation offered by the assessee, in the opinion of the AO is not satisfactory, then sum found credited may be treated as income of t ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... s that no cash was introduced prior to advancing loans to the assessee. We, further, observed that the Ld. AO has not brought on record any evidence to suggest that the assessee had paid cash to the loan creditors in lieu of loans received from them. It is also admitted fact that the unsecured loans under consideration have been repaid over a period of a time and also, the assessee has paid interest after deducting necessary TDS applicable as per law. 12. We, further, noted that the assessee has filed enormous details in respect of companies including their PAN details, CIN master data and other details to prove existence of those companies. The assessee also filed details of active status of the company in the website of Ministry of Corporate Affairs. On going through various detailed filed by the assessee, we find that there is no reason for the AO to doubt the genuineness of transactions and creditworthiness of the parties. We further notice that the assessee has filed balance-sheet of all creditors wherein they have huge share capital and reserves and surplus to establish creditworthiness of the parties. We further notice that all companies are having regular business. All the ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... P. Ltd. 1,77,00,000 5. Pragati Gems P. Ltd. 2,25,00,000 6. Sumukh Commercial P. Ltd. 1,15,00,000 7. Viraj Mercantile P. Ltd. 2,00,00,000 8. Lunkad Textile P. Ltd. 50,00,000 9. Falak Trading Co. P. Ltd. 17,00,000 Total 10,91,50,000 On a perusal of the assessment orders, we find, that the A.O had drawn adverse inferences as regards the authenticity of the loans raised by the assessee from the aforementioned parties, for the reason, that the said parties were allegedly operated and controlled by Shri. Praveen K. Jain, an infamous accommodation entry provider. Apart there from, it was observed by him, that in the course of the survey action conducted on the assessee company, its director viz. Shri Chetan R. Shah was unable to divulge the details about the lenders from whom the aforesaid loans had been raised and had admitted that the same were in the nature of accommodation entries. In sum and substance, the authenticity of the loan transactions under consideration was not accepted by the A.O for two reasons, viz. that, the aforesaid concerns were controlled and operated by Shri Praveen K. Jain, an infamous accommodation entry provider, who in the course of se ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... g the said documentary evidence and placing on record any material proving to the contrary was not justified in summarily dislodging the claim of the assessee as regards the authenticity of the loans that were raised by it from the aforementioned parties. 8. We shall in the backdrop of the aforesaid facts deliberate on the observations of the lower authorities. We shall first advert to the statement of Shri Chetan R. Shah, director of the assessee company, which had been heavily relied upon by the A.O for driving home his claim that no genuine loans were raised by the assessee company from the aforementioned lenders. As is discernible from the order of the CIT(A), Shri Chetan R. Shah had during the course of the survey proceedings conducted on the assessee company under Sec.133A, vide his statement dated 25.03.2014, had in his reply to Question no.29 submitted that unsecured loans from parties listed in Table no. 1 and Table no. 2 in the said statements were unsecured loans routed in the books of Marathan Fiscal Pvt. Ltd., Marathan Realty Pvt. Ltd. and Chetan Shah, HUF during the financial years 2011-12, 2012-13 and 2013-14 were in nature of accommodation entries, and had offered ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... of the Act, wherein the authorized officer can examine anybody on "Oath‟, and such statement may be used as evidence in any proceedings under the Act. As the statement recorded under Sec. 133A(3)(iii) of the Act is not recorded on oath, therefore, as had consistently been held by various courts the same has no evidentiary value in absence of any corroborative evidence. In sum and substance, the statement recorded under Sec. 133A can be used to corroborate a state of fact, however, the same on a standalone basis cannot justifiably lead to drawing of any inferences. To sum up, a statement recorded under Sec.133A is simply an information which can be used for corroborative purpose for deciding any issue in favour or against the assessee. In fact, we find that the evidentiary value of a statement recorded under Sec. 133A of the Act has been subjected to judicial scrutiny and the Hon'bleCourts had concluded that the same has no evidentiary value in the absence of any corroborative evidence. Our aforesaid view is fortified by the order of a coordinate bench of the ITAT, Delhi in the case of Mahesh Ohri Vs. ACIT (ITA No.4109 of 2009, dated 08.03.2013) (Del). The Tribunal in its a ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... he Income- tax Act it is not given any evidentiary value obviously for the reason that the officer is not authorised to admin is teroath and to take any sworn statement which a lone has evidentiary value as con temp la ted under law. Therefore, there is much farce in the argument of learned counsel for the appellant that the statemente licited during the survey operation has no evidentiary value and the Income-tax Officer was well aware of this." 9. Similarly, the Hon'ble Madras High Court has also concluded that statement recorded during the course of survey has no evidentiary value. The special leave petition against the decision of the Hon'ble Madras High Court has also been dismissed by the Hon'ble Supreme Court on September 20, 2012. We have examined the record and we do not find any other material collected by the survey team and used by the Assessing Officer for making the addition of Rs. 2 crores . The contention so The learned Departmental representative on the strength of the Hon'ble Karnataka High Court decision is that the Department was prevented by the assessee to conduct further inquiry and, therefore, the assessee can not take a some rsault subsequently . We do no ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... open to the person who made the admission to show that it was incorrect. In the backdrop of the aforesaid judicial pronouncements, it can safely be concluded that the statement recorded during the course of the survey proceedings has no evidentiary value and the same can only be used for corroborative purposes for deciding an issue in the course of the assessment proceedings. Now in the case before us, we find that the assessee in the course of the assessment proceedings had placed on record sufficient documentary evidence to substantiate the authenticity of the loan transactions viz. (i) confirmations of the lenders; (ii) copies of the returns of income for A.Y. 2013-14 of the lender parties; (iii) copies of the annual audited accounts for A.Y. 2013-14 of the lenders parties; and (iv) copy of the bank statements of the lenders. Also, as observed by us hereinabove, the assessee while filing the return of income for the year under consideration had not considered the unsecured loans as its income. In fact, Shri Chetan R. Shah, director of the assessee company had vide his letter dated 01.01.2016 that was submitted during the course of the assessment proceedings categorically withdra ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the same. Accordingly, the Board taking cognizance of the said ground realities had in its aforesaid circular emphasised that the officials in the course of the search & seizure proceedings and survey operations should focus and concentrate on collection of evidence of income which leads to information on what has not been disclosed or is not likely to be disclosed by the assessee before the department, and no attempt should be made to obtain confession as regards the undisclosed income. The said CBDT Circular reads as under: "Instances have come to the notice of the Board where asses see have claimed that they have been forced to confess the undisclosed income during the course of the search & seizure and survey operations. Such confessions, if not based upon credible evidence, are later retracted by the concerned assessee's while filing returns of income. In these circumstances, confessions during the course of search & seizure and survey operations do not serve any useful purpose. It is, therefore, advised that there should be focus and concentration on collection of evidence of income which leads to information on what has not been disclosed or is not likely to be disclosed b ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... rch operations had continued at length for 9 days, therefore, it had taken a toll on his mental faculties. Be that as it may, we find that it is not the case of the revenue before us that the aforesaid person had at any stage in his statement recorded during course of the search proceedings ever alleged that he had provided accommodation entries to the assessee company. We shall in the backdrop of the aforesaid facts emerging from the statement of Shri Praveen Kumar Jain recorded under Sec.132(4) of the Act, which thereafter is stated to have been retracted by him, therein deliberate on the evidentiary value of the same insofar the case of the assessee before us is concerned. As observed by us hereinabove, one of the material aspect which had weighed in the mind of the A.O while concluding that the assessee had obtained accommodation entries from the aforementioned companies which were stated to be operated and controlled by Shri Praveen K. Jain, was the statement of the said person recorded under Sec. 132(4) of the Act. As observed by us hereinabove, it has throughout been the claim of the assessee that the aforesaid person had never stated that he had provided accommodation entri ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... , we are persuaded to subscribe to the view of the CIT(A) that though a statement recorded under "oath‟ is an important piece of evidence however, addition/disallowance cannot be made solely on the basis of such statement in the absence of any corroborative evidence supporting the same. As a matter of fact, in a case where a statement had been retracted by the assessee, it becomes all the more onerous on the part of the A.O to corroborate the statement recorded in the course of the search proceedings on the basis of supporting evidence. As had been observed by various courts, a statement recorded under Sec.132(4) is treated as a piece of evidence in the proceedings under the Act, as long as the same is not retracted. However, in case the assessee retracts the statement, the evidentiary value of the said statement suffers a serious dent. Accordingly, the mandate envisaged under sub-section (4) of Sec.132 of using the statement as evidence in any proceedings under the Act gets honoured only when there is no other version of the assessee vis-a-vis the said statement. To sum up, a statement recorded under Sec.132(4) has though an evidentiary value, however, the same cannot be asc ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... s an extremely important piece of evidence but it cannot be said that it is conclusive. It was observed by the Hon'ble Apex Court that it was open to the person who made the admission to show that it was incorrect. Relying on the aforesaid judgment of the Hon'ble Apex Court, we find, that a coordinate bench of the Tribunal viz. ITAT, Mumbai in the case of Tribhuvandas Bhimji Zaveri, ITA No. 2250 & 2251/Mum/2013, dated 04.11.2015, had drawn an analogy and had observed that though an admission made in a statement recorded under Sec.132(4) is an extremely important piece of evidence but it cannot be said that it is conclusive as it is open to the person who made the admission to show that it is incorrect. We further find that the Hon'ble High Court of Gujarat in DCIT (Investigation) Vs. Narendra Garg & Ashok Garg (AOP) (ITA No. 1531 & 1532 of 2007, dated 28.07.2016), had held, that as the assessee had retracted from his statement recorded under Sec.132(4), which though was not accepted by the revenue, therefore, it was incumbent on the part of the A.O to have supported the addition made on the basis of the disclosure made by the assessee in his aforesaid statement on the basis of ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... t he had provided any accommodation entries to the assessee company. We also cannot remain oblivious of the fact that in the absence of any corroborative evidence the statement of the aforementioned "third party‟ viz. Shri Praveen K. Jain could not be used in isolation for drawing of adverse inferences in the hands of the assessee. Apart therefrom, we find that as is discernible from the assessment order, though the assessee had sought a "cross- examination‟ of Shri Praveen Kumar Jain, whose statement was being heavily relied upon by the A.O for drawing of adverse inferences in its hands, however, the same was not allowed to him. In our considered view, the aforesaid failure on the part of the A.O to allow a cross- examination of the aforementioned party viz. Shri Praveen Kumar Jain is in itself a flagrant violation of the basic tenets of the principle of natural justice. Our aforesaid view is fortified by the judgment of the Hon'bleSupreme Court in the case of Andaman Timber Industries Vs. Commissioner of Central Excise (2015) 281 CTR 241 (SC). In the said case, it was observed by the Hon'ble Apex Court that not allowing the assessee to cross-examine the witnesses whos ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... upon the observations of the A.O on the basis of which he had declined to accept his aforesaid claim. As is discernible from the orders of the lower authorities, the assessee in order to drive home its claim that it had raised genuine loans from the aforementioned 9 parties had placed on record supporting documentary evidence viz. (i) confirmations of the lenders; (ii) copies of the returns of income for A.Y. 2013-14 of the lender parties; (iii) copies of the annual audited accounts for A.Y. 2013-14 of the lenders parties; and (iv) copy of the bank statements of the lenders from where the loans were advanced to the assessee company. As a matter of fact, the CIT(A) had specifically referred to the documentary evidence placed on record by the assessee on a party wise basis, as under : "a. M/s Atharv Business P. Ltd. The appellant has submitted the copy of confirmation letter for relevant assessment year, copy of acknowledgement of return of income of relevant assessment year , copy of annual audited accounts of relevant assessment year, copy of relevant pages of bank statement of them and itself to establish that the transactions were carried out through proper banking channel. ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... nel. h. M/s Lunkad Textile P Ltd- The appellant has submitted the c o p y o f confirmation letter for relevant assessment year, copy of acknowledgement of. ret urn of income of relevant assessment year , copy of annual audited account so frelevant assessment year, copy of relevant pages of bank statement of them and itself to establish that the transactions were carried out through proper banking channel. i. M/s Falak Trading P Ltd- The appellant has submitted the copy of confirmation letter for relevant assessment year, copy of acknowledgement of return of income of relevant assessment year , copy of annua l audited accounts of relevant assessment year, copy of relevant page so bank statement of them and itself to establish that the transactions were carried out through proper banking channel" We find that the assessee by placing on record the aforesaid documentary evidence had discharged the primary 'onus' that was cast upon it to prove the authenticity of the loan transactions entered into with the aforementioned 9 parties under consideration. However, the veracity of the claim of the assessee was not accepted by the A.O on the basis of generalised observation that t ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... .O neither carried out any verifications on his own nor directed the assessee to clarify any further aspects pertaining to the authenticity of the loan transactions under consideration. As regards the observation of the A.O that the assessee had not produced the parties, we find, that there is nothing discernible from the records from where it could be gathered that he had ever directed the assessee for doing the needful. In fact, in our considered view, now when the assessee in discharge of the primary "onus‟ that was cast upon it to substantiate the authenticity of the loan transactions had placed on record sufficient documentary evidence which had not been rebutted by the A.O, therefore, merely for the reason that the said lenders had not appeared before him would even otherwise not justify characterising the said loan transactions as bogus/sham. Our aforesaid view is fortified by the judgment of the Hon'ble High Court of Bombay in the case of Commissioner of Income Tax-8 Vs. M/s Orchid Industries Pvt. Ltd. (2017) 397 ITR 136 (Bom). In the aforesaid case, it was observed by the Hon'ble High Court that now when the assessee had placed on record documentary evidence to s ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... t was observed by the Tribunal that a perusal of the Bank account of the lender party viz. M/s Natasha Enterprises revealed that after the loan of Rs. 10,00,000/- was advanced to the assessee the balance in the bank account remained at a meagre figure of Rs. 13,717/- only. On a similar footing, it was noticed by the Tribunal that on various other dates also after the amounts were advanced from the bank account of the lender the closing balance of the respective days would remain between few thousands of rupees. Further, it was observed, that though the lender had shown a substantial turnover of 122.92 crores, but there was no closing stock. Also, certain peculiar facts as regards the meagre expenses incurred by the lenders were also noticed, which thus did not inspire any confidence as regards the genuineness of the business transactions of the said respective concerns. Similarly, it was observed that the facts involved in the case of the other lender party viz. M/s Mohit International also did not reveal any different story. To sum up, in the aforementioned case, it was conclusively proved on the basis of the facts borne from the records that the lenders were not carrying out any ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... had emerged in the course of the search proceedings conducted on him. We are afraid that the adverse inferences drawn by the A.O as regards the authenticity of the loan transactions under consideration without any attempt to dislodge the documentary evidence placed on record by the assessee to support its claim, cannot be sustained and is liable to be vacated. Our aforesaid view is fortified by the order of the ITAT "C" Bench, Mumbai, in the case of ITO 20(2)(5), Mumbai Vs. Smt. Pratima Ashar (2019) 107 taxmann.com 135 (Mum), wherein a similar view was taken. At this stage, we may herein observe that similar adverse inferences as regards the authenticity of the loan transactions that were drawn by the A.O. in the case of a "sister concern‟ of the assessee company viz. M/s Manba Finance Ltd., were on appeal deleted by the CIT(A). On further appeal by the revenue, the order passed by the CIT(A) was upheld and the appeal of the revenue was dismissed vide order passed by a coordinate bench of the Tribunal viz. Dy. CIT-CC-7(2), Mumbai Vs. M/s Manba Finance Ltd., (ITA Nos. 1448, 1449 & 1467/Mum/2017, dated 05.10.2018) (copy placed on record). As is discernible from the aforesaid o ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... and therein concluded that the A.O in the absence of the corroborative evidence was not justified in treating the loans received by the assessee before them as unexplained cash credit under Sec. 68 of the Act. 13. We have given a thoughtful consideration and are of the considered view, that the CIT(A) after deliberating at length on the issue under consideration had rightly concluded that as the assessee had discharged the "onus‟ that was cast upon it under Sec.68 of the Act, therefore, the A.O was not justified in treating the loans received from the aforementioned parties as unexplained cash credits under Sec.68 of the Act. We thus not finding any infirmity in the well reasoned order of the CIT(A) to the extent he had deleted the addition of Rs. 10,91,50,000/- uphold the same. The Grounds of appeal No. (i) & (ii) raised by the revenue are dismissed. 14. We shall now advert to the disallowance of the interest expenditure of Rs. 70,49,112/- that was claimed by the assessee to have been paid to the aforementioned 9 lender parties. We find that the aforesaid claim of expense of the assessee was disallowed by the A.O, for the reason, that the loan transactions under consider ..... X X X X Extracts X X X X X X X X Extracts X X X X
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