9911796707
TMI Blog2022 (2) TMI 975X X X X Extracts X X X X X X X X Extracts X X X X ..... erce or business specially looking into the proportion of receipts from such activities therefore, the activities carried on by the assessee are not exempted in view of the section 13(8) HELD THAT:- We observe from the record that assessee was granted 12A registration and continues to enjoy as the trust is established with the object to promote education. It is also fact on record that assessee was treated as an institution to promote the education and cause for promoting the education over the years until the present impugned Assessment year in which Assessing Officer after considering the object and activities of the assessee and came to the conclusion that assessee is hit by the proviso to section 2(15) of the Act and he categorized the assessee under the category of advancement of any other general public utility. We observe from the record that assessee is engaged in the formal form of Certification course of Astronomy and Astrophysics with collaboration with Mumbai University. The Annual Report submitted by the assessee gives detailed discussion of the Education activities carried on by the assessee, it is also found that the assessee is imparting the education in the form of ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... n and skills not only offline but online as well and that is also not confined to basic education like languages, sciences etc., but also encompasses the entire gamut of universe. We are in agreement with the decision of the Ld.CIT(A) that most of the institutions depends on voluntary donations and contributions and aid from government and income from property held by the trust by way of rent and assessee also depends wholly on the investments from which it derives interest and also income from the property held in trust by way of rent which are ultimately applied to meet the objects of the trust, that is, education and in certain ways to meet the objects of general public utility No reason to interfere in the conclusions reached by the Ld.CIT(A) that assessee was engaged in charitable activity and for the purpose of advancing its objects; it earned income which was incidental to its activities. He also came to the conclusion that it is an institution which imparts education and fulfills the basic condition laid down in section 2(15) of the Act. Therefore, the proviso to section 2(15) of the Act does not arise in the case of the assessee. With the above observations and facts on re ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... owledge relating to Nehru's ideas and philosophy and the aims and objects of the society by means of oral instructions, publication of literature and holding dramatic competitions, exhibitions and demonstrations on no profit basis calculated to advance and achieve the above objects No systematic education by normal schooling has been undertaken by the assessee. The rest of the objects can be termed as Advancement of General Public utility 5. Doing all such other lawful things as are incidental to the attainment of the above subjects No systematic education by normal schooling has been undertaken by the assessee. The rest of the objects can be termed as Advancement of General Public utility Further he analysed with the type of receipts as under: Sr. No Nature of receipts Amount Nature of activity and relation with charitable purpose as defined in section 2(15) Whether incidental to charitable purposes of assessee and separate books of accounts maintained for the receipts other remarks as required u/s.11(4A) 1. Compensation received for providing space for 26 commercial exhibitions throughout the year 1,61,19,990 At the most as General Public utility. It is in th ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... l Public utility. It is in the nature of business and rendering services to trade, commerce of parties. Hit by first proviso to section 2(15) Not incidental as it was used by outside agencies and that too for commercial purposes. No separate books of accounts maintained. 8. Compensation n received for providing dubbing unit throughout the year. 3,58,333 At the most as General Public utility. It is in the nature of business and rendering services to trade, commerce of parties. Hit by First proviso to section 2(15). Not incidental as unit was used by outside agencies and that too for commercial purposes. No separate books of accounts maintained 9. Compensation n received for providing Warli Hall who are we Hall and mezzanine floor 3,08,500 At the most as General Public utility. It is in the nature of business and rendering services to trade, commerce of parties. Hit by first proviso to section 2(15). Not incidental as unit was used by outside agencies and that too for commercial purposes. No separate books of accounts maintained. 10. Planetarium show receipts. 3,98,146 persons watched the show throughout the year. 1,24,36,540 General Public utility. Cannot be considere ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... defined under section 2(15) of the Act is not limited to teaching in the narrow sense raising the artistic taste of the country by public performances, dramas, music or show would be in the nature of education purpose. Also the word is defined in the Oxford dictionary as, is the process of receiving or giving systematic instruction, especially at a school or university, the theory and practice of teaching, a body of knowledge acquired while being educated, information or training a particular subject or example health education is education does not necessarily imply only that which is imparted in a classroom with fixed curriculum. 5. After considering the submissions of the Assessee, Assessing Officer rejected the claim of the assessee and treated the income earned by the assessee out of commercial exhibitions, auditorium etc., as not for charitable to the extent of ₹.426,62,090/- with the following observations: "10 Assessee submission with respect to some of the activities it undertakes is true in the sense that it spends some income on these activities. However as explained in detail above table when assessee is hit by proviso to section 2(15) how it spends its income ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... undertaking is commercially exploiting its property. Getting income by way of providing space for commercial exhibitions, for professional and artists Gallery exhibits, preview shows, the dubbing unit, corporate functions meetings is in no way indulging in charitable purpose of social and cultural activities. In this connection it is worthwhile to study the definition of charitable purpose effective as on date: "Charitable purpose: includes "relief of the poor, education, medical relief and the advancement of any other object of general public utility." The line, "not involving the carrying on of any activity for profit" was omitted by the Finance Act, 1983, w.e.f. 1 --4-1984. Thus with effect from 1 April 1984; whether there is any profit motive or not is not relevant. Further section 13 (8) provides that Nothing contained in section 11 or section 12 shall operate so as to exclude any income from the total income of the previous year of the person in receipt thereof if the provisions of the first proviso to clause (15) of section 2 become applicable in the case of such person in the said previous year. 10.5 Though assessee is spending some of it ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... first proviso to section 2(15); object/activities need not be business itself but it being 'in nature of business, trade, or commerce' is sufficient for disqualification. As rent and service charges are considered as business receipts and it contravened the provisions of section 11 of LT. Act, AO was of the opinion that assessee is not behaving as a charitable organization and the character and focus of assessee is commercial. For these reasons, AO denied the benefit of Section 11 and assessed the income at ₹ 7,12,93,545 by considering corpus receipt relating to the property and interest as income of the year and allowing the expenditure relating to such income. 3. The assessee was requested to explain why the receipt of the assessee Should not be taxed denying the exemption under section 11 of IT act 1961. With reference to the above Appeal, the assessee made the following submission vide its letter dated 6" February 2016 as well as further submissions as under. 1. Ground of Appeal No.1 : On the basis of the facts and the position in law, the Assessing Officer erred in taking the view that all the activities carried out by the trust are in the nature of advancem ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... teachers from the Homi Bhabha Centre for Science Education, an improvised laboratory is established for the workshop and the entire expenditure is borne by Nehru Centre. A foundation Course in Astronomy of eight months duration is organized every year in collaboration with the Department of Extramural Studies of Mumbai University. Students of astronomy are taken to places away from Mumbai, where the sky is clear and free from urban lights and pollution, to study the night sky and various astronomical phenomenon like the movement of planets and the eclipses. Every summer Nehru Centre organizes workshops in performing arts viz. dance, drama and classical music. Great Masters like late Guru Kelucharan Mahapatra, Birju Maharaj, Dr. Kanak Rele and so many others teach thousands of young students. In the field of history and culture, the type of education that Nehru Centre imparts is perhaps not given in any school or college. For example, the Centre has a regular audio visual show titled "Who Are We". This eight minute visual explains most vividly that India is the greatest amalgam of races and religions, languages and culture of diversity and contrast unmatched on the globe. In w ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e B). The aims and objectives of Nehru Centre have been spelt out in its Memorandum of Association. Nehru Centre was not funded by any agency or the government. Therefore, the Government of Maharashtra vide its circular dated 14/6/1988 (copy enclosed) granted permission to Nehru Centre to utilise 15% of its area for the purpose of earning revenue with which it could sustain itself and fulfill its objectives. Even though various exhibitions are held at Nehru Centre no counter sale is allowed. It is, therefore, erroneous to conclude that income that Nehru Centre derives by letting out its premises (limited to 15% of its total area) is derived out of trade, commerce or business. In support of the above stated facts, we wish to rely upon the latest judgment of Hon. Delhi High Court in the case of Institute of Chartered Accountants of India v/s DIT(E) (2013)35 Taxmann.com 140 (Delhi) (copy enclosed). In brief, the court has held as follows: S. 2(15) - Charitable purpose is not affected on levy of fees The ICAI does not carry on any business, trade or commerce. The activity of imparting education in the field of accountancy and conducting courses both at pre-qualification as well a ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... stead of allowing the same in full as application of Income. 4) Ground of Appeal No. 4: The Assessing Officer erred in taking the view that the hiring charges received by the Centre, by renting of its property, are not in the nature of income derived from property held under trust and is taxable after allowing the expenditure only in relation to the property. Now it is clear that the AO has only changed the interpretation of the activities of the Appellant Trust to fit into the category of general public utility only to fit it into the amended proviso without any justification. Further he has allowed as deduction only part of the expenses incurred towards the objects of the Trust instead of allowing the same in full as application of income. 5) Ground of Appeal No. 5 The Assessing Officer erred in taking the view that the compensation and hiring charges received from property are in the nature of business or commerce and thus section 11(4A) would be applicable. AO has completely misinterpreted Section 11(4A) of the Act by stating that the same is applicable only to deny the exemption. The income of the Appellant Trust is not out of profits and gains of any business and ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ated the Principle of Consistency. (i) We rely on the judgment of the Bombay High court in the case of Shri Ram Memorial Foundation 158 ITR 1. In which The Hon'ble High Court has held that when a particular party has been recognized as such for several years and is carrying on the same object without any protest it is not for the Court to reopen the same point from time to time. (ii) In the case of Excel Industries Ltd 358 ITR 295 the Apex court held that "Further, as in several assessment years, the Revenue accepted the order of the Tribunal in favour of the assessee and did not pursue the matter any further, it cannot be allowed to flip-flop on the issue and it ought to let the matter rest rather than spend the tax payers' money in pursuing litigation for the sake of it'. (iii) We further rely on the Judgment of Bombay High Court in the case of CIT vs. Gopal Purohit 228 CTR 582 (Bom) wherein it was held that "there should be uniformity in treatment and consistency when facts and circumstances are identical particularly in the case of the assesse". (iv) The Jurisdictional Mumbai Tribunal in the identical case of Shamukhanand Fine Arts and Sangeeta Sabha 1975/M/2016 & 6 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... mentioned Sec 11(4A) of the I.T Act. Further, earning of such receipts was incidental & not the Predominant activity of the Trust. (i) Further the issue of letting out of the hall has been deliberated in following decision: The Jurisdictional Bombay High Court in the case of Fellowship of Physically Handicapped I.T. Appeal No. 673 of 2013 held as under: We find that the CIT(A) as well as the Tribunal on examination of the record have determined that income derived from its property by respondent assesse should be treated as income form house property and not the business Income. This finding of the CIT(A) is upheld by the impugned order. We find that as two authorities under the act have concurrently come to a finding on the fact that the amount received by the respondent assessee on account of letting out of its property is income taxable under the head income from house property. Thus no occasion to apply section 11(4A) of the Act as canvassed by the revenue would arise. (ii) We further rely on the following judgment of the Bombay High Court wherein it was held that letting of hall cannot be treated as business or commercial activity ' (a) The Lajpatrai Memorial Trust 3 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... n's India Trust and it reads as under: "The assessee-trust formed to carry out the object of education and development. of natural talents of people having special skills, more particularly women. It trained them to earn while learning. It educated them in the field of catering, stitching, toy making, etc. While giving them training, it used material bought from the open market. This was essential for carrying out the assessee's object. In the process, some finished product such as pickles, jam, etc., were produced and which the assessee sold through shops, exhibitions and personal contacts. The motive of the assessee was not the generation of profit but to provide training to needy women in order to equip or train them in these fields and make them selfconfident and self-reliant. There was nursing training, which was also being managed and administered by the assessee. The details of income and expenditure showed that the assessee had received donations of ₹ 36, 88,634 and nursing school fees of ₹ 4,46,088. The assessee pointed out that this nursing training provided at the center of the assessee at Panvel was free of cost. The charge was levied for the mess but acco ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ss in the various activities, carried out by it, to the tune of ₹ 32 lakhs (app.) except for eye care department and interest on investment (Pg.50,52, 56-57 of the PB). A perusal of Pgs. 82-84 reveal that expenditure incurred by it during the year under appeal. pertained to overall administration and activities. In other words the said expenditure would have to be incurred even if the SH was not let out.SH was rented out when it was not required by the assessee for its own purpose. Here, one important factor to be remembered is that it could continue to carry out various charitable activities and could achieve the objects at concessional rates due to income received by it from letting out of SH. Conclusion of Mumbai [TAT Decision in the case (SH -Trust) is applicable in our assessee case: As the relevant facts in our case are similar to that in the Case of SH - Trust, therefore, the Bombay ITAT's concluding following decision is applicable in our case also. In the appellant trusts case also the appellant is having losses on carrying out education activity and other object of the Trust and that loss has been financed by the interest income and income form letting out of ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... cular no. 10 134/34/2008-TPL dated 19.12.2008 which reads as under: EXEMPTION UNDER SECTION 11 IN CASE OF ASSESSEE CLAIMING BOTH TO BE CHARITABLE INSTITUTIONS AS WELL AS MUTUAL ORGANISATIONS CIRCULAR NO. 11/2008, DATED 19-12-2008 Definition of 'Charitable purpose' under section 2(15) of the Incometax Act, 1961 Section 2(15) of the Income Tax Act, 1961 ('Act') defines "charitable purpose" to include the following: (i) Relief of the poor (ii) Education (iii) Medical relief, and (iv) the advancement of any other object of general pubilc utility. An entity with a charitable object of the above nature was eligible for exemption from tax under section 11 or alternatively under section 10(23C) of the Act. However, it was seen that a number of entities who were engaged in commercial activities were also claiming exemption on the ground that such activities were for the advancement of objects of general public utility in terms of the fourth limb of the definition of 'charitable purpose'. Therefore, section 2(15) was amended vide Finance Act, 2008 by adding a proviso which states that the 'advancement of any other object of general public utility' shall not be a charit ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ecided based on the nature, scope, extent and frequency of the activity. 3.1. There are industry and trade associations who claim exemption from tax u/s 117 on the ground that their objects are for charitable purpose as these are covered under 'any other object of general public utility'. Under the principle of mutuality, if trading takes place between persons who are associated together and contribute to a common fund for the financing of some venture or object and in this respect have no dealings or relations with any outside body, then any surplus returned to the persons forming such association is not chargeable to tax. in such cases, there must be complete identity between the contributors and the participants. Therefore, where industry or trade associations claim both to be charitable institutions as well as mutual organizations and their activities are restricted to contributions from and participation of only their members, these would not fail under the purview of the proviso to section 2(15) owing to the principle of mutuality. However, if such organizations have dealings with non-members, their claim to be charitable organizations would now be governed by the additiona ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... about applicability of proviso to section 2(15) of the Act. We find that the AO as well as the FAA has emphasized the fact that the provisions of the proviso to the section 2(15) the assessee was not entitled to claim the benefit of section 11 of the Act. We would like to reproduce the proviso and it reads asunder - (15) "charitable purpose" includes relief of the poor, education, medical relief, preservation of environment (including watersheds, forests and wildlife) and preservation of monuments or places or objects of artistic or historic interest, and the advancement of any other object of general public utility : Provided that the advancement of any other object of general public utility shall not be a charitable purpose, if it involves the carrying on of any activity in the nature of trade, commerce or business, or any activity of rendering any service in relation to any trade, commerce or business, for a cess or fee or any other consideration, irrespective of the nature of use or application, or retention, of the income from such activity." If we consider the various activities carried out by the assessee, as evident from the various pages of the PB, it is clear that i ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... tants of India (358 ITR 91), wherein the Hon'ble Delhi High Court has held as under: "A plain reading of section 2(15) of the Income-tax Act, 1961, indicates that the expression "charitable purpose" has been divided into six categories, namely, (i) relief to poor, (ii) education, (iii) medical relief, (iv) preservation of environment including watersheds (forest and wildlife), (v) preservation of monuments and places or objects of artistic or historical importance, and (vi) advancement of any other object of general public utility. The first proviso to section 2(15) of the Act carves out an exception which excludes advancement of any other object of general public utility from the scope of charitable purpose to the extent that it involves carrying on any activity in the nature of trade, commerce, or business or any activity of rendering certain services in relation to any trade, commerce, or business, for a cess or fee or any other consideration is irrespective of the nature of the use or obligation, or retention of the income from such activity. The expressions 'trade', "commerce" and "business", as occurring in the first proviso to section 2(15) of the Act, must be read in th ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... anti Trust Supra must be treated as the business incidental attainment of the objective of the trust. As submitted the appellant is duly maintaining the record of income and expenditure of the hall the case of the appellant comes under exceptional category of the provision of section 11(4A). FINANCE MINISTER'S BUDGET SPEECH Reference to the proposal in the budget Speech of Finance Minister is most cursory. Paragraph 180, wherein the Finance Minister has referred to the amendment, is in the following words: "180. 'Charitable Purpose' includes relief of the poor, education or medical relief. and any other object of general public utility. These activities are exempt, as they - should be. However, some entities are carrying on regular trade, commerce or business or providing services in relation to any trade, commerce or business and earning incomes have sought to claim that their purposes would also fall under 'charitable purposes'. Obviously this is not this was not the intention of the parliament and hence | propose to amend the law to exclude the aforesaid cases. Genuine Charitable organisation will not in any way be affected". (Enclosure - F) According to GOI, MOF , it is ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... recent decision of ITAT Mumbai in the case of Sanmukhanand Fine Arts & Sangeet Sabha, and Judgment of Bombay High Court in the case mentioned in para 18 , we pray to appreciate the grounds and oblige." 8. After considering the detailed submissions and the additional grounds of appeal filed by the assessee Ld.CIT(A) allowed the appeal filed by the assessee and adjudicated that the assessee is not hit by the proviso to section 2(15) of the Act with the following observations: "Crux of the matter is whether the assessee is engaged in the activity for charitable purposes.as defined in section 2(15) of the I.T. Act, 1961 or not and if so what is the nature of that activity that is classifiable and qualifies as a charitable activity. There are four limbs of charitable purposes in section 2(15) of the I.T. Act, 1961 out of which 'relief of the poor, education' and medical relief and preservation of monuments .................and the fourth one is 'objects of general public utility". The proviso comes into the picture only in respect of the fourth activity that is 'advancement of general public utility. It appears from the objects and the activities carried on by the assessee that 't ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... field of paintings photography, sculpture and artistic installations over decades and the role of these institutes in 'spreading and educating general mass of people with knowledge in these fields' is phenomenal. Most of such institutions survive on 'voluntary donations and contributions' and/or government aid and/or income derived from investments by way of interest and dividends' and 'property held in trust by way of rent '. And that is exactly the case with the assessee. Assessee has investments from which it derives interest and also has 'property held in trust' from which it derives income by way of rent which are ultimately applied to meet the 'objects of the trust, that is, education and sometimes meeting objects of general public utility. It can be observed from the income and expenditure account that 'most of these charitable activities do not generate any surplus and there is always a deficit which is generally met with by surplus arising from the net rental and interest income after defraying general expenses. It can also be observed from the balance sheet that a large chunk of land was given to the assessee for a nominal fee and government has also given it a grant in ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... t of general public utility by virtue to proviso, would be excluded from the definition of "charitable trust". However, for the application of the proviso, what is necessary is that the entity should be involved in carrying on activities in the nature of trade, commerce or business, or any activity of rendering services in relation to any trade, commerce or business, for a cess or fee or any other consideration. In such a situation, the nature, use or application, or retention of income from such activities would not be relevant. Under the circumstances, the important elements of application of proviso are that the entity should be involved in carrying on the activities of any trade, commerce or business or any activities of rendering service in relation to any trade, commerce or business, for a cess or fee or any other consideration. Such statutory amendment was explained by the Finance Ministers speech in the Parliament. Relevant portion of which reads as under:- I once again assure the House that genuine charitable organizations will not in any way be affected. The CBDT will, following the usual practice, issue an explanatory circular containing guidelines for determ ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... would now be governed by the additional conditions stipulated in the proviso to section 2(15). 3.2 In the final analysis, however, whether the assessee has for its object the advancement of any other object of general public utility is a question of fact. If such assessee is engaged in any activity in the nature of trade, commerce or business or renders any service in relation to trade, commerce or business, it would not be entitled to claim that its object is charitable purpose. In such a case, the object of general public utility will be only a mask or a device to hide the true purpose which is trade, commerce or business or the rendering of any service in relation to trade, commerce or business. Each case would, therefore, be decided on its own facts and no generalization is possible. Assessees, who claim that their object is charitable purpose within the meaning of section 2(15), would be well advised to eschew any activity which is in the nature of trade, commerce or business or the rendering of any service in relation to any trade, commerce or business. 7. What thus emerges from the statutory provisions, as explained in the speech of Finance Minister and the CBDT Circula ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... . CIT(A) Is right in view of the fact that the definition of charitable activities has been amended by insertion of proviso to section 2(15) of the IT. Act and even if, the assessee's objects are considered charitable, they will fall in the category of the "advancement of any other object of general public utility" attracting proviso to sec. 2(15) of I.T. Act on income from the activities such as exhibitions of commercial entities, professional artists, space for corporate meetings and functions etc. which clearly are activities in the nature of commerce or business specially looking into the proportion of receipts from such activities in overall activities clearly showing that it is the main activity of assessee and therefore such income is not exempt in view of section 13(8) of I.T. Act, 1961". 2. "Whether on the facts and circumstances of the case and in law, the Ld. CIT(A) is right in holding that income from letting out the properties is not a business income but income from house property and thus the provisions of section 11(4A) and proviso to section 2(15) will not apply in the assessee's case despite the fact that the objects of the trust are only in the nature of "advan ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... red the rival submissions and material placed on record, we observe from the record that assessee was granted 12A registration and continues to enjoy as the trust is established with the object to promote education. It is also fact on record that assessee was treated as an institution to promote the education and cause for promoting the education over the years until the present impugned Assessment year in which Assessing Officer after considering the object and activities of the assessee and came to the conclusion that assessee is hit by the proviso to section 2(15) of the Act and he categorized the assessee under the category of advancement of any other general public utility. We observe from the record that assessee is engaged in the formal form of Certification course of Astronomy and Astrophysics with collaboration with Mumbai University. The Annual Report submitted by the assessee gives detailed discussion of the Education activities carried on by the assessee, it is also found that the assessee is imparting the education in the form of organizing various workshop/lectures/Conferences apart from providing the certificate course. It is also fact on record that assessee is also ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... history of India and Nehruvian thoughts from time to time. It is observed that Ld.CIT(A) answered to the re-defining of the above activities by the Assessing Officer that these are not for the purpose of education. The Ld.CIT(A) observed that 'education' is a very wide term which covers not only the skills and information imparted in schools and colleges but also covers the entire field of any institution which disseminates 'information and skills' not only offline but online as well and that is also not confined to basic education like languages, sciences etc., but also encompasses the entire gamut of universe. We are in agreement with the decision of the Ld.CIT(A) that most of the institutions depends on voluntary donations and contributions and aid from government and income from property held by the trust by way of rent and assessee also depends wholly on the investments from which it derives interest and also income from the property held in trust by way of rent which are ultimately applied to meet the 'objects of the trust, that is, education and in certain ways to meet the objects of general public utility. Ld.CIT(A) allowed the appeal of the assessee based on the facts ava ..... X X X X Extracts X X X X X X X X Extracts X X X X
|
