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TMI Blog2022 (5) TMI 1171X X X X Extracts X X X X X X X X Extracts X X X X ..... eason to interfere into the finding disallowing the claim of interest paid on TDS TCS - Thus, ground no. 1 raised by the assessee is dismissed. Deduction u/s 80IA(4)(iii) - HELD THAT:- Looking to the fact that since as on date the said industrial park is not eligible for deduction u/s 80IA(4)(iii) of the Act for want of being noticed by CBDT, the ld. CIT(A) has rightly denied the claim, however, presently the matter is subjudice before the Hon ble Calcutta High Court and whenever the judgment is passed by the Hon ble Court and if held in favour of the assessee then the assessee shall be eligible to put forth the claim before the Revenue authorities to allow the deduction u/s 80IA(4)(iii) of the Act, else the finding of the ld. CIT(A) will remain confirmed. Thus ground no. 2 of the assessee s appeal is dismissed. Disallowance u/s 14A of the Act comprises of interest disallowance - Hon ble High Court of Bombay in the case of Commissioner of Income-tax vs. Reliance Utilities Power Ltd [ 2009 (1) TMI 4 - BOMBAY HIGH COURT] we are of the view that interest disallowance u/s 14A of the Act at Rs.60,03,465/- is uncalled for. We also find that the requirement of sub-Section ( ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ature of business loss. We also find no infirmity in the finding of the ld. CIT(A) allowing the claim of bad debts as these were the sales/rental made in the past offered as revenue but being not realizable has been claimed as bad debts in the regular books of account and this claim has been rightly made in view of the ratio laid down by the Hon ble Supreme Court in the case of TRF Ltd. [ 2010 (2) TMI 211 - SUPREME COURT] - we confirm the finding of the ld. CIT(A) and dismiss the ground no. 5 raised by the Revenue. Deduction u/s 80IB(10) of the Act in respect of projects namely Salarpuria Serenity and Salarpuria Sanctity - HELD THAT:- We find that deduction u/s 80IB(10) of the Act are given for housing projects in a manner of granting incentive to the developers and builders to take up such projects so as to fulfil the housing needs of the citizen of our country. It includes planning of such housing projects, earmarking of the project land, taking various approvals from the local authority for the construction, arrangement of funds to construct the projects, getting the completion certificate and then finally selling the same. Though all the conditions are very important ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... details were called for to examine the claim made for deduction u/s 80IA of the Act, disallowance u/s 14A of the Act, interest expenditure and interest free advances, unsecured loans, application of the provisions of Section 68 Section 40(a)(ia) of the Act, interest on service tax and TDS and miscellaneous other issues. After considering the submissions of the assessee ld. AO assessed the income at Rs.55,13,56,730/- after making following additions to the gross total income of the assessee of Rs.47,96,15,068/- shown by the assessee in the computation of income in the following manner: PARTICULARS AMOUNT (RS.) Gross Total Income as per computation RS.47,96,15,068/- Add: As per above discussion 1. Disallowance u/s 14A (refer para 5) Rs. 1,02,66,118/- 2. Interest free Advances (refer para 6) Rs. 1,00,89,940/- 3. Capital Suspension Account (refer para 7) Rs. 17,90,15,000/- 4. Expenses u/s 40(a)(ia) (refer ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... . 3. For that your petitioner craves the right to put additional grounds and/or to alter/amend/modify the present grounds at the time of hearing. 4.2. Grounds raised by the Revenue: 1. On the facts and circumstances of the case, the Ld CIT(A) is not justified in law as well as on facts by allowing the appeal of the assessee regarding disallowance of Rs.1,02,66,118/-u/s.14A r.w. Rule 8D (Rs. 60,03,465/- under Rule 8D(2)(ii) and Rs.42,62,653/- under Rule 8D(2)(iii). 2. On the facts and circumstances of the case, the Ld CIT(A) is not justified in law as well as on facts by allowing the appeal of the assessee regarding addition of Rs.1,00,89,940/- out of interest debited/paid by the assessee. 3. On the facts and circumstances of the case, the Ld CIT(A) is not justified in law as well as on facts by allowing the appeal of the assessee regarding addition of Rs.17,90,15,000/- by invoking the provision of Sec.68 of the Act. 4. On the facts and circumstances of the case, the Ld CIT(A) is not justified in law as well as on facts by allowing the appeal of the assessee regarding addition of Rs.12,92,185/- being interest on service tax. 5. On the facts and cir ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 86/- and penalty on sales tax of Rs.34,352/-. During the course of hearing, ld. Counsel for the assessee requested for not pressing the disallowance of penalty on sales tax at Rs.34,352/- and, therefore, the said disallowance is confirmed. Remaining amount is interest on TDS TCS at Rs.13,486/-. On going through the finding of the ld. CIT(A), we find no reason to interfere into the finding disallowing the claim of interest paid on TDS TCS at Rs.13,486/-. Thus, ground no. 1 raised by the assessee is dismissed. Ground No. 2: 5.2. Through ground no. 2 assessee has raised the issue of denial of deduction u/s 80IA(4)(iii) of the Act at Rs. 13,58,03,793/-. At the outset, ld. Counsel for the assessee submitted that the said deduction was claimed for the profits arising from industrial park namely Salarpuria Touchstone which has been confirmed by the ld. CIT(A) for want of notification to be issued by Central Board of Direct Taxes (in short CBDT ). The issue of CBDT not issuing notification for the said industrial park is already subjudice before the Hon ble Calcutta High Court and the decision is awaited. 5.3. We, therefore, looking to the fact that since as on date the s ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e requirement of sub-Section (2) of Section 14A of the Act is not fulfilled by the ld. AO as there is no specific finding that why he was not satisfied with the correctness of the claim of the assessee of having not incurred any expenditure for earning exempt income. Thus, under these given facts and the settled judicial precedence, no disallowance u/s 14A of the Act was called for by the ld. AO. Thus, ground no. 1 raised by the Revenue is dismissed. Ground No. 2: 7.3. Through this ground, the Revenue has challenged the finding of the ld. CIT(A) deleting the disallowance of interest paid/debited at Rs.1,00,89,940/. 7.4. Brief facts relating to this issue are that the assessee debited total interest of Rs. 3,38,18,940/-. Ld. AO based on the observation that the assessee had advanced interest free loans to its subsidiary companies namely (i) M/s. Sabitrimata Realtors Pvt. Ltd. (ii) M/s. Beetle Real Estates Pvt. Ltd. and (iii) M/s. Christmas Realtors Pvt. Ltd. came to a conclusion that interest of Rs. 1,00,89,940/- deserves to be deleted. The assessee succeeded before the ld. CIT(A) challenging this disallowance. Before us, ld. CIT(D/R) has supported the observation of ld ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ) deleting the addition made by the ld. AO for unexplained cash credit u/s 68 of the Act of Rs. 17,90,15,000/-. 7.9. Brief facts relating to the issue are that during the year under appeal share application money of Rs. 17,90,15,000/- was received from following four companies: a) M/s. Satern Griha Nirman Pvt. Ltd. Rs. 13,60,00,000/- b) M/s. Onkareswar Realtors Pvt. Ltd. Rs. 7,00,000/- c) M/s. Salarpuria Griha Nirman Pvt. Ltd. Rs. 25,000/- d) M/s. Suruchi Properties Pvt. Ltd. Rs. 4,22,90,000/- Total Rs.17,90,15,000/- 7.10. During the course of assessment proceedings the assessee filed a letter dated 28.03.2014 seeking two weeks time to prepare the material required by the ld. AO. Since the assessment was getting time barred on 31.03.2014, ld. AO, due to lack of relevant material on record and after referring to judicial pronouncements made the addition u/s 68 of the Act at Rs. 17,90,15,000/- for unexplained share application money. 7.11. Aggrieved, the assessee preferred an appeal before the ld. CIT(A) and filed the details to prove the identity and creditworthiness of the alleged companies and the genuineness of the transaction of the s ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... also considering that all the four companies are group concerns of the assessee group, deleted the addition observing as follows: 8.1 The AO in the assessment order has contended and observed that during the year, the appellant had received Share Application Money to the extent of Rs. 17,90,15,000/- and in such respect the AO had issued notice asking the appellant to prove the genuinity of such Share Application Money. The AO has further mentioned that the appellant furnished a letter seeking more time in the matter and since such details were not furnished before the AO till 31.3.2014 and the assessment proceedings were getting time barred and hence he had to make the addition for the entire amount. The appellant on its part submitted that the relevant details in such respect were furnished before the AO on 31.3.2014 itself and hence the contention of the AO is bad in law. The matter was remanded to the AO and the AO in his remand report submitted as follows: The appellant has received Share Application Money from the following group companies. a) SaternGrihaNirman Pvt. Ltd. Rs. 13,60,00,000/- b) Onkeshwar Realtors Pvt. Ltd. Rs. 7,00,000/- c) Salarpuria G ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... -12. vii) Copy of Annual Report filed in ROC. D. Suruchi Properties Pvt. Ltd. (Pages 317 to 360 of the paper book). i) Memorandum of Association and Certification of Incorporation. ii) Copy of IT return for the A.Y. 2011-12. iii) Copy of Assessment order u/s 143(3) for A.Y. 2011-12. iv) Copy of ledger accounts for the Share Application Money so received. v) Copy of bank account for the source of the application so made in the appellant company. vi) Copy of Audited Accounts for the year ended 31.3.2011 relevant to A.Y. 2011-12. vii) Copy of Annual Report filed in ROC. 8.2 The appellant has brought further certain facts on record and which are worth mentioning. In the case of M/s Salarpuria Properties Private Ltd., the appellant assessee s profit is at Rs. 66.52 corre, Rs. 35.64 crore, Rs. 108.88 crore and Rs. 48.47 crores respectively in the years ended 31.3.2008, 31.3.2009, 31.3.2010 31.3.2011. In the background of the same, the appellant has contended that the appellant company is worth investing and it is not a paper company as such. As regards the applicant where from the appellant has received the Share Application Money, ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... td. (ITA No. 114 of 2011 dt. 13.6.2011-Calcutta High Court). I would also like to refer the judgment of the Honble Supreme Court in the case of PC IT v. NRA Iron Steel Pvt. Ltd. (2019) 103 taxmann.com 48 (SC) wherein Hon'ble Apex Court passed a decision in favour of revenue confirming the addition made towards cash credit (i.e. Share Capital) and having gone through the judgment, I find that in that case the AO had made extensive enquiries and from that it is found that some of the investor companies were non-existent. Such judgment doesn t apply in appellant s case and in this case the AO himself has referred to such companies as group company only and further the assessment orders have also been placed before me and existence of such companies carrying substantial business operation is proved. Since the PAN details, bank account statements, audited financial statements, income-tax acknowledgements and assessment orders have been placed before the AO in the remand proceedings and as well as before me, I find that all the three conditions as required u/s 68 of the IT Act, i.e. identity, creditworthiness and genuinity of the transactions have been proved by the appellan ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... deleting the impugned disallowance in view of the judgment of Hon ble Supreme Court in the case of Lachmandas Mathuradas (supra) and also finding that the interest paid on delayed deposit of service tax and VAT as compensatory in nature and, therefore, eligible as expenditure u/s 37(1) of the Act. Thus, since the alleged amount is not penal in nature, we confirm the finding of the ld. CIT(A). Thus, ground no. 4 raised by the Revenue is dismissed. Ground no. 5: 7.17. Through this ground, Revenue has challenged the finding of the ld. CIT(A) deleting the disallowance made by the ld. AO for the claim of bad debts as balance written off Rs. 1,27,29,297/-. 7.18. Brief facts relating to the issue are that the assessee has debited a sum of Rs. 1,27,29,297/- as balance written off. Necessary documents could not be filed before the ld. AO as the assessment was getting time barred. When the matter was carried before the ld. CIT(A) submissions were duly supported by the documentary evidences. Remand report was called for and the assessee has filed a rejoinder. Ld. CIT(A) observed that the alleged disallowance included stock written off at Rs. 73,55,162/- and sundry debtors writte ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... erial so placed before me and I find that as regards the sum of Rs. 73,55,162.22 since the impugned sum pertains to abandonment of business and hence following the judgment of Hon'ble Calcutta High Court in the case of Binani Cement (supra), the said sum is allowable. As regards the write off of Rs. 53,74,135.37, I find that the impugned sum pertains to sales and rental income so offered by the appellant in preceding years and which has claimed to be un-realisable and the same has been written off and hence following the judgment of Hon ble Supreme court in the case of CIT v. TRF Ltd. 323 ITR 500 (SC) the said sum is held as allowable. Hence this ground of the appellant is allowable. 7.22. From the above finding and the ratio laid down by the Hon ble jurisdictional High Court in the case of a) Binani Cement Ltd. (supra) b) Britannia Industries Ltd. (supra), we find no infirmity in the finding of the ld. CIT(A) allowing the claim of the assessee writing off the stock of Rs. 73,55,162.22 being in the nature of business loss. We also find no infirmity in the finding of the ld. CIT(A) allowing the claim of bad debts of Rs. 53,74,135.37 as these were the sales/rental mad ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... land improvement with detailed evidences which has not been furnished. The assessee has agreed that the construction work has commenced only after obtaining the project sanction in January 2008. It is seen from facts that the project was completed and handed over within one year from obtaining project sanction. It is difficult to imagine that a huge project with total cost of Rs. 60 Crs approx, was constructed, completed and handed over in one year, which is not practically_ possible with the current trends and technology prevailing in the construction industry in the year in which the project was completed. In absence of the various details, it seems that the entire fact pattern has been set to obtain the deduction u/s 80IB whereas practically, the same is not possible to execute in reality. 4B(3). Further on specific query on how the assessee is fulfilling the conditions stipulated under section 80IB(10) the assessee has provided certain cryptic details on a perusal of which it appears that two adjacent flat nos. A 1202 and A1203 were sold to Sri Atul Gupta and Smt. Rupali Gupta having same residential address. The assessee has not reverted when asked during assessment proce ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Particulars Salarpuria Serenity 1 2 3 1 Area of Land 4.00 acre 2 Local authority which had approved the Housing Project Bangalore Development Authority (in short BDA) 3 Plan Approval Dare 30.03.2007(Commencement Certificate dt 31.12.2007) 4 Project completion date 08.12.2009 (Architect Completion Certificate with Occupancy Certificate) 5 Built-up area of each flat (Residential unit) Less than 1500 Sq. Ft b) Besides it is quite surprising to note that the AO himself has accepted the sales pertaining to such project and the profit in respect of such project has also been accepted and has been considered in the taxable income so assessed by AO during the years concerned. However as regards of the deduction u/s 80IB(10), the AO has objection on unverified allegations. The AO has merely mentioned that ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... lowing proportionate deduction on such residential project. In this respect, your attention is drawn specifically to the recent judgment of Jurisdictional High Court in CIT v. Martin Burn Ltd. (ITAT No. 94/2013, GA No. 1219/2013 dt. 19.7.2018, Calcutta High Court) wherein in the case of builder deduction was claimed u/s 80IB(10) for a residential project. Some residential units for such housing projects were exceeding prescribed built-up area of 1500 Sq.ft. in and as such revenue held it as violation of the condition of sec. 80IB(10). In spite of the same, the Hon ble Jurisdictional High Court held that the provision of sec. 80IB(10) is for incentive of the housing project and as such the appellant having satisfied all other conditions it is entitled to deduction u/s 80IB(10) on the residential units which do not exceed such prescribed area and as such the Hon ble Jurisdictional High Court affirmed the decision of Hon ble Jurisdictional Tribunal allowing proportionate deduction to the assessee in such case. To support such contention regarding proportionate deduction u/s 80IB(10) reliance is placed on following judgments as well : Bombay High Court - HIGH COURT OF BOMBAY ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... on'ble Kolkata Bench of the Income Tax Appellate Tribunal in Bengal Ambuja Housing Development Ltd v DCIT and Vice Versa(supra) confirmed by the Calcutta High Court, merely because some of the units exceed the maximum limit, it would be a narrow and restricted interpretation to deny the deduction to the entire project. As observed by the Hon'ble Kolkata Bench of the Income Tax Appellate Tribunal, Section 80-IB(10) ) has been enacted with a view to provide incentive for businessmen to undertake construction of smaller residential units and the deduction is intended to be restricted to the profit derived from the construction of smaller units and not from larger residential units. The assessee has only claimed deduction in respect of smaller units, wherever the total area does not exceed 1500 sqft on pro-rata basis. Respectfully following the decision of Hon'ble Jurisdictional ITAT, Chennai Bench in the case of Arun Excello Foundation P Ltd (2007) 108 TTJ 71, the deduction claimed by the assessee is to be allowed. The appellant succeeds on this ground. The AO is directed to delete the deduction. 3. HIGH COURT OF BOMBAY Devashri Nirman LLP. v. Assistant Commissione ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... -company in joint venture with Ghaziabad Development Authority was engaged in business of development and construction of houses of different categories - Assessee-company undertook commencement of construction of S complex which was further sub-divided into six projects - Assessee s case was that development and construction of four projects of S complex were commenced after 1-10-1998 and, therefore, it was entitled to benefit of tax holiday relief available under section 80-IA(4F)/80-IB(10) - Assessing Officer rejected assessee s claim on following grounds: assessee had purchased land on which proposed construction was to be done prior to 1-10-1998; development authority had sanctioned plan of construction prior to 1-10-1998; assessee had advertised for booking of flats prior to insertion of section 80-IA, i.e., 1-10-1998, and assessee had undertaken earth filling activity of land so purchased for undertaking construction of project prior to 1-10-1998 - Whether purchase of land and approval of construction plan by development authority might not necessarily lead to inference that development and construction of projects had commenced prior to 1-10-1998 - Held, yes - Whether, ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... assessee may be justified in claiming deduction for the proportionate profit of the project referable to the residential units upto the ceiling limit indicated in the provision. Since the deduction which has been permitted by the order impugned passed by the Appellate Tribunal does not cover the proportionate profit pertaining to the residential units exceeding 1500 sq.ft. in area, the reasoning of the Tribunal that a liberal construction of the provision should be made to give such benefit that the assessee may be entitled to, does not call for any interference. ITAT No. 94 of 2013 and GA No. 1219 of 2013 are disposed of without interfering with the order under appeal. There will be no order as to costs. C. Without prejudice to the above, the appellant also places reliance upon the following judgments wherein proportionate deduction u/s 80IB(10) was allowed to the assessee concerned therein on the remaining flats which were not hit by clause e f of sec. 80IB(10). Such judgments are as follows: i) Om Swami Smaran Pvt. Ltd. v. ITO (2018) 90 taxmann.com 267 (Mumbai AT) ii) DCIT v. Mandovi Builders (ITA No.1734 and 1735 /Bang/2013 dt. 22.2.2015 [affirmed in CIT v. ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... d. v. Commissioner of Income Tax, Calcutta (2021) 431 ITR 1 (SC) ..20. We now come to the judgment of this Court in Citizen Cooperative Society Ltd. (supra). This judgment was concerned with an assessee who was established initially as a mutually aided cooperative credit society, having been registered under section 5 of the Andhra Pradesh Mutually Aided Cooperative Societies Act, 1995. As operations of the assessee began to spread over States outside the State of Andhra Pradesh, the assessee got registered under the Multi-State Cooperative Societies Act, 2002 as well. The question that the Court posed to itself was as to whether the appellant was barred from claiming deduction in view of Section 80P(4) of the Income-tax Act - see paragraph 5. After setting out the findings of fact in that case, and the income tax authorities concurrent holding that the society is carrying on banking business and for all practical purposes acts like a co-operative bank, this Court then held as follows: 18. We may mention at the outset that there cannot be any dispute to the proposition that section 80-P of the Act is a benevolent provision which is enacted by Parliament in order to enc ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... n of time. Ld. Counsel for the assessee invited our attention about the commencement certificate dated 31.12.2007 and project completion certificate showing that the project was completed on 08.12.2009 and since the assessee has fulfilled all the required conditions, ld. CIT(A) has rightly allowed the claim. 7.29. As far as another project Salarpuria Sanctity is concerned, ld. AO denied the total claim made for this project observing that the assessee has violated the conditions provided in Clause e f of Section 80IB(10) of the Act. As per Clause e of Section 80IB(10) of the Act not more than one residential unit in the housing project is allotted to any person not being an individual and as per Clause f of Section 80IB(10) of the Act if a residential unit in the housing project is allotted to a person being an individual, no other residential unit in such housing project is allotted to the spouse or the minor children of such individual, or the Hindu undivided family in which such individual is the karta, or any person representing such individual, the spouse or the minor children of such individual or the Hindu undivided family in which such individual is the karta. ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ich were below the limit of 1500 sq.ft, and thus approved the proportionate allowance of deduction even if some conditions- prescribed in section 801B(10) were not fulfilled. In the present case, the AO has given the finding that except these two residential units purchased by Mr. Atul Gupta and Mrs. Rupali Gupta no other flats were sold in violation of clause (e) and clause (f) of section 80IB(10).Hence following the principle so settled by Hon ble Calcutta High Court, the assessee is eligible to deduction u/s.801B(10) on the rest of the residential unit m such project. Hence the appellant is entitled to deduction 80IB(10) on the rest of the housing unit in such project. Hence the appellant gets part relief in the matter. In respect of Salarpuria Serenity, it is seen that the AO had disallowed the deduction on the ground that the project was approved on 31.12.2007 and the same has been completed on 8.12.2009. The AO has expressed his disbelief that within one year of the sanction of the project, the project has been completed which as per the AO seems impossible. The appellant in its submission has contended that the AO has merely expressed his disbelief without even conducti ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... s taxed the profits on such sales. On one hand ld. AO has accepted that the assessee has sold the flats and has accepted the revenue figures and further has taxed the profits earned on such sales and on the other hand is doubting the actual construction done for the completion of the project. Thus, under the given facts and circumstances since the assessee has fulfilled all the conditions necessary for claiming deduction u/s 80IB(10) of the Act for the profits earned from Salarpuria Serenity project, ld. CIT(A) has rightly allowed the same and thus hold that ld. AO has not justified in rejecting the assessee s claim u/s 80IB(10) of the Act at Rs. 3.13 Cr. 7.32. Now, as regards the other project Salarpuria Sanctity is concerned it remains an uncontroverted fact that two flats were sold to husband and wife and thus there was a violation of one of the conditions necessary for claiming deduction u/s 80IB(10) of the Act. Even though the assessee has claimed that both the flats were adjacent to each other and that the Clause e f of Section 80IB(10) of the Act was inserted w.e.f. 01.04.2010 whereas the said project was completed prior to such date and advance from the custome ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... hem, constructed area exceeded the upper limit that too by a small margin, deduction claimed cannot be denied in respect of entire housing project. 7.34. Hon ble Supreme Court in the case of Bajaj Tempo Ltd. v. CIT (1993) 196 ITR 188 (SC) had categorically observed that the provision in a taxing Statute granting incentives for promoting growth and development should be construed liberally and since a provision for promoting economic growth has to be interpreted liberally the restriction has to be construed so as to advance the objective of the provision in Statute. Applying this maxim, it may be appreciated that the legislature has prescribed the condition by using express in separate which the only condition which the assessee is unable to satisfy so as to two adjacent flats sold to spouses so as to qualify in respect of profits derived from housing project for remaining project. Hence in this case the appellant has complied with all the conditions in and separate for balance project hence a liberal view is warranted in the matter The AO is not justified in rejecting the claim for deduction u/s 80IB(10) in toto. 7.35. Considering the ratios laid down by the Hon ble Courts in ..... 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