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TMI Blog2024 (1) TMI 1247X X X X Extracts X X X X X X X X Extracts X X X X ..... be no distinction between the quasi-judicial function and an administrative function inasmuch as the aim of both is to arrive at a just decision and to prevent miscarriage of justice. In STATE OF ORISSA VERSUS DR. (MISS) BINAPANI DEI ORS. [ 1967 (2) TMI 96 - SUPREME COURT] , the Supreme Court observed that even an administrative order or decision in matters involving civil consequences have to be made consistently with the rules of natural justice. The purpose of the rules of natural justice is to prevent miscarriage of justice, the rules should be made applicable to administrative enquiries also. On examination of contention of learned Senior Advocate appearing for the petitioner and taking note of concession made by the learned Senior Standing Counsel defending the order of the AAAR, it is found that the Order dated 27.07.2021, which is sought to be set aside invoking extraordinary jurisdiction under Article 226/227 of the Constitution of India for want of confrontation, as one of the facets of the principles of natural justice, does not transpire that the AAAR has disclosed the material contained in the report submitted by the Superintendent of CGST Central Excise, Sambalpur-I R ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... tion 96 vide Order No. 06/Odisha- AAR/2020-21 dated 09.03.2021 in consideration of the Application filed under Section 97 of the GST Act has been set aside in the appeal preferred by the Jurisdictional Officer and held that "the items sold by the applicant-M/s. Pioneer Bakers will attract the GST tariff rate as individual items". 1.1. It is alleged that the Appellate Order has been passed in gross violation of the established position of law and suffers from procedural irregularities warranting interference being in violation of principles of natural justice. FACTS AS NARRATED BY THE PETITIONER: 2. The Petitioner-firm is operating its outlets under the name of "GO-COOL" since 1997. It has established itself as a brand in the field of bakery items, especially in cakes. It has several outlets operating in the State of Odisha and it offers a wide range of goods and services in the aforementioned outlets. 2.1. Principal business of the petitioner is making and selling of bakery products, viz., cakes, artisan cakes, pastries, pizza, patties, sandwich, burgers, handmade chocolates, cookies, beverages etc., in its outlets. It offers a large number of customisation options to its custo ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... is also a form of service provided by the petitioner. The chocolates prepared in the workshop are also used in the preparation of brownies, smoothies, shakes and other beverages, etc. prepared in the outlets itself and the customer is normally served with various dishes of hot chocolates in the premises. 2.7. The customer has also the option to choose a suitable beverage from a whole lot of options or to ask for a custom drink (non-alcoholic), which is prepared instantly in the outlets on demand. Different customers have different tastes and as per their demand various drinks are prepared in the outlets. 2.8. The facilities provided in the outlets coupled with the ambience make it a perfect place for customer to celebrate birthday, anniversary or any other event of the like and accordingly, sometimes the customer also demand for special arrangements in the premises to celebrate special moments. While the petitioner is indulged in preparation and supply of varieties of items from pizza base to creams for cakes in the outlets or from the workshop, some of the items, like balloons, plastic knife for cutting cake, birthday caps and posters and other related items used in decoration a ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... oods consists of bakery items, chocolates while the supply of services include the supply of air conditioned place to sit and to celebrate birthday. Ans: The answer is in the 'Negative'. Q.(c) Whether the sale of handmade chocolates which are manufactured in the workshop of the Applicant and are utilised for the purpose of providing other services such as shakes, brownies and are also retailed by packing in different containers as per the choice of the customer will be covered under the under the restaurant services? Ans: Yes, answer is in the affirmative. Q.(d) What is the nature and rate of tax applicable to the following items supplied from the premises of the bakery shop of the Applicant (i) Items such as Birth caps, knife, decorative items which are bundled along with the cakes and are utilised by the Customers in the premises of the outlets. Ans: Replied at para 4.5 & 4.6 as above. (ii) Items such as Birthday caps, knife, decorative items which are bundled along with the cakes and are taken away by the Customers from the outlets. Ans: Replied at para 4.5 & 4.6 as above. (iii) Items such as chocolate, cookies which are prepared in the nearby workshop of the A ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ST, Odisha also put forth their submissions on the similar grounds. The Concerned Officer submitted that, in the instant case it is a bakery outlets where ready to each (sic. eat) items are sold and mere facility is provided to take it from the shop. The applicant has only prepared birthday cakes, as per order for take out service and they do not prepare birthday cakes immediately from the customers order. Those who want to take within the premises, they merely supply the readily available cakes. They do not serve food to the Customer table & in most cases, sold the items from the counter. Therefore, the applicant should not be considered as Restaurant Services." 4.1. It has further been observed by the AAAR as follows: "We examined the submission made by the applicant. We have also gone through the above verification put forth by the Jurisdictional Officer and the Concerned Officer." 4.2. And, thereafter, it has been concluded as follows: "Ruling (a) The appeal made by the Jurisdictional Officer is allowed; (b) The ruling made by the Authority for Advance Ruling, Odisha vide their Order No. 06/Odisha- AAR/2020-21 dt. 09.03.2021 against the Question Nos. (a), (c), (d)(iii) ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... he premises of the restaurant itself, because the essential character of a restaurant is serving hot cooked full meals. However, in case of bakery the existence of kitchen in the same premises is not essential. It is also not a requirement for the bakery to serve baked items in the same premises. The main purpose of bakery is only to sell its baked items rather than serving them to customers in its premises. 7. Refuting such contention of the opposite parties the petitioner filed rejoinder affidavit on 08.08.2022 by making statement that the petitioner does run "restaurant business" and the food is being served to each and every customer in the restaurant. Having accepted that the petitioner serves food to its customer, the opposite parties contradicted by stating that serving a few items does not make a place "restaurant", but the opponents have not given any reason for such assertion. 7.1. Strongly opposing the contention of the opposite parties, the petitioner has sought to explain that the petitioner fulfils all the requisite criteria for the goods and services to be classified within fold of "composite supply" as defined under Section 2(30) and supply of ancillary goods and ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... sis for varying with the opinion of the AAR in the appeal, the petitioner on 03.08.2021 made an application for supply of copy of said report. Since copy of the report was not supplied to the petitioner, reminders were submitted on 12.08.2021 and 31.08.2021. By way of Letter C.No.IV(023)/AAR/ Pioneer/SBP-I/2021/1457, dated 03.09.2021, the Assistant Commissioner, GST and Central Excise, Sambalpur-I Division denied to supply copy of the report. The text of said letter reads as follows: "Please refer to your Letter Ref. NIL dated 12.08.2021 on the above mentioned subject. In this context, it is to intimate that the sought enquiry report cannot be provided to you, as the undersigned is also a party in the instant case and on the basis of the same sought enquiry report carried out by the JRO, GST and Central Excise, Sambalpur-I Range, Sambalpur, the undersigned has filed appeal before the Odisha Appellate Authority of Advance ruling for Goods and Service Tax (GST), Rajaswa Vihar, Bhubaneswar, Pin-751007 (Odisha) against order No. 06/Odisha-AAR/2020-21 dated 09.03.2021. You may sought the same from the Odisha Appellate Authority of advance ruling for goods and Service Tax, Rajaswa Vi ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... is purpose. Any violation of COVID-19 protocols will attract closure/sealing/cancellation of license of the concerned shops. 2. Malls shall operate with reduced number of customers. The mall Owner shall ensure that persons entering malls are thoroughly screened for temperature, correct use of masks and physical distancing. No food court shall be open for seat- in dining. Only take away shall be allowed. No one shall be allowed to take/consume food in the mall premises. It shall be the responsibility of the owner/ management of the mall to ensure that there is no overcrowding at any point of time within the shops and common areas. 3. It shall be the responsibility of all shop owners/shopkeepers and market associations to ensure that all their staff put on mask during the entire period of their stay in the shop premises. Under no circumstances, violation of this instruction will be tolerated. 4. All buyers/visitors/consumers coming to the shop shall mandatorily use mask correctly. The market association/ shop owners/ shop keepers shall ensure this in letter and spirit. 5. Number of visitors/buyers to the shop shall be regulated by the market association/shop owners/ shop keep ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Disaster Management Act, 2005, the Epidemic Diseases Act, 1897 and Regulations issued thereunder besides legal action under Section 188 of the IPC and other legal provisions as applicable." 9.6. Taking cue from aforesaid guidelines the learned Senior Counsel appearing for the petitioner submitted that when such was the restriction in the State of Odisha at the relevant period, the petitioner has been doing the business only "on take away basis" in obedience of such prohibitory orders of the Government. This itself cannot be the basis to de-classify its business from the category of "restaurant services". The general nature of transactions carried on by the petitioner could not be judged on the foundation of situational disadvantage prevailing during April, 2021. As the inspection report was not confronted to the petitioner, it had been deprived of explaining the position to the AAAR. 9.7. The report, submitted during the currency of said Order dated 19.04.2021, could not be utilised for conceiving general appreciation of factual aspect whether the activity of the petitioner would fall within the connotation of "restaurant service". Hence, the perception of the AAAR does not stand ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Vrs. S.N. Brothers, Kanpur, (1973) 3 SCC 496 = AIR 1973 SC 78. 9.9. Sri Jagabandhu Sahoo, learned Senior Advocate, therefore, contended that had there been proper opportunity afforded to the petitioner by confronting the adverse report, which was relied on by the AAAR to vary with the finding and the ruling of the AAR, it could have put forth its explanation in better perspective. Faced with such situation, the Senior Counsel has suggested for according opportunity to proffer explanation before the AAAR so as to enable the petitioner to have its say with regard to the report collected behind its back. 10. Per contra, though Sri Radheyshyam Chimanka, learned Senior Standing Counsel for the opposite party Nos. 2 to 6 made valiant attempt to justify the conclusion arrived at by the AAAR, which reversed the finding of the AAR after obtaining verification report submitted by the Superintendent of CGST & Central Excise, on the question of confrontation he remained gagged. However, he stood by what has been mentioned in the impugned Order vis-à-vis the counter affidavit eliciting the merit of the matter. 10.1. He would submit that the inspection of the business premises during A ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the increasing importance of natural justice in the field of administrative law. Natural justice is a great humanising principle intended to invest law with fairness and to secure justice and over the years it has grown into a widely pervasive rule affecting large areas of administrative action. Lord Morris of Borth-y-Gest spoke of this rule in eloquent terms in his address before the Bentham Club: 'We can, I think, take pride in what has been done in recent periods and particularly in the field of administrative law by invoking and by applying these principles which we broadly classify under the designation of natural justice. Many testing problems as to their application yet re-remain to be solved. But I affirm that the area of administrative action is but one area in which the principles are to be deployed. Nor are they to be invoked only when procedural failures are shown. Does natural justice qualify to be described as a 'majestic' conception? I believe it does. Is it just a rhetorical but vague phrase which can be employed, when needed, to give a gloss of assurance? I believe that it is very much more. If it can be summarised as being fair-play in action-who could wish that ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... vide American Journal of International Law, Vol. 67, p. 479). Magarry, J., describes natural justice 'as a distillate of due process of law' (vide Fontaine Vrs. Chastarton, (1968) 112 Solicitor General 690). It is the quintessence of the process of justice inspired and guided by 'fair-play in action'. If we look at the speeches of the various Law Lords in Wiseman case, 1971 AC 297 " (1969) 3 All ER 275 it will be seen that each one of them asked the question 'whether in the particular circumstances of the case, the Tribunal acted unfairly so that it could be said that their procedure did not match with what justice demanded', or, was the procedure adopted by the Tribunal 'in all the circumstances unfair?' The test adopted by every Law Lord was whether the procedure followed was fair in all the circumstances and 'fair-play in action' required that an opportunity should be given to the taxpayer 'to see and reply to the counter-statement of the Commissioners' before reaching the conclusion that 'there is a prima facie case against him'. The inquiry must, therefore, always be: does fairness in action demand that an opportunity to be heard should be given to the person affected?" 12.3. ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 32, it has been held as follows: "Principle of natural justice is attracted whenever a person suffers a civil consequence or a prejudice is caused to him by an administrative action. In other words principle of natural justice is attracted where there is some right which is likely to be affected by any act of the administration including a legitimate expectation. [See: Ashoka Smokeless Coal India (P) Ltd. Vrs. Union of India, (2007) 2 SCC 640]. The procedure to be followed is not a matter of secondary importance and in the broadest sense natural justice simply indicates the sense of what is right and wrong [Voinet Vrs. Barrett (1885) 55 LJQB 39] and even in its technical sense it is now often equated with fairness. As a well-defined concept, it comprises of two fundamental rules of fair procedure that a man may not be a judge in his own cause (nemo judex in re sua) and that a man's defence must always be fairly heard." 12.5. In Mangilal Vrs. State of M.P., (2004) 2 SCC 447, the Hon'ble Supreme Court declared that even if a statute is silent and there are no positive words in the Act or the Rules made thereunder, principles of natural justice must be observed. This is what the C ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... etitions, namely, the audi alteram partem rule, in its fullest amplitude means that a person against whom an order to his prejudice may be passed should be informed of the allegations and charges against him, be given an opportunity of submitting his explanation thereto, have the right to know the evidence, both oral or documentary, by which the matter is proposed to be decided against him, and to inspect the documents which are relied upon for the purpose of being used against him, to have the witnesses who are to give evidence against him examined in his presence and have the right to cross examine them, and to lead his own evidence, both oral and documentary, in his defence. The process of a fair hearing need not, however, conform to the judicial process in a Court of law, because judicial adjudication of causes involves a number of technical rules of procedure and evidence which are unnecessary and not required for the purpose of a fair hearing within the meaning of audi alteram partem rule in a quasi-judicial or administrative inquiry. If we look at clause (2) of Article 311 in the light of what is stated above, it will be apparent that that clause is merely an express stateme ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... thority would violate the fundamental rights enshrined in the Constitution. When it comes to authorities that are expected to discharge judicial and quasi-judicial functions, the rule of audi alteram partem applies with equal force. Reasonableness infuses lifeblood in procedural matters, be it elements of the notice, the contents of the notice, the scope of inquiry, the material available or an adequate opportunity to rebut such material. All of this is to avoid miscarriage of justice at any stage. This is of course fluid and subject to adapting to the demands of a situation in the given facts of a case." 12.7. On perusal of the ratio laid down in the cases referred to above, the adherence to the principles of natural justice is mandatory requirement. As can be seen, natural justice ideas are not new, but they are also not a man- made product. Its foundation was laid by various philosophers, jurists, rulers, and teachers. People should utilise practical wisdom or active reason to be consistent with a virtuous living, according to Aristotle, the greatest proponent of Natural Justice. 12.8. In State of Odisha Vrs. Dr. (Miss) Binapani Dei, AIR 1967 SC 1269, the Supreme Court observe ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ssee so that the assessee could controvert the statements contained in it by asking for an opportunity to cross-examine the manager of the bank with reference to the statements made by him. 13. In Delhi Transport Corporation Vrs. D.T.C. Mazdoor Congress, 1991 Supp (1) SCC 600, the Hon'ble Supreme Court held as follows: "*** It is now well-settled that the 'audi alteram partem' rule which in essence, enforces the equality clause in article 14 of the Constitution is applicable not only to quasi-judicial orders but to administrative orders affecting prejudicially the party-in-question unless the application of the rule has been expressly excluded by the Act or regulation or rule which is not the case here. Rules of natural justice do not supplant but supplement the Rules and Regulations. Moreover, the rule of law which permeates our Constitution demands that it has to be observed both substantially and procedurally. ***" 14. In Basudeo Tiwary Vrs. Sido Kanhu University, (1998) 8 SCC 194, the Hon'ble Supreme Court held that in order to impose procedural safeguards, this court has read the requirement of natural justice in many situations when the statute is silent on this point. ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ck 469 = 38 (1972) CLT 349 = AIR 1972 Ori 224 (Pramila Dei Vrs. Secretary, Board of Secondary Education, Orissa, Cuttack), the requirements of natural justice have been indicated. To a case of this type the following in our opinion would be applicable: (1) The assesse has to be informed about the materials against him together with a statement of the allegations on which they were based; (2) He should be given a reasonable opportunity of stating his own case; (3) If the assessee demands that the witness reporting against him should be cross-examined by him, ordinarily such opportunity has to be granted. (4) The taxing authority would consider the entire material placed on the record and complete the assessment in good faith." 13.2. In Kanak Cement Pvt. Ltd. Vrs. Sales Tax Officer, (1997) 105 STC 112 (Ori) this Court has observed as follows: "6. *** It is a fundamental requirement of the principles of natural justice that if any person is likely to be affected by use of any material collected by the Revenue, those are to be brought to his notice, and disclosed to him. The requirement of natural justice is to disclose by way of confrontation of the materials collected and ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... n to the assessee to make prayer for summoning a person who has nexus with the material sought to be utilised, so that the witness can throw light on the materials. For example, if a third party's accounts is sought to be utilised the assessee can pray the Sales-tax Officer to issue summon to the party whose accounts are sought to be relied upon. Denial to accept the prayer would amount to violation of the principles of natural justice. The person whose accounts are sought to be utilised against the assessee stands in the footing of a witness for the revenue. Utilisation of any entry in his account against the assessee without accepting prayer for summoning him, would vitiate assessment. 6. As observed by the Supreme Court in Khem Chand Vrs. Union of India, (1958) SCR 1080 = AIR 1958 SC 300, the assessee must not only be given an opportunity, but such opportunity must be a reasonable one; he should be informed about the charge or charges levelled against him and the evidence by which it is sought to be established. The assessing authority is not bound by any technical rules of the law of evidence. It is open to him to collect materials to facilitate assessment even by private enq ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... d to cross- examine the person who made the statement for the purpose of meeting the statement or with a view to commenting thereon, such a request, except on exceptional or special cases, be denied without violating the principles of natural justice. The assessing authority has to objectively satisfy that the case comes within the "exceptional or special cases" category. As observed by the Apex Court in State of Kerala Vrs. K.T. Shaduli Yusuff, (1977) 39 STC 478, cross-examination in one of the most efficacious methods of establishing truth and exposing falsehood. It was held that where an assessee's returns were sought to be treated as incorrect and incomplete because of entries in the books of account of a third party, the assessee could prove the correctness and completeness of its return by showing that the entries in the books of account of the third party were false, bogus or manipulated and this could obviously be done if he is given opportunity to examine the third party on being summoned. The action of the assessing authority in refusing to summon the third party constituted an infraction, and vitiated the orders of assessment. However, the Intelligence Officer's presence ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e in disregard of the evidence, oral or documentary, led by the assessee, he should in fairness disclose to the assessee the material on which he is going to found that estimate; (3) he is not however debarred from relying on private- sources of information, which sources he may not disclose to the assessee at all; and (4) in case he proposes to use against the assessee the result of any private inquiries made by him, he must communicate to the assessee the substance of the information so proposed to be utilised to such an extent as to put the assessee in possession of full particulars of the case he is expected to meet and should further give him ample opportunity to meet it, if possible. The decision does not lay down that it is open to the Income-tax Officer to make an estimate on pure guess and without reference to any material or evidence before him." 13.8. This Court in answering one of the questions of law posed in the case of State of Odisha Vrs. Muralimanohar Prabhudayal, 1982 SCC OnLine Ori 195 = (1983) 52 STC 35 while sitting in reference jurisdiction under Section 24(1) of the Odisha Sales Tax Act, 1947 that "whether, on the facts and in the circumstances of the ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... explanation. CONCLUSION & DECISION: 14. Perusal of Letter dated 11.10.2021 communicated to the petitioner by the Superintendent of CGST & Central Excise, Sambalpur-I Range in connection with application under the Right to Information Act, wherein the "Factual Report" prepared on 27.04.2021 after verification of activity of the petitioner-business and furnished to the Assistant Commissioner of CGST & Central Excise, Sambalpur-I Division has been enclosed, reveals as follows: "FE-20(08)/CGST/Investigation/SBPR-I/2019/784, dated 27.04.2021 To Sir, The Assistant Commissioner CGST & Central Excise, Sambalpur-I Division, Sambalpur. Subject: Factual report regarding M/s. Pioneer Bakers- Reg. Please refer to your Letter C.No. V(16)(1)01/Tech/Misc/ SBP-I/2019, dated 27.04.2021 wherein it was requested to verify and submit report regarding business, activity of M/s Pioneer Bakers, Sambalpur. In this context, this is to inform that the undersigned along with Inspector visited the business premises of the said firm at Bhalubahal (Sason), Budharaja & Gole Bazar (Sambalpur). In Bhalubahal we found that there is no selling of goods and in Budharaja renovation work was going on ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... mendment) Act, 2020, taking into view spread of pandemic COVID-19. It is apparent from such notifications that actions could not be completed or complied with due to force majeure the statutory period of limitation for taking action has been extended. With such notifications in force, Order dated 19.04.2021 of the Special Relief Commissioner came to be passed specifying that "Home Delivery of food, groceries, vegetables and essential items by restaurants and aggregators such as Zomato, Swiggy, etc." and "Dhabas along National and State Highways/Major roads for takeaway only". Deviation of any of the measures contained in the said Order attracted penalty in accordance with the provisions of Section 51 to 60 of the Disaster Management Act, 2005, the Epidemic Diseases Act, 1897 and Regulations issued thereunder besides legal action under Section 188 of the Indian Penal Code and other legal provisions as applicable. 14.5. Therefore, this Court entertains serious doubt whether the report as stated to have been submitted on 27.04.2021 eliciting the business activities carried on by the petitioner on the date of inspection of its premises on 27.04.2021 can be taken aid of in order to asc ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Relations Act, 1960] clearly spells out the jurisdiction of the Industrial Court to pass any order in reference to the case brought before it as it thinks fit. The expression "as it thinks fit" confers a very wide jurisdiction enabling it to take an entirely different view on the same set of facts. The expression "as it thinks fit" has the same connotation, unless context otherwise indicates, "as he deems fit" and the latter expression was interpreted by this Court in Raja Ram Mahadev Paranjype Vrs. Aba Maruti Mali, AIR 1962 SC 753 = 1962 Supp (1) SCR 739 to mean to make an order in terms of the statute, an order which would give effect to a right which the Act has elsewhere conferred. Is this jurisdiction so circumscribed as to bring it on par with Section 115 of the Code of Civil Procedure? Proviso does cut down the ambit of the main provision but it cannot be interpreted to denude the main provision of any efficacy and reduce it to a paper provision. Both must be so interpreted as to permit interference which if not undertaken there would be miscarriage of justice. Sub-clause (c) of the first proviso to Section 66(1) will permit the Industrial Court to interfere with the order m ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ncerned, we find that rejection of this plea is totally untenable. The Tribunal has simply stated that cross- examination of the said dealers could not have brought out any material which would not be in possession of the appellant themselves to explain as to why their ex-factory prices remain static. It was not for the Tribunal to have guess work as to for what purposes the appellant wanted to cross-examine those dealers and what extraction the appellant wanted from them. 7. As mentioned above, the appellant had contested the truthfulness of the statements of these two witnesses and wanted to discredit their testimony for which purpose it wanted to avail the opportunity of cross-examination. That apart, the Adjudicating Authority simply relied upon the price list as maintained at the depot to determine the price for the purpose of levy of excise duty. Whether the goods were, in fact, sold to the said dealers/ witnesses at the price which is mentioned in the price list itself could be the subject matter of cross- examination. Therefore, it was not for the Adjudicating Authority to presuppose as to what could be the subject matter of the cross- examination and make the remarks as ..... X X X X Extracts X X X X X X X X Extracts X X X X
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