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TMI Blog2008 (9) TMI 400X X X X Extracts X X X X X X X X Extracts X X X X ..... tion 80-I, the industrial undertaking should be treated as the only source of income of the assessee. 1.3 The appellant prays that the past losses etc. should not be set off against the current profits of the unit for calculating deduction under section 80-I of the Act. Without Prejudice to Ground No. 1 II.1 The learned Commissioner of Income-tax (Appeals) erred in not considering the provisions of section 34A being restriction on unabsorbed depreciation and investment allowance for limited period in case of certain domestic companies. II.2 The appellant prays that the restrictive provisions of section 34A be considered while arriving at the profit of the unit. 3. The material facts are like this. In the previous year relevant to the assessment year 1988-89, the assessee had set up its new industrial undertaking in Kodinar. There is no dispute that this unit is eligible for deduction under section 80-I. All along in the past, and in the year in appeal before us, the said unit was the only unit belonging to the appellant and hence its only source of earning as the assessee did not have any other unit or any other source of income, other than the income from Kodinar unit. In the ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... rlier years in respect of the same unit, even though the same may have been set off against profits of the assessee from other sources. According to the revenue, and as upheld by the CIT(A), the deduction is to be allowed only in respect of the net profits and gains from such unit after making these adjustments. 6. The plea of the assessee appears to be well taken. The expression used in section 80-I(6) is "as if such industrial undertaking... were the only source of income of the assessee during the previous years" in question. In case there are more than one units owned by the assessee, it poses no difficulty because in such a case only the profits or losses of that unit are to be taken into account. The other incomes earned by the assessee do not come into play at all. However, when there is only one unit owned by the assessee, all incomes of the assessee are to be treated as income of that solitary unit - whether derived from the industrial undertaking or not. Therefore, when the unabsorbed depreciation and investment allowance of the unit is set off against the income from other sources, such depreciation or unabsorbed depreciation cannot indeed be taken into account for comp ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... t context. 7. In the result, the appeal is allowed in the terms indicated above. Per I.P. Bansal, Judicial Member.-I have gone through the proposed draft order authored by my learned brother Shri Pramod Kumar. However, I am in respectful disagreement with the opinion expressed in the said order. Therefore, I proceed to pass a dissenting order as under:- 2. The original assessment in the present case was completed vide order dated 28-2-1995 passed under the provisions of section 143(3) of the Income-tax Act, 1961 at an income of Rs. 25,61,310, in which deduction under section 80-I was allowed at a sum of Rs. 8,70,90,300 being at the rate of 25 per cent of business profit of the eligible unit relating to the current year. The said assessment was reopened by issuing notice under section 148 dated 8-8-1996 for the reason that deduction under section 80-I was allowed excessively due to the fact that while computing section 80-I deduction, the brought forward losses, unabsorbed depreciation and Investment Allowances of the said unit were not reduced from the profits of the current year even though they were set off against the income from other sources in the earlier years. Reference ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... under section 80-I. Without prejudice, it was submitted that the restrictive provisions of section 34A should be considered while arriving at the profit of the unit. 5. The ld. CIT(A) has upheld the action of the Assessing Officer. He also found that the Assessing Officer has arrived at the eligible profit for allowing set off of only 2/3rd of brought forward depreciation/investment allowance. Hence he declined to interfere with the order of the Assessing Officer. It is relevant to mention here that while giving effect to the order of the CIT(A) dated 7-3-1996 passed in respect of original assessment, the Assessing Officer vide order dated 29-3-1996, has allowed the set off of carried forward unabsorbed investment allowance to the extent of 2/3rd by restricting the allowance to 1/3rd and the computation in this regard is as under:- Profits & Gains of Business Rs. 44,25,56,418 Capital gains Rs. 4,54,24,307 ---------------- Rs. 48,79,80,725 Income from other sources: Dividend Income Rs. 3,39,15,516 ---------------- Rs. 52,18,96,241 Less: Carry forward of unabsorbed investment allowance of earlier years: AY 1988-89 Rs. 7,89,79,185 AY 1989-90 Rs. 1,26,87,392 AY 1990-9 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... m of deduction under sub-section (1) for the assessment year immediately succeeding the initial assessment year or any subsequent assessment year, be computed as if such industrial undertaking or ship or the business of the hotel [or the business of repairs to ocean going vessels or other powered craft] were the only source of income of the assessee during the previous years relevant to the initial assessment year and to every subsequent assessment year up to and including the assessment year for which the determination is to be made." 8. According to the provisions of section 80-I(1) as it relevant for the case of the assessee, deduction is available to an assessee whose gross total income includes any profit and gains derived from an industrial undertaking which fulfils all the conditions laid down in that behalf in section 80-I(2). It may be noted that in the case of assessee, deduction under section 80-I is available only on the profits and gains which are derived from an Industrial undertaking. In the case of assessee, the deduction which is to be considered is deduction under section 80-I and not 80-IA. In section 80-IA, the expression used is "profit and gains derived from ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... nd 3595 of Chaturvedi & Pithisaria's Income-tax Law, Fifth Edition, Volume 2. 11. From the plain reading of section 80-I(1) and (6) it is clear that the profits and gains of an industrial undertaking for the assessment year immediately succeeding the initial assessment year or any subsequent assessment year are to be computed as if such industrial undertaking were the only source of income of the assessee during the previous years relating to the initial assessment year and to every subsequent assessment year up to and including the assessment year for which the determination is to be made. Thus, the unabsorbed losses, unabsorbed depreciation, etc., relating to eligible unit has to be taken into account in determining the quantum of deduction under section 80-I even though these may actually have been set off against the income of the assessee from other sources. From the annexure annexed to the impugned assessment order, it is clear that a sum of Rs. 4,35,52,000 which has been excluded from the current year's profit and gains of assessee's industrial undertaking relates to income earned by the assessee from other sources in the shape of interest, capital gains and dividend. The d ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... tax Act, 1961 must be understood as something which has direct or immediate nexus with the appellant's industrial undertaking. Although electricity may be required for the purposes of the industrial undertaking, the deposit required for its supply is a step removed from the business of the industrial undertaking. The derivation of profits on the deposit made with Electricity Board cannot be said to flow directly from the industrial undertaking itself. 7. The learned counsel appearing on behalf of the appellant has referred to several decisions of the Madras High Court in order to contend that the words 'derived from' could be construed to include situations where the income arose from something having a close connection with the industrial undertaking itself. All the decisions cited by the appellant have been considered by the Madras High Court in the case of Pandian Chemicals Ltd. We see no reason to disagree with the reasoning given by the High Court in Pandian Chemicals Ltd.'s case. With respect to those decisions to hold that they do not in any way allow the word 'derived' in section 80HH to be construed in the manner contended by the appellant. 8. The learned counsel for the ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e past years which was assessed as income from other sources compute profit and gains derived by the assessee from its eligible industrial undertaking as according to the provisions of section 80-I(6) the profits and gains of eligible industrial undertaking were to be computed as if such industrial undertaking was the only source of income of the assessee during the previous years relevant to the initial assessment year and to every subsequent year up to and including the assessment year for which the determination has to be made, it is not disputed that the adjustment made by the Assessing Officer of a sum of Rs. 4,35,52,000 relating to assessment years 1988-89 to 1991-92 was not relating to the previous years relevant to the initial assessment year and every subsequent assessment years thereafter. 13. It will also be relevant to mention here that similar view has been taken by the co-ordinate Bench in the case of CIT v. Ashok Alco Chem Ltd. [2005] 96 ITD 160 (Mum.). [In the said order I am a party] While interpreting the provisions of section 80-IA(1) it has been held that section 80-IA(7) has created a legal fiction that for the purpose of applying the provisions contained in t ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... sequent years. The Assessing Officer has arrived at the eligible profit after allowing set off of only 2/3rd of brought forward depreciation/investment allowance." 16. Section 34A reads as under:- "Restriction on unabsorbed depreciation and unabsorbed investment allowance for limited period in case of certain domestic companies. 34A. (1) In computing the profits and gains of the business of a domestic company in relation to the previous year relevant to the assessment year commencing on the 1st day of April, 1992, where effect is to be given to the unabsorbed depreciation allowance or unabsorbed investment allowance or both in relation to any previous year relevant to the assessment year commencing on or before the 1st day of April, 1991, the deduction shall be restricted to two-third of such allowance or allowances and the balance,- (a) where it relates to depreciation allowance, be added to the depreciation allowance for the previous year relevant to the assessment year commencing on the 1st day of April, 1993 and be deemed to be part of that allowance or if there is no such allowance for that previous year, be deemed to be the allowance for that previous year and so on for t ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... us year and so on for the succeeding previous years; Where it relates to investment allowance, be carried forward to the assessment year 1993-94 and the balance of the investment allowance, if any, still outstanding shall be carried forward to the allowing assessment year and where the period of eight years has expired before the portion of such balance is adjusted, the said period shall be extended beyond eight years till such time the portion of the said balance is absorbed in the profits and gains of the business of the domestic company." 17. The computation of deduction under sections 80HH, 80-I and 80M as done by the Assessing Officer in his order dated 29-3-1996 has been reproduced in para 5 of this order. In the impugned assessment order the Assessing Officer has taken the base gross total income of Rs. 44,09,50,675 as per order dated 29-3-1996. The said figure has been arrived at by allowing set off of carried forward unabsorbed investment allowance of earlier years to the extent of 2/3rd of a sum of Rs. 12,14,18,349 representing carried forward unabsorbed investment allowance of assessment years 1988-89, 1989-90 and 1990-91. Thus, effect has already been given by the Ass ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... r 1992-93 was heard by a Division Bench of the Tribunal and as a result of difference of opinion amongst Members of the Bench; the Hon'ble President has nominated me as Third Member for deciding the points of dispute in accordance with provisions of section 255(4) of the Income-tax Act, 1961. The points of dispute, as identified by the Learned Judicial Member are as under:- "1. Whether on the facts and in the circumstances of the case, a sum of Rs. 4,35,52,000 (aggregate of brought forward unabsorbed losses, depreciation and investment allowance relating to the eligible industrial undertaking and which was set off in assessment years 1988-89 to 1991-92 against income of assessee from interest capital gain and dividend) is required to be reduced as per section 80-I(6) of the Income-tax Act, 1961 from current year's profits derived by assessee from its eligible industrial undertaking for the purpose of computing deduction under section 80-I(1) of the Act? 2. Whether the provisions of section 80-I(6) are liable for two interpretations? 3. Whether rule of liberal interpretation can be applied while interpreting the provisions of section 80-I(6)." 2. The Learned Accountant Member ha ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 0 and after giving effect to the order of the CIT(A), the deduction under section 80-I stood allowed at Rs. 8,56,18,127. 6. Subsequently, the Assessing Officer issued a notice under section 148 dated 8-8-1996, for the reason that deduction under section 80-I was allowed excessively ignoring the provisions of section 80-I(6). As per the Assessing Officer, the brought forward losses, unabsorbed depreciation and investment allowance had not been reduced from the profits of the current year even though they were set off against the income from other sources in the earlier years in contravention of section 80-I(6) of the Act. 6.1 In response to the notice under section 148, the assessee filed a letter stating that the return already filed on 21-12-1992 may be taken as a return filed in response to notice under section 148. So however it was claimed that there was no mistake in the original assessment order warranting action under section 148 read with section 147 of the Act. 7. The Assessing Officer passed an order under section 147 read with section 143(3) on 4-10-1996 and after giving effect to section 80-I(6), the deduction under section 80-I was recomputed at Rs. 5,76,06,501 as a ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... distinction between the source of income and the heads of income. According to the learned counsel for the assessee, the mere fact that the income is assessed under various heads of income should not detract us from the fact that the entire income relates to the industrial undertaking. The learned counsel further pointed out that there is a distinction between the language of section 80-IA(7) and section 80-I(6). It was pointed out that under section 80-IA(7), the Legislature has used the words "eligible business" in contrast to the words used in section 80-I(6) as industrial undertaking being the only source of income of the assessee. The learned counsel for the assessee contended that since both the sections were co-existing in the year under appeal, the manifest distinction in the language of the two provisions of the Act has got to be kept in mind for interpreting section 80-I(6). The learned counsel for the assessee further contended that the decision of the Special Bench in the case of Goldmine Sharer & Finance (P.) Ltd. [IT Appeal Nos. 4044 to 4049 (Ahd.) of 2003], assessment years 1997-98 to 2002-03, order dated 30-4-2008, relates to section 80-IA and in the light of the d ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... I(6), the same cannot be cured by the appellate authorities. Reliance was placed on the following decisions of the Supreme Court to support this contention:- (1) Padmasundra Rao v. State of Tamil Nadu [2002] 255 ITR 147 (SC); (2) Prakash Nath Khanna v. CIT [2004] 266 ITR 1 (SC). Reliance was also placed on the Special Bench decision of the Tribunal in the case of Jt. CIT v. Montgomery Emerging Markets Fund[2006] 100 ITD 217 (Mum.) to support the contention that there is a distinction between sources of income and heads of income. Learned counsel reiterated that though in this case the income was assessed under various heads of income, yet, the source of such income was the industrial undertaking and accordingly no adjustment was required under section 80-I(6) of the Act. Reliance was also placed on the decision of the Supreme Court in the case of Padmasundara Rao, to support the contention that the ratio of a decision cannot be applied de hors of facts of a particular case. 9.2 It has further been pointed by the learned counsel for the assessee that for the assessment year 1992-93, the Assessing Officer has assessed the interest income of Rs. 1.91 crores as part of the business ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ed my attention to the provisions of section 80-I and has contended that the provisions of sub-section (6) of section 80-I are very clear and not liable for two interpretations and that because of non obstante clause contained in section 80-I(6) the provisions have overriding effect vis-a-vis other provisions of the Act. He has also contended that section 80-I(6) enacts a legal fiction that the profit and gains of new undertaking shall be computed as if the new undertakings were the only source of income of the assessee, from the initial assessment year and the past years unabsorbed, depreciation, losses and investment allowance are to be set off against the income of the assessee from the income of the undertaking. It was accordingly pleaded that the view expressed by the learned Judicial Member may be followed in preference to the view expressed by the learned Accountant Member. 11. In counter reply, the learned counsel for the assessee contended that the decisions cited on behalf of the revenue are distinguishable on facts and accordingly inapplicable for the present controversy. It was accordingly pleaded that the view canvassed on behalf of the assessee be accepted. 12. I ha ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ing specified in the list in the Eleventh Schedule, or operates one or more cold storage plant or plants, in any part of India, and begins to manufacture or produce articles or things or to operate such plant or plants, at any time within the period of ten years next following 31-3-1981, or such further period as the Central Government may, by notification in the Official Gazette, specify with reference to any particular industrial undertaking; (iv) in a case where the industrial undertaking manufactures or produces articles or things, the undertaking employs ten or more workers in a manufacturing process carried on with the aid of power, or employs twenty or more workers in a manufacturing process carried on without the aid of power: Provided that the condition in clause (i) shall not apply in respect of any industrial undertaking which is formed as a result of the reestablishment, reconstruction or revival by the assessee of the business of any such industrial undertaking as is referred to in section 33B, in the circumstances and within the period specified in that section: Provided further that the condition in clause (iii) shall, in relation to a small-scale industrial under ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... chinery or plant previously used for any purpose; (ii) the business of the hotel is owned and carried on by a company registered in India with a paid-up capital of not less than five hundred thousand rupees; (iii) the hotel is for the time being approved for the purposes of this sub-section by the Central Government; (iv) the business of the hotel starts functioning after 31-3-1981, but before 1-4-1991. (4A) This section applies to the business of repairs to ocean going vessels or other powered craft which fulfils all the following conditions, namely:- (i) the business is not formed by the splitting up, or the reconstruction, of a business already in existence; (ii) it is not formed by the transfer to a new business of machinery or plant previously used for any purpose; (iii) it is carried on by an Indian company and the work by way of repairs to ocean-going vessels or other powered craft has been commenced by such company after 31-3-1983, but before 1-4-1988; and (iv) it is for the time being approved for the purposes of this subsection by the Central Government. (5) The deduction specified in sub-section (1) shall be allowed in computing the total income in respect of th ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... l undertaking or ship or the business of the hotel or the business of repairs to oceangoing vessels or other powered craft were the only source of income of the assessee during the previous years relevant to the initial assessment year and to every subsequent assessment year up to and including the assessment year for which the determination is to be made. (7) **" 12.1 A plain reading of section 80-I reveals that deduction is available to an assessee whose gross total income includes any profits and gains derived from:- (i) an industrial undertaking, which fulfils all the conditions laid down in that behalf in section 80-I(2); (ii) a ship, which fulfils all the conditions laid down in that behalf in section 80-I(3); (iii) the business of a hotel, which fulfils all the conditions laid down in that behalf in section 80-I(4), and (iv) the business of repairs to ocean-going vessels or other powered craft, which fulfils all the conditions laid down in that behalf in section 80-I(4A). 12.2 It is not disputed that the assessee owns an industrial undertaking, which fulfils all the conditions laid down in section 80-I(2) and is eligible for deduction in respect of the profits and gains d ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... (6) the income derived from the industrial undertaking alone is to be considered as the only source of income of the assessee. The purpose of sub-section (6) of section 80-I is to ensure that the assessee does not get a double deduction in respect of the income derived from the industrial undertaking. In earlier years the assessee had suffered losses in running the industrial undertaking. If the assessee did not have any other source of income, such losses would have been carried forward and set off against the income of any subsequent year(s). So however, the assessee had income, which was taxable in the respective assessment years. The assessee has set off losses against the taxable income and therefore derived the benefit in such years. In the year under appeal, the benefit derived by the assessee by setting off the losses of the industrial undertaking against the taxable income is adjusted against the benefit sought in respect of the income derived from the industrial undertaking. 12.4 It has got to be borne in mind that sub-section (6) limits the deduction to be computed under sub-section (1) of section 80-I. 12.5 Section 80-I refers to the profits and gains derived from an ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... , where the undertakings are engaged in the production of articles other than articles listed in the said Schedule. (iii) In computing the quantum of "tax holiday" profits in all cases, taxable income derived from the new industrial units, etc., will be determined as if such unit were an independent unit owned by an assessee who does not have any other source of income. In the result, the losses, depreciation and investment allowance of earlier years in respect of the new industrial undertaking, ship or approved hotel will be taken into account in determining the quantum of deduction admissible under the new section 80-I even though they may actually have been set off against the profits of the assessee from other sources". 12.7 The view canvassed by the revenue is supported by some of the decisions of the Tribunal. I am avoiding the reference to the decisions, which are in respect of section 80-IA. Reference hereunder is made only of such decisions as are relevant to section 80-I. In the case of Prasad Productions (P.) Ltd. v. Dy. CIT [2006] 98 ITD 212 (Chennai), the Tribunal held that by virtue of sub-section (6) of section 80-I, the new industrial undertaking is isolated from ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... preciation and making disallowance under rule 6D as submitted by the assessee, has arrived at the net profit from the ship at Rs. 75,20,175. The deduction allowance under section 33AC, about which there is no dispute, is Rs. 2,50,00,000. The Assessing Officer has adjusted this deduction against the income of Rs. 75,20,175. The entire profits from the ship would absorb part of the deduction under section 33AC. Thereafter, as rightly pointed out by the Assessing Officer no profits would be left, against which the Assessing Officer could allow deduction under section 80-I. He has therefore, rightly determined the amount deductible under section 80-I to be nil His working of the deduction is incomplete accord with the provisions of sub-section (6) of section 80-I." In Para 11, the Tribunal has also referred to the CBDT Circular No. 281, dated 22-9-1980. The relevant portion of the Circular has been reproduced as under:- "In computing the quantum of "tax holiday" profits in all cases, taxable income derived from the new industrial units, etc., will be determined as if such unit were an independent unit owned by an assessee who does not have any other source of income. In the result, t ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... plea of the learned counsel for the assessee can be divided into two limbs. First limb is, that for purpose of sub-section (6) of section 80-I, the entire income earned by the industrial unit, not merely the income derived from the industrial unit, has got to be treated as the income of the unit for the purposes of restricting the quantum of deduction under section 80-I(6). In other words, the income derived from the industrial unit as well as any income, which is attributable to the industrial unit, is to be taken as the income of the industrial undertaking for purposes of sub-section (6) of section 80-I. Second limb of the contention, which has been accepted by the learned Accountant Member in the proposed order, is that when the assessee owns only one industrial unit, the income from all sources of income of the assessee is to be considered as the income of the industrial unit for the purposes of sub-section (6) of section 80-I. As far as the first part of the contention advanced on behalf of the assessee is concerned, there is a scope for acceptance of such a contention, if the language of section 80-I(6) is considered in isolation from the scheme of deduction under section 80- ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... be said to be attributable to the industrial undertaking. That issue does not arise in this case the light of treatment given by the Assessing Officer. It is only the income by way of interest, dividend and capital gains, which has not been considered as the income of the industrial undertaking for purposes of section 80-I(1) as well as for purposes of sub-section (6) of section 80-I. Before proceeding further, it would be relevant to refer to the decision of the Hon'ble Supreme Court in the case of Vellore Electric Corpn. Ltd. v. CIT [1997] 227 ITR 557, at 576. In this case the Hon'ble Supreme Court held that profits and gains can be said to be attributable to the priority industry under section 80-I if there is a direct and proximate connection between the profits and gains and the business of priority industry. 12.9 Now let me consider the nature of interest income, dividends and capital gains earned in earlier years as well as in the year under appeal, on the basis of the material on record. I am tempted to refer to Schedule 'F' of the Balance Sheet for assessment year 1990-91, which reads as under:- ------------------------------------------------------------ As at As at ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... idend and capital gains, in my view, not having any nexus with the industrial undertaking, is not to be considered to be the income of the industrial undertaking. Such income is neither derived from nor attributable to the industrial unit. Therefore, the first limb of the contention on behalf of the assessee that it is not only the income derived from the industrial undertaking but also the income which is attributable to the industrial undertaking is to be taken into account while giving effect to sub-section (6) of section 80-I as the only source of income of the industrial undertaking, is of no consequence in this case. As pointed out earlier, the Assessing Officer has treated the miscellaneous income, insurance claim, profit on disposal of empty bags, etc. as the income derived from the industrial undertaking. At this stage there is no scope for disputing the treatment, given by the Assessing Officer in respect of the miscellaneous income, insurance claim and profit on sale of empty bags as being the income derived from the industrial undertaking. Since such an income has already been considered to be as part of the eligible profits even for the purposes of sub-section (6) of s ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... been conscious of the distinction between an assessee and the industrial unit etc., i.e., its income earning apparatus. So once a distinction between an assessee as a company and its industrial unit set up by it is kept in mind, the confusion of treating the income of the assessee-company from all its sources as the income of the industrial unit will not survive. Therefore, once it is accepted that the company has its own existence as an assessee and industrial unit is one of its profit earning apparatus, the view that the income of an assessee, who owns only one industrial unit, from all the sources has got to be treated as income of the industrial undertaking is bound to fail. If the contention on behalf of the assessee that the income of a company who owns only one industrial undertaking, say Unit No. I. has got to be treated as the income of the industrial unit were to be accepted, then the income of any other unit, say Unit No. II, set up by the company at any point of time is bound to be treated as the income of the Unit No. I. This is not even the case of the assessee. The illusion of treating the income from all sources of the assessee company as income of the sole industri ..... X X X X Extracts X X X X X X X X Extracts X X X X
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