Provision related to issue & Service of Notices.

Provision related to issue & Service of Notices


Provision related to issue & Service of Notices.


1. Recently the Hon’ble Apex Court held that service of notice u/s. 148 on an erstwhile company which is now converted into an LLP would be a valid service and defect or error in writing the name of the entity would be taken care of by section 292B. The Hon’ble Bombay High Court in another case held that notice sent by WhatsApp and its receipt, indicated by two blue ticks on the senders mobile, will also constitute service of the notice. This is a new perspective of the law relating to issue and service of the notices which are otherwise covered by Order V of CPC. In the present article a bird’s eye view of the law on issue and service of the notices as per provisions of the Income-tax Act and CPC, General Clauses Act and Information Technology Act in the light of recent judicial pronouncements are given.

Law relating to service under the Act

2. Section 282, as it stood prior to 1-10-2009, provided that a notice or requisition under the IT Act may be served on the person named therein, either by post, or like a summon issued by a Court under CPC. Regarding the person upon whom such service could be made it was provided in sub-section (2) that service can be done, (i) in the case of firm/HUF— upon member/manager of the firm or any adult member of HUF, (ii) in the case of local authority/company—- upon principal officer, (iii) in the case of an AOP/BOI—— upon Principal Officer/member, (iv) in the case of any other person (not being individual)—— upon the person who manages/control its affairs. The amended section 282, as per Finance Act (No. 2), 2009 w.e.f. 1-10-2009, provides that a notice/summon/requisition/order/any communication issued under the Act may be served by delivery or transmission by (i) post/courier as may be approved, or (ii) in the manner as provided in CPC, or (iii) in the form of an electronic record as provided under the IT Act, 2000, or (iv) by any other means of transmission of documents as provided by Rules made by the Board in this behalf. The Board is empowered by sub-section (2) to frame Rules for addresses including electronic addresses for emails, etc. The meaning of “electronic mail” or “electronic mail message” shall be the same as provided in the Explanation to section 66A of IT Act, 2000. This Explanation provides that “the terms “electronic mail” and “electronic mail message” mean a message or information created or transmitted or received on a computer, computer system, computer resource or communication device including attachments in text, images, audio, video and any other electronic record, which may be transmitted with the message”.

Addresses, as per Rule 127, at which service is to be affected

3. Notices/orders/summons/communications/requisitions shall be served at addresses provided —

(i) In the PAN data base, or (ii) in income-tax return to which communication relates to, or (iii) in last income-tax return, or, (iv) In the case of a company, in the records of Ministry of Corporate Affairs, or (v) to the Department for the purposes of communication.
With effect from 20-12-2017, where communication/service cannot be affected at addresses given above, then communication/service can be affected at addresses provided (i) to banking company, or (ii) to post master general, or (iii) to insurer, or (iv) in Form No.. 61 or 61A Director/Joint Director (as per Rule 114D(1) or as per Rule 114E(1), as the case may be) of income-tax (intelligence and criminal intelligence), or (v) as available in the record of the government or local authority.
Electronic communication or service through email may be affected at (i) email address available in the IT return to which communication relates to, or (ii) email address in the last IT return, or (iii) in the case of the company email address available with the Ministry of Corporate Affairs, or (iv) email address made available to an IT Authority or to any person.
PDGIT (Systems) or DGIT (systems) have been authorized to specify the procedure, formats and standards and formulating appropriate policies for ensuring secure transmission of e-communication.

Service through WhatsApp

4. WhatsApp is also an electronic media through which communications of messages, Photos, documents, videos and audios are affected through a transcript mode for ensuring privacy and confidentiality. The Hon’ble Bombay High Court in the latest judgment dated 11-6-2018 in the case of SBICards & Payments Services (P.) Ltd. v. Rohidas Jadhav [NOTICE NO. 1148 OF 2015 in EXECUTION APPLICATION NO. 1196 OF 2015], in case of sending of notice through WhatsApp, held that “For the purposes of service of Notice under Order XXI Rule 22, I will accept this. I do so because the icon indicators clearly show that not only was the message and its attachment delivered to the Respondent’s number but that both were opened.” Thus, where icons on the WhatsApp number of the sender indicates that not only the message (notice) to the addressee was delivered but is was also opened, it was treated as a valid service under order XXI Rule 22.

Service through emails

5. Where email address of the addressee has correctly been typed by the sender, the message of transmission to the sender can be treated as evidence of delivery of the message. However, in a case of dispute by the addressee that he has not received the communication on his email, the onus will lie on the addressee. To show non-delivery, email transcripts received by the addressee of that date, being the date of delivery, claimed by the sender, has to be produced provided there is no deletion of the relevant communication. The onus will shift on the sender to prove that either email address was correct, taken from the documents/sources provided under Rule 127 of the IT Rules, or there was a fraud on the part of the addressee by deleting the message. To safeguard the correct delivery of notice/order/summons/communications, their photo scripts should also be sent through WhatsApp at the registered Mobile Number. There may also be simultaneous email delivery to the authorized representative, other directors/principal officers (who are authorized to receive communication from the Department). There is no prohibition under law for communication through multiple modes.

Difference in the law under section 282 as it existed prior to 1-10-2009 and thereafter

6. It may be noted that prior to 1-10-2009 section 282 specified the persons upon whom notice/requisition could be addressed, whereas section 282 as it existed after 01-10-2009 did not provide as to whom the notice/summon/order/requisition could be addressed. However, general rule is that notice/summon, etc., should be addressed only to the assessee, i.e., in the case of the firm it should be addressed to the firm, in the case of HUF it should be addressed to the HUF and the like. It was only as an abundant caution that an option was given to the Department, by the use of the word “may” in pre 01-10-2009 law, also to address the notice/requisition to the partner/member, etc., in addition to, or instead of, the main assessee. In post 01-10-2009 law such an option is no longer considered necessary. The notice/order, etc., has to be addressed to the Income-tax assessee for whom it is meant and served upon it, or on a person authorized to receive. The law as provided in CPC, 1908 (5 of 1908) for service of summons will hold the field in respect of manner in which such notice/orders/summons under the IT Act has to be served.

7. Service as per CPC

7.1 Rule 12 Order V, of the Code of Civil Procedure, 1908provides that Service of a notice/summon is to be done on defendant in person when practicable, or on his agent who is empowered to accept service in which case service on such agent shall be sufficient.

7.2 Rule 9 order V of CPC: provides that service of summons may be made by delivering or transmitting a copy thereof by registered post acknowledgement due, or by speed post or by such courier service (as approved by the High Court), or by any other means of transmission such as fax messages or electronic mail service. The receipt of “acknowledgement due” by the Court or receiving back the postal article (i.e., envelope) with the remark by postal authority that the addressee has refused to take the delivery of the postal article, or non-receipt of acknowledgement (on account of loss or mislaid) within 30 days of date of dispatch/hand over to postal authorities, will be treated as valid service. [refer- CIT v. Yamu Industries Ltd. [2008] 167 Taxman 67/306 ITR 309 (Delhi)] However, service on non-receipt of acknowledgement within 30 days of dispatch will be deemed only when Revenue could show that envelope containing the notice was correctly addressed. [refer- CIT v. Rajesh Kumar Sharma [2007] 165 Taxman 488/[2009] 311 ITR 235 (Delhi)]

7.3 Order V, rule 20(1A): provides for paper publication if the address of the assessee was not known or same could not be furnished by his representative. Where place of last known address was demolished, the service should have been ordered to be effected by publication in a local daily newspaper. [refer- Anthi Reddy Yamireddy v. Dy. CIT [2017] 88 635 (Hyderabad – Trib.)]

7.4 Service through affixture: Order V Rule 17 provides the procedure when defendant refuses to accept service, or cannot be found.—Where the defendant or his agent refuses to sign the acknowledgement, or where the serving officer, after using all due and reasonable diligence, cannot find the defendant (who is absent from his residence at the time when service is sought to be effected on him at his residence and there is no likelihood of his being found at the residence within a reasonable time), and there is no agent empowered to accept service of the summons on his behalf, nor any other person on whom service can be made, the serving officer shall affix a copy of the summons on the outer door or some other conspicuous part of the house in which the defendant ordinarily resides or carries on business or personally works for gain, and shall then return the original to the Court from which it was issued, with a report endorsed thereon or annexed thereto stating that he has so affixed the copy, the circumstances under which he did so, and the name and address of the person (if any) by whom the house was identified and in whose presence the copy was affixed. Therefore, where notice u/s. 148 was affixed at the gate on the refusal to accept service by the gatekeeper, the Hon’ble Delhi High Court held that service through affixture was invalid as there was no evidence that the assessee or his agent refused to sign the acknowledgement or could not be found. [refer- CIT v. Hotline International (P.) Ltd. [2007] 161 Taxman 104/296 ITR 333 (Delhi)]

7.5 Before resorting to affixture as provided in Rule 17 Order V, procedure laid down in Rules 19 & 20 has to be followed. Rule 19 provides that the serving officer (notice server/inspector of the Department) shall report service/non-service of the notice/summon on the defendant, i.e., assessee through an affidavit which shall be examined by the Court (the Income-tax authority issuing notice/summons under its signature), to carry out inquiry if required and either declare that notice/summon has been duly served or order to serve by affixture. Rule 20 provides that if the Court is satisfied that summon/notice cannot be served as defendant is keeping out of the way for the purpose of avoiding service or for any other reason, then notice/summons shall be served by affixture by affixing a copy thereof in some conspicuous place of the house of the defendant where he is known to have last resided or carried on business or personally worked for gain and Court house.

Service by post, which had been returned with endorsement “addressee not found”, followed by an attempt at personal service and subsequent affixture would constitute substantial compliance of provisions of section 282. [refer- Success Tours & Travels (P.) Ltd. v. ITO [2017] 80 262/247 Taxman 109/394 ITR 37 (Cal.)]

7.6 Recognised/authorized agents: Order III, rule 2 of the CPC provides that notice/summons can be served upon the persons holding power-of-attorney, authorizing them to make and do such appearances, applications and acts on behalf of such parties. In case of non-resident persons carrying on trade or business for and in their names are treated as recognised agents. Therefore, Service of notice u/s. 143(2) on authorized representative of assessee on ground of non-availability of assessee is deemed service of notice on assessee and sufficient compliance of requirement of that section. [refer- ITO v. Dharam Narain [2018] 90 325/253 Taxman 479 (SC)]. Similarly, where assessee did not intimate change of address, then service of notice u/s. 143(2) on authorized representative who consistently used to appear to represent her case from year to year, was valid. [refer- CIT v. Smt. Sushila Devi [2014] 45 467 (Mad.)] On the other hand, service of the notice u/s. 148 on an employee or CA who was not authorized to receive notices, was not held valid. [refer- Rajesh Kumar Sharma(supra); Harsingar Gutkha (P.) Ltd. v.. CIT [2012] 20 713/[2011] 336 ITR 90 (All.)]. The onus is on the AO to establish that the person upon whom notice was served was an agent of the assessee. [refer- Nripendra Mishra v. ITO [2009] 121 TTJ 701 (Lucknow)]

7.7 Service on family members: As per Order V, rule 15 of the Code, service of a summon issued by a civil court can be made on any adult member of the family of the defendant, residing with him, whether male or female. Therefore, where the assessee was absent from his residence at the time when the service of the notice was sought to be effected on him and there was no likelihood of his being found at the residence within a reasonable time and he had no agent empowered to accept service of the notice on his behalf, service of notice u/s. 148 on an adult member of family was valid. [refer- ITO v. Gurbax Singh Gill [2010] 123 ITD 226 (Amritsar)]

7.8 Rule 18 of Order V: Where process server had not identified the person upon whom the notice was served which was necessary as per rule 18 of Order V of CPC, 1908, it was held that neither notice had been served on partner of firm, nor on Authorised Representative of assessee-firm as per provisions of section 282 and, thus, it was to be held that there was no valid service of notice. [refer- ITO v. Bedi Enterprises [2008] 25 SOT 115 (Lucknow)]

7.9 Presumption as to the service of notice: Where the assessee declined to accept notice under section 148 three times at the three addresses which belonged to assessee at relevant time, service of notice was to be presumed under section 27 of the General Clauses Act, 1897. [refer- Mayawati v. CIT [2010] 321 ITR 349 (Delhi)]

7.10 Order V, rule 19A provides for simultaneous issue of summons for service by post in addition to personal service.

7.11 Examples :

(i) Thus, where there was no proof/documentary record that the AO was satisfied that efforts were taken to serve summon/notice in ordinary course, and assessee had avoided to accept service and there was no authorization by the AO to the process server of the Department to serve the assessee by affixture, there was a violation of Rule 20, Order V of CPC and the service through affixture was invalid. [refer- ITO v. PTC Impex (India) (P.) Ltd. [2018] 93 158 (Delhi – Trib.); Sanjay Badaniv. Dy. CIT [2014] 50 457 (Mum. – Trib.)]
(ii) Where inspectors at their own decided to serve notice u/s. 148 through affixture on refusal by the gatekeeper to accept the notice, the service thereof was invalid. [refer- Auram Jewellery Exports (P.) Ltd. v. Asstt. CIT [2017] 88 633 (Delhi – Trib.)]. That is, service through affixture by notice server without getting order from the AO was invalid service. [refer- Ashok Lal Chandani v. ITO [2017] 81 143 (Lucknow – Trib.)]. But the Hon’ble Allahabad High Court held that where ITO deputed two Inspectors to make personal service of notice u/s. 148 upon assessee who refused to receive said notice and, thereafter notice was affixed at main door of assessee’s clinic, there was valid service of notice upon the assessee. [refer- Dr. Sheo Murti Singh v. CIT [2015] 64 276/[2016] 236 Taxman 405/383 ITR 174 (Allahabad)]
(iii) The service of the notice u/s. 148 through affixture at a place where assessee was not residing was invalid. [refer- ITO v. Om Parkash Kukreja [2016] 70 147/159 ITD 190 (Chd. – Trib.)]
(iv) Where the Assessing Officer has not exhausted the ordinary way of service by sending it by post or by courier but directly made the services through affixture, it was held that the substituted service as provided in the Order-V, Rule-20 of Civil Procedure Code is only a last resort when the court or other authorities are satisfied that service cannot be affected through ordinary mode/method. [refer- Ketan V Shah v. Asstt. CIT [2010] 7 88 (Mum); CIT v. Kishan Chand [2010] 328 ITR 173 (Punj. & Har.); Kiran Machines v. ITO [2006] 156 Taxman 463/[2007] 295 ITR 4 (Mad.); Arun Lal v. Asstt. CIT [2010] 124 ITD 85 (Agra)(TM)]. Therefore, where procedure laid down in Rule 20 Order V is not complied with service by affixture will be invalid.. [refer- Ram Singh Mathur v. ITO [2007] 112 TTJ 989 (Delhi); CIT v. Naveen Chander [2010] 323 ITR 49 (Punjab & Haryana)]
(v) Service of notice u/s. 143(2) was held invalid as it was issued at last minute to avoid limitation and since the office of the assessee was closed, no efforts were made by the Assessing Officer to find out the whereabouts of the assessee to serve it but a short cut was taken by the Inspector who resorted to affixation, which was carried out in the absence of any independent witness. [refer- CIT v. Dewan Kraft System (P.) Ltd. [2007] 165 Taxman 139 (Delhi)]
(vi) Where assessee sold his house which was his last address, now did not reside there, no efforts were made by the AO to search for new address, procedure for substituted service like publication, etc., was not followed, service through affixture at the last known address was not proper. [refer- CIT v. Sher Singh [2013] 37 418 (Punjab & Haryana)]

Simultaneous (multiple mode of) service

8. Newly enacted section 282 provides for multiple modes of service such as post, courier service, electronic media or any other mode as provided in the Rules. There is no bar to use any one or multiple modes of service. The Hon’ble Apex Court has also approved of such multiple modes of service in Central Electricity Regulatory Commission v. National Hydroelectric Power Corpn. Ltd. [2010] 10 SCC 280 wherein it was observed that in addition to normal mode of service, service of Notice(s) may be effected by E-Mail which will be provided by the advocate(s) on-record at the time of filing of petition/appeal/counter. The Registry of Supreme Court will send such an additional notice at the E-Mail addresses of the respondent/petitioners so provided. Such additional copy of the notices will also be sent to the email address of the advocates who filed caveat. Notices to the Government Departments will also be sent at their email addresses. The IT Department can also send notices through multiple modes. However, in the case of notice u/s. 148 of IT Act it appears that sending a hard copy of notice will be necessary in addition to exercising other modes of service. A safer option in all cases of communication is always to send a hard copy by post/courier with acknowledgement due in addition to sending notices through electronic mode.

Issue and service of notice u/s. 148

9. Section 148 requires the service of notice before making assessment/reassessment/recomputation u/s. 147, whereas section 149 requires issuance of notice before the expiry of the period of limitation for initiating proceedings. Noticing this distinction, the court held that what is needed u/s. 149 is that notice must be issued by the Assessing Officer before the expiry of the period of limitation provided u/s. 149. However, it may be served on the assessee even after the expiry of the period u/s. 149 but before the assessment/reassessment/recomputation u/s. 147. [refer- R.K. Upadhyaya v. Shanabhai P. Patel [1987] 166 ITR 163/33 Taxman 229 (SC); CIT v. Uttam Chand Nahar [2007] 295 ITR 403 (Rajasthan); Smt. Rajee Rajkumar v. Asstt. CIT [2017] 81 113/247 Taxman 353 (Kerala)]. The service of the notice u/s. 148 is mandatory/essential for validating reassessment order. [refer- CIT v. Mani Kakar [2009] 178 Taxman 315 (Delhi); Y. Narayana Chetty v. ITO [1959] 35 ITR 388 (SC)]. Where assessment/reassessment order is passed ex-parte the Department has to prove the service of the notice both u/s. 148 as well as u/s. 143(2). On not proving the service, the assessment/reassessment proceedings can be declared invalid. [refer- CIT v. Premium Capital Market & Investment Ltd. [2006] 151 Taxman 194/[2005] 275 ITR 260 (MP)]. On the other hand, notice issued u/s. 148 sent by post to addressee at his proper address, would be deemed to have been delivered/served to him in ordinary course, if not returned undelivered. [refer- CIT v. Privilege Investment (P.) Ltd. [2017] 88 559/395 ITR 147 (Allahabad)]

However, where a notice u/s. 148 was sent by registered post but was received back without any endorsement on cover (envelope) of either refusal or service or even return of envelope to sender or fact that assessee had left addressed place, it could not be said that there was a proper service of the notice. [refer- Keshab Narayan Banerjee v. CIT [1998] 101 Taxman 512 (Cal.)] But where the fact of receipt of notice by the assessee is not disputed then manner and mode of service will become irrelevant. [refer- Venad Properties (P.) Ltd. v. CIT [2011] 16 62/[2013] 212 Taxman 20/340 ITR 463 (Delhi)]

Date of service of notice is date of its actual receipt by assessee.. [refer- OIP Sensor Systems India Liaison Office v. ADIT (International Taxation) [2014] 41 509/148 ITD 324 (Delhi – Trib.)]

Where AO sent two notices in same envelope and assessee accepted the receipt of one, the service of other notice is presumed. [refer- Shahbad Co-operative Sugar Mills Ltd. v. Dy. CIT [2013] 38 204/218 Taxman 352 (Punjab & Haryana)]

10. Service by speed post

Section 282 uses the expression “post” through which service is to be affected. The term “post” includes Ordinary Post, Post under Certificate, Registered Post, Registered A/D or by Speed Post. Where notice sent by speed post did not return to the Income-tax Department as undelivered, it is deemed as served under Rule 9 Order V of CPC. [refer- Milan Poddar v. CIT [2012] 24 27/211 Taxman 403/357 ITR 619 (Jharkhand)]

Service of notice and section 292B

11. Section 292B of the Act deals with effect/mistake, defect or omission in service of notice, summons, etc., and states that notice, order, proceedings, etc., will not be invalid on account of any mistake, defect or omission if in substance and effect it is in conformity with and in accordance with the intent and purpose of the Act. It has been held by the Hon’ble Delhi High Court in CIT v. Sudev Industries Ltd. [2018] 94 373/256 Taxman 317 (Delhi) that the aforesaid section is a broad and wide provision which lays emphasis on substance rather than on form and that technicalities should not result in invalidating the proceedings, notice, orders, etc. Therefore, where notice u/s. 148 was served on gatekeeper and the director of the company did not raise objection to validity of service of the notice and participated in the reassessment proceedings, service will not be held invalid. However, in the case of a notice u/s. 143(2) it has been held that it should not only be issued but also served within limitation period. [refer- CIT v. Avi-Oil India (P.) Ltd. [2010] 323 ITR 242 (Punjab & Haryana)]

Objection to issue and service of notice

12. Section 292BB provides that if assessee has participated in assessment proceedings or cooperated in any inquiry relating to assessment/reassessment, it shall be deemed that service of the notice has been proper, provided such objections are raised during the course of assessment/reassessment proceedings. After closure of this proceedings, assessee will be precluded to raise objection that notice was not served on him or was not served in time or was served in any improper manner. Objections to service of notice will be sustainable only when there is some controverting evidence/material on record. In absence of any contrary material regarding delivery of communication and arrangements entered into with postal authorities, objection cannot be sustained. [refer- Color Craft v. ITO [2016] 68 409 (Mumbai – Trib.)]. Where return was filed in response to notice u/s. 158BD it could not be contented that the notice was not served upon him. [refer- CIT v. Lekshmi Traders [2011] 11 52/[2012] 344 ITR 281 (Kerala)]

Issuance of notice in the name of erstwhile entity

13. Issuance of notice u/s. 148 in the name of the company which has been converted into LLP on the date of issue of notice will be valid as it was not a jurisdictional error, but an irregularity and procedural/technical lapse which could be cured under section 292B. [refer- Sky Light Hospitality LLP v. Asstt. CIT [2018] 92 93/254 Taxman 390 (SC)]. Therefore, in view of this decision of the Hon’ble Apex Court, the view held in Asstt. CIT v. DLF Cyber City Developers Ltd. [2015] 53 81 (Delhi – Trib.) that issuance of notice to a partnership firm which was converted into company will be invalid, or the view held in Dy. CIT v. Mani Square Ltd. [2017] 88 77 (Kolkata – Trib.) that the issue of notice for reopening u/s. 148 only against amalgamating company and not against assessee-company which was amalgamated/successor company, assessment made in name of assessee-company was void is no longer are correct views.

However, this decision of the Hon’ble Apex Court in Sky Light Hospitality LLP (supra) may not be applicable in respect of issue of notice in the name of dead person, as the difference is apparent. In the case before the Hon’ble Apex Court the entity was existing but with a different name and structure but in the case of dead person the entity (person) is no longer in existence.

Issuance of notice in the name of dead person

14. The settled legal principle is that a notice issued in the name of the dead person is unenforceable in law. A fresh notice after limitation period issued to the spouse after knowing the death of the assessee will not validate the proceedings u/s. 148. [refer- Alamelu Veerappan v. ITO [2018] 95 155 (Mad.); CIT v. M. Hemanathan [2016] 68 22/239 Taxman 533/384 ITR 177 (Mad.); Lal Chand Agarwal v. CIT [2016] 68 102 (Allahabad)] A notice to reassess the income of an earlier year of a person who is dead can be issued only to a legal representative of assessee within period of limitation for issuance of notice. [refer- Vipin Walia v. ITO [2016] 67 56/238 Taxman 1 (Delhi)] A non-service of notice u/s.. 143(2) in respect of income of the deceased to all legal representatives, will only be an irregularity and will not vitiate the proceedings if initiated on issue of notice to one LR. [refer- CIT v. Jai Prakash Singh [1996] 219 ITR 737/85 Taxman 407 (SC)]

Service through courier

15. Where AO prefers to send notice through courier he has to ensure that such courier service is aproved by the Board and a proper acknowledgement of service must be placed on record with a certification that parcel/envelope has been delivered to the addressee. Where department reopened assessment of assessee by sending notices through courier but failed to produce copy of acknowledgement in token of service of notices, it could not be said that notices were actually served and, therefore, reassessment proceedings were quashed. [refer- Asstt. CIT v. Ashiana Automobiles (P.) Ltd. [2010] 124 ITD 425 (Patna)]


16. A notice u/s. 148 must be issued with a limitation period as provided u/s. 149 but its service can be affected after limitation. Notice u/s. 143(2) must be issued and served within limitation. Service must be affected on the addressee or on his agent authorized to receive the notices. Receipt of notice by a person not authorized by the addressee will be invalid. Service through affixture has to be affected as per procedure laid down in Order V of CPC. Without there being a record of satisfaction recorded by the AO service through affixture will be invalid. Issue of notice in the name of an entity which is converted into another entity will be valid and error in mentioning the name is covered by section 292B. However, notice issued in the name of dead person will be invalid. Service through WhatsApp will be valid, if mobile of the sender reflects two blue ticks on the message sent.



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