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Entries in the books of account are not relevant for rejecting the claim of the assessee if it is otherwise allowable
Mumbai ITAT in the case of Zuari Industries Ltd. Vs. ACIT has done few remarkable observation which may be relevant for the taxpayers in various other cases as well. The judgment includes the following.
1. n the case of slump sale, where liabilities are more than value of assets, the net worth, viz., the cost of acquisition has to be taken at nil and entire sale consideration is liable to capital gains tax; AO was not justified in adding net worth to sale consideration and computing capital gains at a figure higher than sale consideration.
2. Notwithstanding the fact that assessee has capitalised interest on capital borrowed for expansion of plant, the same is allowable business expenditure under s. 36(1)(iii). Entries in the books of account are not relevant for rejecting the claim of the assessee if it is otherwise allowable—India Cement Ltd. vs. CIT (1966) 60 ITR 52 (SC) and Kedarnath Jute Mfg. Co. Ltd. vs. CIT (1971) 82 ITR 363 (SC) followed.
3. Notwithstanding the fact that assessee has capitalised interest on capital borrowed for expansion of plant, the same is allowable business expenditure under s. 36(1)(iii).
4. Payment to various clubs by way of reimbursements is not disallowable under s. 40A(9).
5. Major part of investment came out of sale proceeds of assessee’s one unit. Further, there was no material on record to prove that any interest was paid for earning tax-free income under s. 10(33)—No disallowance was called for. When the major part of investment came out of sale proceeds of assessee’s one unit and there was no material on record to prove that any interest was paid for earning tax-free income under s. 10(33), no disallowance could be made by invoking s. 14A.
The complete order copy is as under:
ZUARI INDUSTRIES LTD. vs. ASSISTANT COMMISSIONER OF INCOME TAX
ITAT, MUMBAI ‘E’ BENCH
K.C. Singhal, J.M. & D.K. Srivastava, A.M.
ITA No. 71/Mum/2005
1st June, 2006
(2006) 25 CCH 0418 MumTrib
(2007) 108 TTJ 0140 : (2007) 105 ITD 0569 : (2006) 9 SOT 0569
Legislation Referred to
Section 10(33), 14A, 36(1)(iii), 40A(9), 48, 50B
Case pertains to
Asst. Year 2001-02
Decision in favour of:
In favour of:
Case referred to
Avada Trading Co. (P) Ltd. vs. Asstt. CIT (2006) 104 TTJ (Mumbai)(SB) 83
Maruti Udyog Ltd. vs. Dy. CIT (2005) 92 TTJ (Del) 987 : (2005) 92 ITD 119 (Del)
Premier Automobile Ltd. vs. ITO (2003) 182 CTR (Bom) 202 : (2003) 264 ITR 193 (Bom)
Deepak Tralshwala, for the Assessee : Girish Dave, K.L. Maheshwari & S.M. Keshkamat, for the Revenue
K.C. SINGHAL, J.M.: :
*Also see Asst. CIT vs. Zuari Industries Ltd. (ITA No. 75/Mum/2005, asst. yr. 2001-02)
Both the appeals have been heard together and are being disposed of by the common order for the sake of convenience.
ITA No. 71/Mum/2005
The first issue arising in this appeal relates to computation of capital gains under s. 50B of the IT Act, 1961 (‘Act’). Briefly stated, the facts are these : The assessee was engaged in the business of manufacturing and sale of chemical fertilizers and allied products as well as cement and furniture. It sold its cement division located in the State of Andhra Pradesh to Zuari Cement Ltd., in which 50 per cent shares were held by assessee against lump sum consideration of Rs. 75.98 crores paid by way of allotment of 7,59,80,000 fully paid-up equity shares of face value of Rs. 10 each under the scheme of arrangement approved by the Hon’ble Bombay High Court vide order dt. 12th Jan., 2001. This scheme was effective from 1st April, 2000. In the return filed for the year under consideration, it was stated that net worth of cement division as per computation done under s. 50B was in negative sum of Rs. 150.46 crores. As such, in the absence of cost which is a necessary limb for computing capital gain, the relevant section for computing capital gain fails. Thus, consideration received amounted to capital receipt not chargeable to tax. Such claim of assessee was rejected by AO as he was of the view that formula given in s. 50B for determining net worth was nothing but a mathematical calculation totally dependent upon the amount of liabilities and assets. He further opined that net worth so determined has to be used in determining the capital gain in the form of a mathematical formula. So, if net worth was in positive, it was to be reduced from the sale consideration but where net worth was in negative, it should be added to the sale consideration. Consequently, he computed the capital gain at Rs. 226.4399 crores by adding the net worth to the sale consideration. He also relied on the judgment of the apex Court in the case of CIT vs. Attili N. Rao (2001) 171 CTR (SC) 188 : (2001) 252 ITR 880 (SC), for the proposition that sale consideration would include the liabilities settled out of sale proceed.
2. The matter was carried in appeal before the learned CIT(A) before whom various submissions were made which, inter alia, included (i) that there was no cost at all as net worth was in negative and, therefore, computation provisions failed, (ii) that in view of provisions regarding indexed cost of acquisition in ss. 48 and 55 of the Act, negative cost is not envisaged by the legislature, (iii) that as per dictionary meaning, cost can never be a negative figure, (iv) in the alternative, negative figure should be ignored for computing capital gain, (v) it is not open to AO to vary the formula by adding a limb of cost i.e., liabilities to sale consideration, and (vi) that an undertaking with a negative net worth cannot be regarded as capital asset. The transfer of net liability would only amount to gift. The Learned CIT(A), for detailed reasons given in his order at pp. 30 to 46, rejected all the contentions of the assessee and accordingly upheld the order of the AO. Aggrieved by the same, the assessee is in further appeal before the Tribunal.
3. At the outset, we may mention that the learned counsel for the assessee has restricted himself to the issue regarding computation of capital gain under s. 50B by not seriously challenging the contention taken before the lower authorities to the effect that in the absence of any cost, computation provisions fails. So, he proceeded on the footing that cement division as such amounted to capital asset and profit arising from sale of such unit would be taxable as per the special provisions of s. 50B of the Act. Accordingly, it was contended that s. 50B, being special provision, would apply in the present case and normal procedure for computing capital gain in respect of other assets would not apply. He then took us through the provisions of s. 50B and pointed out that as per sub-s. (2), “net worth” of the undertaking or division shall be deemed to be the cost of acquisition and the cost of improvement for the purposes of ss. 48 and 49 and the provisions contained in the second proviso to s. 48 are to be ignored. He then pointed out that “net worth” has been defined in Expln. 1 which provides that it shall be the aggregate value of the assets of the undertaking or the division as reduced by the value of liabilities of such undertaking or division as appearing in the books of account. He then drew our attention to Expln. 2 which provides mechanism for adopting the value of assets. According to this Explanation, depreciable assets are to be valued at WDV as per s. 43(6)(c) of the Act and non-depreciable assets are to be valued as per book value. He then pointed out that as per balance sheet of the division, there was positive net worth but because of value of depreciable assets at WDV its net worth has been worked out in negative.
4. Proceeding further, it was submitted that the expression “net worth” in respect of any asset either can be positive figure or in the alternative as “Nil”, but in no circumstances, it can be negative. He also drew our attention to the words “reduced by” used by the legislature in Expln. 1 to contend that value of an asset can be reduced upto “Nil” and in no case, it can be negative.
5. The learned CIT-Departmental Representative, Mr. Dave, has vehemently supported the order of the learned CIT(A) by reiterating the reasons given by him. He further submitted that s. 50B is a unique piece of legislation for computing capital gain in case of slump sale. According to him, it is a charging provision in contradiction to s. 45. Proceeding further, it was submitted by him that sub-s. (1) provides that capital gain arising from slump sale shall be chargeable to tax while other provisions of this section provide computation of net worth of an undertaking or division which is deemed to be the cost of acquisition and cost of improvement for the purpose of ss. 48 and 49. However, this section does not provide for computation of consideration from which such net worth is to be deducted. According to him, if the undertaking or division, being the capital asset, is saddled with any liability, then such liability must be added to the consideration received by the assessee in view of the judgment of the Hon’ble Supreme Court in the case of Attili N. Rao (supra). Regarding the definition of net worth, it is submitted that a formula has been provided by the legislature and, therefore, it has to be worked out in that manner strictly. Consequently, if such figure is in negative, then it has to be carried to the logical end. Accordingly, it was prayed that the order of the learned CIT(A) be confirmed.
6. Rival submissions have been considered carefully. At the outset, it may be mentioned that provisions of s. 50B were inserted in the Act by the Finance Act, 1999, w.e.f. 1st April, 2000. Prior to it, there were disputes as to (i) whether, transfer of business/an undertaking/division, etc., by way of slump sale constituted transfer of capital asset and (ii) whether, there was any cost of acquisition of such business/undertaking/division. The jurisdictional High Court in the case of Premier Automobile Ltd. vs. ITO (2003) 182 CTR (Bom) 202 : (2003) 264 ITR 193 (Bom), has held that assessee is liable to tax under the head “Capital gains” on the transfer of an undertaking by way of slump sale. After insertion of s. 50B in the Act, profits on transfer of such asset are chargeable to tax under the head “Capital gains” and cost of acquisition for the purpose of s. 48 would be the net worth as computed under the provisions of s. 50B. In view of this legal position, the learned counsel for the assessee, perhaps, has not seriously challenged this aspect of the matter though raised before the lower authorities. Accordingly, we hold and proceed on the footing that profit arising on the transfer of cement division by way of slump sale is chargeable to tax under the head “Capital gain”.
7. Now the dispute between the parties is narrowed down to the computation of capital gain since as per Revenue, it amounts to Rs. 226.443 crores as computed by AO while as per assessee’s counsel, it cannot exceed Rs. 75.98 crores being the sale consideration. To appreciate the controversy, it would be appropriate to reproduce the relevant provisions of s. 50B as under :
“50B Special provision for computation of capital gains in case of slump sale.—(1) Any profits or gains arising from the slump sale effected in the previous year shall be chargeable to income-tax as capital gains arising from the transfer of long-term capital assets and shall be deemed to be the income of the previous year in which the transfer took place :
(2) In relation to capital assets being an undertaking or division transferred by way of such sale, the “net worth” of the undertaking or the division, as the case may be, shall be deemed to be the cost of acquisition and the cost of improvement for the purposes of ss. 48 and 49 and no regard shall be given to the provisions contained in the second proviso to s. 48.
(3) Every assessee, in the case of slump sale, shall furnish in the prescribed form along with the return of income, a report of an accountant as defined in the Explanation below sub-s. (2) of s. 288, indicating the computation of the net worth of the undertaking or division, as the case may be, and certifying that the net worth of the undertaking or division, as the case may be, has been correctly arrived at in accordance with the provisions of this section.
Explanation 1. : For the purposes of this section, “net worth” shall be the aggregate value of total assets of the undertaking or division as reduced by the value of liabilities of such undertaking or division as appearing in its books of account :
Provided that any change in the value of assets on account of revaluation of assets shall be ignored for the purposes of computing the net worth.
Explanation 2. : For computing the net worth, the aggregate value of total assets shall be,—
(a) in the case of depreciable assets, the written down value of the block of assets determined in accordance with the provisions contained in sub-item (C) of item (i) of sub-cl. (c) of cl. (6) of s. 43; and
(b) in the case of other assets, the book value of such assets.”
A bare look at the above provisions reveals that (i) these are special provisions for computing capital gains chargeable to tax in case of slump sale and, therefore, would prevail over the general provisions in case of any conflict, (ii) the provisions of ss. 48 and 49 have been made applicable, subject to some modification, for computing capital gains in case of slump sale, (iii) net worth of the undertaking transferred shall be deemed to be the cost of acquisition and cost of improvement for the purpose of ss. 48 and 49, and (iv) net worth shall be computed in accordance with the provisions of Explns. 1 and 2. As per Expln. 1, “net worth” has been defined as aggregate value of total assets of the undertaking or division as reduced by the value of liabilities of such undertaking/division as appearing in the books of account. Explanation 2 provides that value of depreciable assets shall be taken as WDV determined under s. 43(6)(c) of the Act, while value of non-depreciable assets shall be taken as per books. The net worth so computed is to be certified by the report of accountant as defined in s. 288(2) of the Act.
8. The question for our consideration is whether “net worth” so computed can be in negative so as to increase the sale consideration by such negative figure of “net worth” for computing capital gain. In other words, can the capital gain be more than the sale consideration received by the assessee. In our humble opinion, the answer is in negative for the reasons given hereafter. Firstly, capital gain is always a portion of sale consideration and, therefore, portion can never be higher than the whole. Gain would arise only where sale consideration is more than the cost. By no stretch of imagination, it can be said that capital gain would be more than the sale consideration. No man of prudence can ever think of capital gain higher than the sale consideration. Capital gain can either be excess of sale consideration over the cost or “nil” if sale consideration is equal to cost. Where the cost is more than sale consideration, it would be a case of loss. No other situation can be visualized. Therefore, capital gain can never be more than the sale consideration. Secondly, the legislature has used the expression “net worth” which by deeming fiction is to be considered as cost of acquisition and cost of improvement for the purpose of computing capital gain under s. 48. Sec. 48 of the Act provides for deduction of cost of acquisition/improvement from the full value of consideration received or accruing as a result of transfer of capital assets. The cost of a property, as per dictionary meaning, means the price paid by a buyer to the seller. Therefore, it must be a positive figure. That is why the legislature has provided for deduction of cost from sale consideration. Similarly, the word “worth”, as per dictionary meaning, also means value of goods or asset or property, which also suggests positivity. No person would buy any property which is worthless. Further, the word “worth” is qualified by the word “net” which would mean the net value of the property which is being sold or purchased. At best, value of the property can be “Nil” but in our opinion, there is no concept of negativity with reference to the expression “net worth” or “cost of acquisition”. Thirdly, had the legislature also intended negative cost of acquisition, it would have used the words “by deducting from or adding to, as the case may be” in s. 48 of the Act instead of the words “by deducting from” actually used by it. The language used by legislature in s. 48, thus, itself shows that it never intended negative cost of acquisition. Since “net worth” in s. 50B is deemed to be the cost of acquisition as per sub-s. (2) thereof, it must also have been intended by the legislature in positive. Therefore, the expression “reduced by” used by the legislature in Expln. 1 to s. 50B, in our opinion, has been used in the sense that net worth should be arrived at positive figure or at best be reduced to “Nil”. Consequently, where the liabilities are more, then the value of assets as computed under s. 50B, the net worth, in our opinion, would be considered as “Nil”.
9. In the present case, the value of assets as per books of account is much more than the value of liabilities. No prudent person would have acquired the unit unless the value of assets or benefits attached to the division is more than the liability. The division was purchased since value of assets was more than the liabilities. It is because of WDV of assets under s. 43(6)(c) of the Act, that value of depreciable assets had to be computed at substantially low figure which resulted in the value of assets lesser than liabilities but on that account net worth cannot be reduced below the “Nil” account since such process would be contrary to the scheme of the section itself. Therefore, in view of the above discussion, it is held that “net worth” of the cement division would be taken as “Nil” which shall be deemed to be the cost of acquisition for the purpose of computing capital gain under s. 48 of the Act.
10. Coming to the contention of Mr. Dave, the next question for our consideration is whether the amount of consideration received by the assessee should be increased by the amount of liabilities of the cement division for ascertaining the full value of consideration in view of the judgment of the Hon’ble Supreme Court in the case of Attili N. Rao (supra). In our opinion, such contention cannot be accepted for the reasons given hereafter. Firstly, it was never the case of AO or the learned CIT(A). Secondly, no additional ground has been raised by the Revenue. Thirdly, even assuming that Revenue can raise such plea to support the conclusion of the AO, we do not find merit in such plea of Mr. Dave. No doubt, the judgment of apex Court would have supported Mr. Dave, but for the special provisions of s. 50B of the Act. Where an asset is saddled with liability then there are two ways for considering the value of liability while computing the capital gain. Firstly, sale consideration should be increased to the net amount realised by the vendor, as held by the apex Court in the aforesaid case. Secondly, the value of liability can be deducted from the value of assets while determining the cost of acquisition as provided in s. 50B. The legislature, in its wisdom, having opted for the second option, it is not open now for the Revenue to contend that such liability should again be added to the sale consideration realised by the vendor. If liability is to be added to the sale consideration then the same has also to be excluded from the computation of “net worth” since otherwise it would amount to double jeopardy. Such process would amount to re-writing of the provisions of s. 50B which is not permissible in law since such process is within the exclusive domain of the legislature. Therefore, considering the scheme of s. 50B, the judgment of the apex Court cannot be applied to the present case.
11. In view of the above discussion, the order of the learned CIT(A) is modified and the AO is directed to assess the capital gain at Rs. 75.98 crores.
12. The next issue relates to the disallowance of interest of Rs. 21,06,849 under s. 36(1)(iii) of the Act. This interest was paid on the loans borrowed towards the expansion of NPK plant which was capitalized by assessee but claimed as deduction while computing the total income. Reliance was placed by the assessee on various judgments but the AO rejected the claim of the assessee. On appeal, the learned CIT(A) confirmed the order of the AO. Aggrieved by the same, the assessee is in further appeal before the Tribunal.
13. After hearing both the parties, we are of the view that this issue is no more res integra since covered by the judgment of the Hon’ble Supreme Court in the case of India Cement Ltd. vs. CIT (1966) 60 ITR 52 (SC), wherein it has been held that interest on borrowed funds would be allowed irrespective of the fact whether used for day-to-day running of the business or for acquisition of business assets. Both the authorities have not given any specific reason for not following this judgment. The claim of the assessee cannot be disallowed merely on the ground that it has been capitalised in the books of accounts. Entries in the books of accounts are not relevant for rejecting the claim of the assessee if it is otherwise allowable. Reference can be made to the judgment of the Hon’ble Supreme Court in the case of Kedarnath Jute Mfg. Co. Ltd. vs. CIT (1971) 82 ITR 363 (SC). Respectfully following the above judgments, we set aside the order of the learned CIT(A) on this issue and delete the disallowance confirmed by him.
14. The next issue arising in this appeal is whether interest received by the assessee on refund received from IT Department for the year under consideration is chargeable to tax in this year or not. The learned counsel for the assessee has fairly stated that this issue is covered against him by the decision of the Special Bench in the case of Avada Trading Co. (P) Ltd. vs. Asstt. CIT (in ITA No. 508/Mum/2001 [reported at (2006) 104 TTJ (Mumbai)(SB) 83], wherein it has been held that interest accrues in the year in which interest on refund is received by the assessee. Therefore, following the said judgment, we decide the issue against the assessee. However, the AO is directed to delete the addition, if any, on the basis of income offered by the assessee in subsequent years.
15. The next issue relates to the disallowance of Rs. 1,66,329 being payments made to clubs. This amount represents payment to 10 clubs, a list of which appeared in para 6.1 of the assessment order. In the course of assessment proceedings, the assessee could not explain as to how such expenditure could be allowed as deduction under s. 37 of the Act. The only plea taken before the AO was that payments were made for business purposes. Not satisfied with such explanation, the AO disallowed the expenditure and the same has been confirmed by the learned CIT(A). Aggrieved by the same, the assessee is in appeal before the Tribunal.
16. After hearing both the parties, we do not find merit in the appeal of the assessee on this issue in absence of any details. The learned counsel for the assessee has stated before us that these payments were made on account of subscription but there is no evidence to support such submissions. Even this stand was never taken before the lower authorities. Accordingly, we reject the claim of the assessee for deduction under s. 37(1) of the Act. However, we are of the view that these expenditures should be considered as entertainment expenditure. Accordingly, the order of the learned CIT(A) is modified and the AO is directed to work out the disallowance considering the above expenditures as entertainment expenditure.
17. The next issue relates to the disallowance of Rs. 10,61,528 being payments to various clubs by way of reimbursement. The AO has disallowed the same by invoking the provisions of s. 40A(9) of the Act and the action of the AO has been confirmed by the learned CIT(A). After hearing both the parties, we find merit in the appeal of the assessee. We have gone through the provisions of s. 40A(9) of the Act, which provides that no deduction shall be allowed in respect of any sum paid by the assessee as an employer towards the set-up or formation of or as a contribution to any fund, trust, company, AOP, BOI, society, or other institution for any purpose, except covered by s. 36(1)(iv/v). There is no finding by the AO that such payments were made towards the purposes mentioned in sub-s. (9) of s. 40A. The list of expenditures is given in para 7.1 of the assessment order and the perusal of the same shows that such expenditures were incurred either by way of subsidy or by way of reimbursement of expenditure. Therefore, such expenditure cannot be considered as contribution to such club towards set-up or formation of such clubs. In our opinion, the provisions of s. 40A(9) are not applicable and, therefore, no disallowance was justified. The order of the learned CIT(A) is, therefore, set aside on this issue and the disallowance sustained by him is hereby deleted.
18. The next and the last issue arising in this appeal relates to disallowance of interest of Rs. 6,34,49,000 on the ground that such interest on borrowings was relatable to tax-free dividend income. The deduction has been made by the AO in para 8 of the assessment where it has been mentioned that assessee had invested huge amount in purchasing of shares during the year in 4 companies, namely, Chambal Fertilizers & Chemicals Ltd., Gautier India Ltd., Zuari Cement Ltd. and Green Tech Seeds International (P) Ltd., the total investment in the acquisition of shares of these companies amounted to Rs. 82,46,41,000. The assessee company was asked to explain the sources of these investments and full details of interest. The assessee stated that shares in Zuari Cement Ltd. were on account of sale of consideration on the transfer of its cement division by way of slump sale which was the major amount i.e., Rs. 75.98 crores. Regarding the minor investments in other companies, it was stated that these investments were made from internal accruals. However, the AO was not satisfied and again asked the assessee to show cause why proportionate interest be not disallowed as dividend income was exempt from taxation. The explanation of the assessee was as under :
“1. The investments made during the year as well as in earlier years were not out of borrowed funds. Borrowings are as per the terms with banks, only been used for specific purposes, such as, working capital, etc. and not for investments.
2. No borrowing was resorted for investment in shares.
3. No dividend has been received on investments made during the year.”
Not satisfied with the said explanation, he worked out the proportionate interest to Rs. 12,68,98,000. However, he assumed that part of investment would have been made through internal accruals. Accordingly, 50 per cent discount was made on this account and consequently he disallowed the interest of Rs. 6,34,49,000 on the ground that it related to earning of tax-free income under s. 10(33). The said disallowance has been confirmed by the learned CIT(A). Aggrieved by the same, the assessee is in further appeal before the Tribunal.
19. Both the parties have been heard at length. The question for our consideration is whether any disallowance of interest can be made under s. 14A of the Act on the ground that certain borrowed funds were utilised for acquiring shares whose dividend income is exempt under s. 10(33) of the Act. We have gone through the details of investments in acquiring shares of 4 companies as given in para 8.2 of the assessment order. The total investment amounts to Rs. 82,46,41,000 out of which Rs. 75.98 crores are in respect of acquisition of shares of Zuari Cement Ltd. This amount represents the sale consideration of the cement division transferred by the assessee to Zuari Cement Ltd. by way of slump sale. Thus, the finding of the AO that borrowed funds were utilised for acquiring such shares is without any basis and, therefore, has to be vacated. If this amount is excluded, then the balance amount comes to Rs. 6,48,36,000 only. The assessee has specifically contended before the AO that no borrowed funds were utilised in such investments and further no dividend has been received on investment made during the year. This contention remains uncontroverted. It has been held by the Tribunal in the case of Maruti Udyog Ltd. vs. Dy. CIT (2005) 92 TTJ (Del) 987 : (2005) 92 ITD 119 (Del), that onus is on the Department to prove that any expenditure was incurred for earning tax-free income. The entire books of account were before the AO who has not brought any material on record to prove that any interest was paid for earning tax-free income under s. 10(33). Therefore, following the said decision, the disallowance sustained by the learned CIT(A) is hereby deleted.
ITA No. 75/Mum/2005
The Revenue has raised two grounds challenging the deletion of two additions of Rs. 43,500 in respect of refund of income-tax and interest in the case of foreign concern and deletion of disallowance of Rs. 8,76,025 being expenditure incurred on acquiring bus as well as education expenses in respect of employees’ children. The learned CIT(A) has deleted the additions following his earlier orders which are disputed by the Revenue in further appeal before the Tribunal. We are told that the said appeals are still pending. In these circumstances, both the parties are agreed that the matter may be remitted to the file of AO for fresh adjudication in accordance with the final verdict of the Tribunal in the appeals relating to the earlier years. In view of the same, we set aside the order of the learned CIT(A) on these two issues and remit the matters to the file of AO for fresh adjudication in accordance with the decision of the Tribunal pertaining to the earlier years.
20. In the result, appeal of the assessee stands partly allowed while the appeal of the Revenue stands allowed for statistical purposes.
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