The above captioned appeals by Revenue under Section 260A of the Income Tax Act, 1961 („Act‟, for short) in the case of M/s Geetanjali Credits and Capital Limited, formerly known as Shubh International Limited ('respondent- assessee' for short), relate to Assessment Years 1999-2000 and 2000-01 and arise from common order of the Income Tax Appellate Tribunal, Chandigarh ('Tribunal', for short) dated 22nd April, 2016 passed in ITA Nos. 920 and 921/CHD/2008 ('impugned order' for short).
2. The appeals were admitted for hearing vide order dated 10th February, 2017 on the following substantial questions of law:-
“(1) Did the ITAT fall into error in holding that reassessment in the circumstances of the case, was not in accordance with law; and
(2) Did the ITAT fall into error in cancelling the additions made to the tune of Rs.2.1 crores and Rs.48.00 lakhs [Sic. Rs. 40.00 lakhs] (for AYs 1999-2000 and 2000-2001, respectively) under Section 68 of the Income Tax Act, 1961 in the hands of the Assessee, in the circumstances of the case.”
3. The respondent-assessee has not disputed the territorial jurisdiction of this High Court to decide the afore-captioned appeals in view of order dated 31st July, 2014 passed under Section 127 of the Act.
4. Two issues arise for consideration in view of the substantial questions of law framed vide order dated 10th February 2017. First issue relates to validity of proceedings initiated by the Assessing Officer vide notice under Section 148 read with Section 147 of the Act. The second issue relates to merits i.e. deletion of additions of Rs.2.10 crores and Rs.40 lacs made by the Assessing Officer on protective basis for the Assessment Years 1999-2000 and 2000-01 respectively, which additions were affirmed by the Commissioner of Income Tax (Appeals) on substantive basis.
5. To avoid prolixity, repetition and for convenience, we have with consent of the parties, treated the appeal preferred by the Revenue for the Assessment Year 1999-2000 as the lead case. Tribunal and the Commissioner of Income Tax (Appeals) had also treated the appeal for the Assessment Year 1999-2000 as the lead case and followed and applied their findings to the appeal for the Assessment Year 2000-01.Wherever necessary, we would refer to the facts relevant for the Assessment Year 2000-01.
6. Respondent-assessee is a public limited company, that had made a public issue for Rs. 95 Lakhs in December, 1996 which was fully subscribed. The issue was to fund the project for manufacture and sale of egg trays. However, this business/project did not start though the respondent-assessee had acquired about 2 acres of land in village Haripur, Distt. Panchkula in Haryana. Attempt made once to grow crops on the land was not successful due to non-availability of water etc. Thereafter the land could not be put to any use.
7. Bharat Bhushan Goyal, Kewal Krishan and Sunil Gupta were the Directors of the respondent-assessee, during the period relevant to the Assessment Years 1999-2000 and 2000-2001. Sunil Gupta, a Chartered Accountant by profession, was not a shareholder in the respondent-assessee.
8. The respondent-assessee in the return for the Assessment Year 1999- 2000 filed on 31st December, 1999 had declared taxable income of Rs. 6,899/-and in the return for the Assessment Year 2000-2001 filed on 11th June, 2002 had declared loss of Rs. 41,766/-. The returns were processed under Section 143(1) of the Act and were not taken up for scrutiny assessment under Section 143(3) of the Act.
9. On or about 23rd May, 2002 search and seizure operations under Section 132 of the Act were conducted in the case of M/s Lada Liquor Group by Investigation Wing, Chandigarh. It was then noticed that respondent-assessee had made investment of Rs.2.50 Crores with M/s Taranjit Singh & Co., Chandigarh, a partnership firm engaged in the business of Liquor Contractors. Payments were made in February, March and April, 1999. Money paid to M/s Taranjit Singh & Co. had not been refunded or re-paid till the date of search. Detailed enquiries by the Investigation Wing on the source of investment had revealed that cash was first deposited in different accounts of stock-brokers before it was transferred to the bank account of the respondent-assessee with Bank of Baroda, Civil Lines, Ludhiana. Source of deposits in the bank accounts of stock-brokers had remained unexplained and were dubious. This information with details and evidence were furnished to the Assessing Officer of the respondent-assessee by the Additional Director of Income Tax (Inv.), Chandigarh vide his letter dated 4th September, 2003. The Assessing Officer had thereupon recorded „reasons to believe‟ and notice under Section 148 read with Section 147 of the Act for the Assessment Year 2000-01 was issued on 6th October, 2003 and served on the respondent-assessee on 16th October, 2003 and notice for the Assessment Year 1999-2000 was issued on 30th July, 2004 and served on the respondent-assessee on 2nd August, 2004.
10. Pursuant to the said notices, the respondent-assessee had stated that the earlier returns filed under Section 139 of the Act should be treated as returns filed in response to the notices.
11. By Assessment Order dated 16th March, 2006 for the Assessment Year 1999-2000, addition of Rs.2.10 crores on protective basis on account of unexplained deposit in bank account was made, for the following reasons:-
10. To summarise, the facts of the case are that search was conducted in the case of M/s Lada Liquor whereby it was noticed that M/s Taranjit Singh & Co. took entries of Rs. 2,50,00,000/- (Rs. 2,10,00,000/- pertaining to the year under consideration) in the name of the assessee M/sShubh International Ltd. (now Nis Getanjali Capital & Credit Ltd.) through demand drafts. Perusal of bank account of the assessee shows that these demand drafts were issued by the assessee after receiving various cheques (as discussed in Para 3 above). These cheques were received by the assessee from three stock brokers namely M/s EssArr& Co., M/s S.K. Sharma & Co. and M/s Usha Garg & Co. (as shown in para 4 above) in lieu of sale of investments by the directors of the assessee in connivance with Sh. Taranjit Singh. When examined, the stock brokers failed to give ledger folio numbers/distinctive nos. of the shares sold and identity of buyers. In addition payments from so called buyers which were brought by the representatives of the assessee, have been allegedly received in cash by the stock brokers. In turn the stock brokers issued cheques to the assessee and the assessee transferred sum Rs. 2,10,00,000/- in the account of M/s Taranjit Singh & Company through Demand Drafts, Shri Bharat Bhushan, Director of the company assessee, in his statement dated 03.09.2002 has accepted that market value of shares held by the company was negligible. But these shares have been shown as sold for a whopping consideration of Rs. 2.5 crores and the whole sale was made in cash which was received by the stockBrokers on behalf of M/s Shubh International Ltd. This makes it quite obvious that these are simply sham transactions by which unaccounted cash has been introduced in the form of sale of investments of Assesse Company. This unaccounted cash is nothing but the unaccounted income of the assesse company. The director of the assesse company Sh. Bharat Bhushan has stated that control of the company was handed over to Sh. Taranjit Singh though legal formalities were not completed as Sh. Taranjit Singh expired in April, 2000 and Sh. Taranjiot sold the investments of the company.
He has further stated that the investments of the assesse company were sold by Sh. Taranjit Singh. Sh. Taranjit Singh might have sold the investment in order to bring his own unaccounted money into Assesse Company. Since the amount was paid out of bank account n. 60140 of the company maintained with Bank of Baroda, Civil Lines, Ludhiana, addition of Rs, 2,10,00,000/- is made on protective basis without prejudice to any action in the hands of M/s Taranjit Singh& Company, Chandigarh.
11. Vide order sheet entry dated 13.03.2006, Sh. Sunil Gupta, FCA, councel for the assesse company confirmed that the fads of the present case are similar to the case of assesse itself for the assessment year 2000-01 and claimed that there is no justification of making double addition as the addition has been made by the ACIT (Central Circle) in the case of lulls Taranjit Singh & Co. in respect of credits received from the assesse company.
12. The replies of the assesse company have been considered. He has accepted that the facts are similar for the Assessment Year 2000-01 in which addition of Rs. 40,00,000/- was made on protective basis in respect of entries pertaining to that year. Total of entries pertaining to this year comes to Rs. 2,10,00,000/-. Protective assessment does not tantamount to double addition as claimed by the assesse.
13. In view of above, an addition of Rs. 2,10,00,000/- is made in the hands of the assessee company on protective basis without prejudice to any action in the hands of M/s Taranjit Singh &Company, Chandigarh.
12. By the Assessment Order dated 30th March, 2005 for the Assessment Year 2000-01, the Assessing Officer made an addition of Rs.40 lacs on protective basis on account of unexplained deposit in the bank account and investment for the following reasons: -
“7.1. On 21.03.2005 a copy of a/c of M/s Shubh International Ltd. as appearing in the books of account of M/s Sharma & Co. was furnished. Shri S.K. Sharma failed to furnish the names & addresses of company whose shares were sold by him.
7.2 Hence, it has been established that the directors of M/s Shubh International Ltd. has introduced their unexplained money in the guise of shares in the bank account of the company from which the amount was further advanced to M/S Taranjit Singh & Company.
8. Vide order sheet entry dated 21.3.2005 the assessee company was asked to furnish the distinct number of shares which were sold by M/s Usha Garg & Co., M/s EssArr& Co. and M/s S.K. Sharma & Co.
8.1 On 23.3.2005 Shri Sunil Gupta, CA furnished the names of the companies whose shares were sold by the above mentioned concerned which are as under:-
8.2 The counsel for the assessee company failed to supply the complete addresses of the companies of which the shares were sold bythe stock brokers on behalf of Shubh International Ltd. Before the DDIT(Inv.) the assessee has not filed the detail of share holding of above companies. In the return of income the assessee has also failed to show the transactions as well as the income from these transactions, it clearly shows that no sale of shares have been taken place. Only the accommodation entries have been given by the above mentioned stock brokers to M/s Shubh International Ltd. by issuing the cheques amounting to Rs. 40,00,000/- which was further advanced to M/s Taranjit Singh & Company, Chandigarh during the year 1999-2000 relevant to the A.Y 2000-01.
9. The statement of Shri Bharat Bhushan Goyal, Director, shows that investments held by the company were not worth the liability of the company. Since the amount was paid out of the bank account No. 60140 of the company maintained with Bank of Baroda Civil Lines, Ludhiana, addition of Rs.40,00,000/- is made on protective basis without prejudice to any action in the hands of M/s Taranjit Singh & Company, Chandigarh.”
13. Two Assessment Orders had reproduced details of deposits/credit and payments/debit entries in the account of the respondent-assessee with Bank of Baroda, Civil Lines, Ludhiana. In this manner deposits made were collated with issue of bank drafts/cheques in favour of the M/s Taranjit Singh & Co. Assessment Orders had reproduced statement on oath made by Bharat Bhushan Goyal, Director of the respondent-assessee recorded on 3rd September, 2002 by Dy. Director (Inv.) Chandigarh accepting that worthless shares held by the respondent-assessee were purportedly disposed of for more than Rs. 2 crores and credited in the account in Bank of Baroda by transfer/payments by the stock-brokers. Amounts deposited were then transferred to M/s Taranjit Singh & Co. These transactions relating to purchase and sale of shares to generate book entries were bogus and sham and were allegedly made by Taranjit Singh who was also wanting to take control of the respondent-assessee, for which legal formalities had not been completed. Taranjit Singh, partner of M/s Taranjit Sigh & Co., died in April, 2000 and thereafter the respondent-assessee had tried to recover the investment from Ms. Mahinder Kaur, the legal representative/heir of Taranjit Singh. We shall subsequently refer to and reproduce statement made by Bharat Bhushan Goyal.
14. The Assessment Orders also extensively quote from statements made on oath by Shagun Garg, authorized signatory of M/s Usha Garg and Company, Ludhiana; Hari Krishan Punni, authorized signatory of M/s Ess Arr and Company, Ludhiana and Sudhir Kumar Sharma, proprietor of S.K. Sharma and Company, Ludhiana, the stock-brokers through whom the respondent-assessee had made investments and sold the worthless shares. They had confirmed the sham and bogus nature of share transactions accepting that they did not know the purchasers to whom the shares were sold as the purchasers were brought to them by representatives of the respondent-assessee and were unknown persons who had paid cash as sale price which was deposited in the bank accounts of the stock-brokers, who in turn had issued cheques in favour of the respondent-assessee. The stockbrokers were unable to even give detail of distinctive number of shares, name and addresses of the purchasers etc. We would subsequently reproduce relevant portion of their statements.
33. Hari Krishan Punni, authorized signatory of M/s Ess Arr and Company, Ludhiana in his statement recorded on 20th August, 2002 had stated:-
“Q. Please give the detail of sizeof the deal youhad made withShubh International Ltd. during last 3-4 years?
A. We had sold and purchased shares for M/s Shubh International Ltd. for about 90 lacs during the last four years. We have already furnished you the account of above company. Giving all the details of size of above transactions.
Q. How did you buy/sell shares for concern M/s Shubh International ltd. Who use to visit you for delivery of shares and get payments on behalf of the company when shares are sold to you. What was the mode of payment i.e. cash or cheques?
A The representative of the company i.e. M/s Shubh International Ltd, use to come and give order frequently inthe year 1998 for the sale/purchase of shares. The procedure for the sale of shares is firstly representative places the orders for purchase of shares which is written in a register i.e. day book. When we execute the order then the delivery of shares is made to us and we made the payment within a stipulated period of 12-15 days of the execution of the deal. We usually made the payments by cheque but when the amount is Rs.20,000/- or less it was made also in cash.
Q. You have stated above that representative of the company i.e. Shubh International Ltd. use to visit you for sale/purchase of shares. Please give the names and addresses of these representatives who visited you on behalf of the company?
A. At present, I am unable to give you the names and addresses of the persons who use to visit me. I will check up my records and submit the same.
Q. In the copy of ledger account supplied by you. You have not mentioned the ledger Folio no. Distinctive No. Name of the purchaser. Mode of payment received from the buyer and mode of payment made to the seller in the case of shares sold on behalf of Shubh International Ltd.?
A. The ledger account do not have above things mentioned. The relevant information as required by you will be supplied on the next date.
Q. Now did you sell or buy shares for M/s Shubh International Ltd. Did the representative of the company brought the buyer with themselves and asked you to execute the deal?
A. The shares were sold on behalf of Shubh International Ltd. to various persons brought by the representatives who deals with us. I want to make it clear that………. I was directly involved as the transactions of sale/purchase of shares of Shubh International Ltd. were of special kind i.e. of different nature. The representative of the company used to bring buyers in whose names shares were to be transferred. The cash payments were received from the buyers brought by the representatives of the company M/s Shubh International Ltd. The cash brought by these so called buyers were deposited in my bank account and cheques were issued thereafter to the representative of the company M/s ShubhIntenational Ltd.”
34. Sudhir Kumar Sharma, proprietor of S.K. Sharma and Company, Ludhiana, in his statement recorded by the Assessing Officer on 11th March, 2005 had stated as under:-
“Q. As per information available with this office you have sold shares held by M/s Shubh International Ltd. to some other parties. Please state the number of such shares, the names of the companies and Distinct No. of these shares?
A. At present, this information is not readily available with me. I will consult my records and send the same within 3-4 days positively.
Q. Please state the name of the person who approached you to sell the shares held by M/s Shubh International Ltd. during the year 1998-99 and 1999-2000?
A. Some representative of the company contacted me at my office. I do not remember his name as the matter is about three years old.
Q. Please state how you have received the payments of these shares on behalf of M/s Shubh International Ltd.?
A. At present, I cannot tell anything about these transactions. I will consult my records and send the reply accordingly.”
35. In addition to the statements, the Assessing Officer had details of the credit entries i.e. investment made by the respondent-assessee of Rs.2.10 crores with M/s Taranjit Singh & Co. The aforesaid evidence and material was available with the Assessing Officer when he had recorded the 'reasons to believe'.
36. The impugned order passed by the Tribunal does not dispute the evidence and material, albeit holds that this material was not tangible for the three brokers did exist and it was known that the source of deposit in the bank account was a sale of shares/investments. No information was received by the Assessing Officer from the Investigation Wing that the respondent-assessee had received accommodation entry (see paragraph 25(i) of the impugned order). The aforesaid rationale is incorrect, for whether or not any accommodation entry was received has to be inferred and concluded from the facts by the Assessing Officer, and not by a third person. It is the subjective opinion formed by the Assessing Officer that has to be tested on the principle of an honest and reasonable person. In this case, the stockbrokers had elucidated on the sham and bogus nature of the share transaction i.e., investment and sale of worthless shares which was done through unknown persons who were the respondent-assessee's representatives, and other facts accepted and admitted in the statements which were recorded by the Investigation Wing.
37. Similarly, paragraph 25(ii) of the impugned order proceeds on wrong premise that when the block assessment order in the case of Ms. Mohinder Kaur was quashed on the technical ground that addition of Rs. 2.5 crores could not have been made in the block assessment proceedings, re-opening under Section 147 read with Section 148 of the Act would not be justified, for the entire money of Taranjit Singh was routed through the respondentassessee or the Revenue could not take a 'somersault' for the purpose of reopening assessment or make addition on substantive basis later on. This reasoning is wrong and fallacious being contrary to law, for appellate orders in the case of Ms. Mohinder Kaur had not been passed when the 'reason to believe' in the case of respondent-assessee were recorded. The 'reason to believe' recorded cannot be set aside on the basis of the appellate order in the case respondent-assessee making substantive addition instead of protective additions made in the assessment order. Question of 'somersault' does not arise when protective addition made into substantive addition.
38. We, at this stage, reproduce the findings of the Tribunal in paragraphs 28 to 30, which read as under:-
“28. It may also be noted here that the assessee explained that investments/shares have been sold by the assessee company through three brokers. The brokers in their statements have confirmed selling the shares/investments on behalf of the assessee company. They have also confirmed giving of sale consideration through banking channel to the assessee company in their statements. The existence of brokers not disputed. The assessee proved identity of brokers and their creditworthiness and genuineness of transaction. The assessee proved source of money deposited in their bank account on account of sale of shares/investments. It is not a case of A.O. that despite sale of shares/investments, assessee still possessed and controlled the same shares/investments. The Assessing Officer did not record anywhere in the assessment order if these statements recorded by DDIT (Investigation) of the brokers have been supplied to the assessee for the comments of the assessee and whether assessee has been given any opportunity to cross-examine these brokers. In the absence of any evidence or material on record, it is difficult to believe that assessee has been given any opportunity to cross-examine the statements of these three brokers on behalf of the assessee. Therefore, when these brokers have confirmed selling the shares on behalf of the assessee company and giving sale consideration through banking channel to the assessee company and their statements are not adverse in nature against assessee, but in the absence of giving right of crossexamination of their statement, their statements cannot be read in evidence against the assessee on certain points which have been considered by Assessing Officer to be adverse in nature. We rely upon decision of Hon‟ble Supreme Court in the case of Kishan Chand Chela Ram (supra).
29. It may also be noted here that Assessing Officer has recorded two statements in both assessment year as per assessment order but Assessing Officer has not recorded any fact if assesseee has been allowed to crossexamine these brokers at assessment stage. Therefore, on the same analogy, even if their statements are not adverse in nature against assessee but same cannot be read in evidence against the assessee for the purpose of making addition. It may also be noted here that Assessing Officer himself has mentioned in the assessment order that sale consideration and source of giving advance to M/s Taranjit Singh & Co., Chandigarh is the amount received through three brokers through banking channel, therefore, Assessing Officer cannot ask the assessee to prove source of the source. The Assessing Officer has also not brought any evidence on record that despite selling the investments through the brokers, assessee company was still having ownership and possession over the same investments held by the assessee company. These facts and material on record clearly suggest that assessee genuinely sold the investments/shares through three brokers and received the sale consideration through banking channel. Therefore, such consideration could not be treated as undisclosed unaccounted income of the assessee.
30. Considering the facts and circumstances of the case in the light of the material, evidences on record and above discussion, we are of the view assessee has been able to prove that it has received the sale consideration on account of sale of shares/investments and has genuinely entered into the bank account. Therefore, no addition against the assessee could be made. We, accordingly, set aside the orders of authorities below and delete the addition of Rs.2.10 Cr converted by ld. CIT (Appeals) on substantive basis.”
39. There is a contradiction in the findings recorded in paragraphs 23 to 27 in the impugned order and what has been recorded in paragraphs 28 to 30. In paragraphs 23 to 27 the Tribunal accepts and holds that Taranjit Singh was responsible and the addition was assessable in his hands as undisclosed income. In paragraphs 28 to 30, the Tribunal, in fact, upholds and accepts that the investment was genuine and valid. We shall deal with the findings in Para 27 to 30 while examining question no. 2. Question No. 1 is accordingly answered in favour of the appellant/Revenue and against the respondent/assessee.
Question No.1, ITA No. 75/2017 (AY 2000-01).
40. Order passed by the Tribunal does not record and exact the 'reason to believe' and without reproducing and examining the same, holds that following the reasons given for the Assessment Year 1999-2000, they would quash the reopening of the assessment under Sections 147 and 148 of the Act and also delete the addition of Rs.40 lacs made by the Commissioner of Income Tax (Appeals) on substantive basis. We have already commented upon the reasoning given by the Tribunal on the question of reopening for the Assessment Year 1999-2000. As the Tribunal has not considered and examined the 'reasons to believe' for the Assessment Year 2000-01, we would pass an order of remit for fresh consideration. Question No. 1 is accordingly answered.
Question No.2, ITA No. 74/2017 (AY 1999-2000) & 75/2017 (AY 2000- 01).
41. As regards question No. 2 in ITA Nos. 74/2017, we have already pointed out contradiction of the first order of the Tribunal vide paragraphs 23 to 26, 27 and second portion of the order of the Tribunal vide paragraphs 28 to 30.
42. Apart from the said contradiction, we find that the Tribunal has not taken notice of the statements of Bharat Bhushan Goyal, and the three brokers, reproduced in the Assessment Orders, on the ground that there was violation of principles of natural justice. The reason given was that the Assessment Orders do not record that the assessee had been allowed to cross examine the brokers at the assessment stage. An adverse presumption has been drawn to affirmatively believe and hold that the respondent-assessee was not given opportunity to cross examine or was denied the right to cross examine because the Assessment Order did not record that such opportunity was granted. The presumption is wrong and perverse . The finding, in fact, ignores the grounds of appeal reproduced in the order of the Commissioner of Income Tax (Appeals) dated 19 th September, 2008,which read :-
“1. That assessment order is against law and facts on the file in as much as the Ld. Income Tax Officer, framing assessment was not justified to make an arbitrary addition of Rs. 2.10 crores, although on protective basis on the ground that three brokers namely M/s S.K. Sharma & Company, Ms. Usha Garg & Chemical and M/s EssArr& Company have given accommodation entries to the appellant Company whatever amounts has been received were on account of sale proceeds of shares made through them.
2. That action of the Ld. Assessing Officer in recalling to provisions u/s 148 is had in law.”
43. The assessee had not raised a specific ground that they were not furnished statements on oath or were denied opportunity to cross-examine the brokers. The Assessment Order specifically refers to the failure of the stock brokers to produce relevant documents/papers. Assessing Officer had not only relied upon the statements recorded by Deputy Director (Inv.) but had also himself recorded the statement of Shagun Garg on 11th March, 2005. The Commissioner of Income Tax (Appeals) had similarly recorded the statement of Hari Krishan Punni on 27th February, 2008 during the pendency of the appeal. Relevant facts noticed in the assessment order, statement an oath etc. have been passed over and overlooked.
44. In view of the aforesaid discussion, we would answer the substantial question of law No. (2) framed in ITA No.74/2017, relating to Assessment Year 1999-2000 in favour of the appellant-Revenue and against the respondent-assessee, albeit, with an order of remand to the Tribunal to decide the issues raised on merits after duly taking into account all facts and circumstances recorded by the Assessing Officer and the first Appellate Authority. The decision would be taken afresh without being influenced by the impugned order or present judgment. We have passed an order of remand on question No.(2) in the present ITA relating to Assessment Year 1999-2000 in view of the remand order in ITA No.75/2017 passed in respect of question No.(1). Question No.(2) in respect of ITA No.75/2017 is also accordingly answered in the manner indicated above with a direction to the Tribunal to decide the question afresh on merits.
45. The appeals are accordingly disposed of, with no order as to the costs. Parties would appear before the Tribunal on the 12th of March, 2019, when a date of hearing would be fixed.
Cases Referred to
1. Inductotherm (India) P. Ltd. V M. Gopalan, DCIT, 356 ITR 481
2. Signature Hotels P. Ltd. Vs ITO & Another 338 ITR 51
3. CIT Vs Smt. ManibenValji Shah 283 ITR 453
4. Assistant Commissioner of Income Tax versus Rajesh Jhaveri Stock Brokers Private Limited, (2008) 14 SCC 208
5. Apogee International Ltd. v. Union of India [(1996) 220 ITR 248 (Del)
6. Deputy Commissioner of Income Tax and Another versus Zuari Estate Development and investment Company Limited, (2015) 15 SCC 248
7. Central Provinces Manganese Ore. Company Limited versus I.T.O., Nagpur,(1991) 191 ITR 662 (SC)
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