Undoubtedly, the Respondent municipal corporation would be required to determine the assessable value/price on which the octroi can be levied in accordance with the Octroi Rules. The power to determine this value undoubtedly rests with the Respondent and its officers. It cannot be said that any decision taken by the Respondents/its officers competent to decide the value for the purpose of levy of octroi is without power or in excess of their jurisdiction. The error, if any, in determination of the assessable value for the purpose of levy of octroi would be an error within the powers or within the jurisdiction of the Respondent and its officers. Such an error can be corrected in an appeal under Section 406 of the BPMC Act. A civil suit would not be an appropriate remedy and the civil court would not have jurisdiction to decide the issue. The jurisdiction of the civil court is excluded by necessary implication by reason of a provision of an appeal against determination of an octroi (which is a tax) contained in Section 406 of the BPMC Act.
IN THE HIGH COURT OF BOMBAY
Appeal From Order NO. 1379 of 2010
Decided On: 12.07.2011
Titan Industries Limited Vs. Thane Municipal Corporation and Ors.
Hon'ble Judges/Coram:
D.G. Karnik, J.
Citation: MANU/MH/0889/2011
1. This appeal is directed against the judgment and order dated 30 November 2010 passed by the 8th Joint Civil Judge, Sr. Division, Thane dismissing the Appellant's application for temporary injunction with costs.
2. The Appellant manufactures and sells gold ornaments and jewellery under the brand name "Tanishq" through various outlets/showrooms in different cities and towns. One selling outlet/showroom of the Appellant is situated in the city of Thane within the limit of Thane Municipal Corporation. The Appellant imports ornaments and jewellery manufactured by it for sale in its showroom at Thane. In the invoices/goods transfer memos sent from its factory to the Thane showroom, the Appellant mentions the price of the ornaments on the basis of their gold content and the same price is declared for the purpose of octroi duty at the octroi naka. The Appellant actually sells the ornaments/jewellery in its shop at a price which is higher than the price shown in the invoice. The difference in the sale price and the import price shown in the invoice/goods transfer memo is the profit earned by the Appellant. This gross profit, in the trade parlance is called as the labour charges or making charges.
3. On 22 September 2010, the Respondent issued a notice purporting to be a notice under Rule 30(2) of the Thane Municipal Corporation (Octroi) Rules, 1999 (for short "the Octroi Rules") calling upon the Appellant to give inspection of the goods inward register, stock register, sale bills, sales tax receipts, custom receipts, receipts of payment of excise and bank statements for the period between 20 September 2009 and 20 September 2010 to the inspectors of the Respondent. The Appellant complied with the requisition and gave inspection of all the documents. During the course of inspection, the inspectors discovered that the price at which the ornaments/jewellery were sold by the Appellant through the retail outlet was higher than the price shown in the import invoices/goods transfer memos and the octroi was paid not on the sale price of the goods but on the import price shown in the invoices. The Respondent, therefore, issued a notice to the Appellant on 3 November 2010 calling upon it to pay the octroi duty on the difference between the sale price and the price shown in the import invoices amounting to Rs. 36,39,251/- and the penalty of Rs. 3,63,92,510/- being ten times the amount of the octroi duty evaded. The notice also stated that if the duty and the penalty was not paid, the property and assets of the Appellant would be attached. After some correspondence which ensued, the Respondent attached from the showroom of the Respondent 339 items of ornaments/jewellery contained in 9 boxes. The attached ornaments and boxes were then given in custody of Hemant Deshpande, representative of the Appellant for safe custody. Feeling aggrieved by the illegal notice of inspection, illegal levy of octroi, illegal procedure followed and illegal attachment of the ornaments and jewellery by the Respondent, the Appellant filed a suit, bearing Special Civil Suit No. 793/10, in the Court of Civil Judge, Sr. Division, Thane. By the suit, the Appellant inter alia prayed for a declaration that the demand notice was illegal, arbitrary and void; the demand of the octroi was illegal and void; the attachment of the ornaments was illegal and void and other ancillary reliefs. In the suit, the Appellant made an application for an interim injunction restraining the Respondent from in any manner acting upon the notice of demand of the octroi and also made a prayer that the goods attached and sealed by the Respondent be released on such terms and conditions as the Court thought fit. The Respondent, by filing a reply opposed the application. By an order dated 30 November 2010, the trial court rejected the application. That order is impugned in the present appeal.
4. The trial court held that the Appellant had not made out a prima facie case for grant of an interim injunction. It also held that the balance of convenience was not in favour of the Appellant and that irreparable loss would be not caused to the Appellant if the relief of injunction was refused. Though no specific finding was recorded on the contention of the Respondent that the had no jurisdiction to entertain and try the suit, the trial Court held that the remedy of an appeal provided Under Section 406 of the Bombay Provincial Municipal Corporation Act 1949 (for short "BPMC Act") was an alternative and equally efficacious remedy available to the Appellant and hence, balance of convenience did not lie in favour of the Appellant.
5. Assailing the findings of the trial Court, Mr. Tulzapurkar, learned Counsel for the Appellant submitted that the remedy by way of a suit was not barred as in the present case, the demand of octroi was totally illegal and ultra vires. He submitted that the initial notice of inspection dated 22 September 2010 purporting to be issued under Section 430(2) of the Octroi Rules was ultra virus and illegal. Rule 30 of the Octroi Rules did not empower the Respondent municipal corporation to inspect the records. Assuming that the Respondent had the power to inspect the records, the Respondent could not have demanded inspection of the records beyond one year and since the notice demanded inspection of the records of the period remoter than one year, the notice was without authority to law and was illegal. Inspection carried out in pursuance of illegal notice was also illegal and the demand of octroi based on such illegal inspection and illegal notice was illegal and without authority of law. He further submitted that the valuation of the goods for the purpose of octroi could be made only in accordance with Rule 16 of the Octroi Rules. The making charges which were added by the Appellant while selling the goods at the showroom were nothing but the gross profit earned by the Appellant and the amount of profit can never be included in the value of the goods for the purpose of octroi. Rule 16 of the Octroi Rules submitted, Mr. Tulzapurkar, does not permit the Respondent from inclusion of making charges which were in the nature of profit while determining the value of the goods. Relying upon a decision of a Division Bench of this Court in Municipal Council, Morshi v. Tulsiram Vishwanath Gadbail MANU/MH/0393/1977 : 1977 Mh.L.J. 735, he submitted that the scope of an appeal under the Maharashtra Municipalities Act is confined to the valuation of goods and the legality and validity of the Tax cannot be challenged in the appeal. Since the validity of the levy was challenged in the present suit, jurisdiction of the civil court to entertain and try the suit was not excluded. In support of this submission, he also relied upon two other decisions of this Court in Balkrishna Vora v. Poona Municipal Corporation MANU/MH/0203/1962 : 1963 Mh.L.J 325 and Gopal Mills Co. Ltd v. The Broach Borough Municipality (1995) 58 Bom.L.R 300.
6. Per contra, Mr. Tekawade, learned Counsel appearing for the Respondent submitted that Section 406 of the BPMC Act provides for an appeal against any rateable value or tax fixed or charged under the BPMC Act to the Judge. The octroi in the present case was a tax levied and demanded under the BPMC Act and therefore, the jurisdiction of a civil court to entertain and try the suit against the demand of octroi was impliedly barred. In support, he referred to and relied on the following decisions of this Court.
(i). Subhash Trading Company and Ors. v. Municipal Corporation Solapur and Ors. 1998 (5) LJ 337,
(ii). M. Sector Industries v. State of Maharashtra MANU/MH/0803/2000 : 2002 (1) Bom. C.R. 725.
(iii). Mahratta Chamber of Commerce, Industries and Agriculture v. State of Maharashtra MANU/MH/0476/2003 : 2003 (4) All MR 32.
(iv). Small Scale Enterpreneurs Association v. State of Maharashtra 2007(3) Bom.C.R. 496 and
(v). Commissioner of Sangli Miraj Up wade Cities v. Bide and Sons MANU/MH/1151/2006 : 2007(3) Bom.C.R.732.
He also referred to and relied upon a decision of the Supreme Court in NDMC v. Satish Chand, MANU/SC/0703/2003 : (2003) 10 SCC 38.
7. In Gopal Mills Co. Ltd (supra) the Plaintiff had filed a suit for a declaration that certain taxes (house tax and its components) imposed by the Broach Municipality were illegal and asked for an injunction restraining the municipality from recovering the taxes and also asked for refund of taxes which were paid under protest. The municipality inter alia contended that the civil court had no jurisdiction to entertain the suit as an appeal against the tax was provided to the Magistrate under the Municipal Borroughs Act, 1925. The Division Bench held that it is well settled that when an Act sets up a special machinery and provides for a special tribunal then the party affected by any action taken under the Act must seek redress according to the special machinery and before the special tribunal, and by reason of setting up of a special tribunal the jurisdiction of a civil court would be excluded. The provision of the Municipal Borroughs Act making the decision of the Magistrate final clearly excluded the jurisdiction of the civil court to decide questions which were to be decided by the Magistrate and ultimately in revision by the appellate Court. However, the jurisdiction of the Magistrate is limited to consider the question with regard to the quantum of taxation. It is not open to him to consider whether the tax that was imposed was valid or ultra virus the municipality. The suit to the extent it related to the legality of taxes and the power of municipality to impose taxes was concerned, was held to be maintainable.
8. In Balkrishna Vora v. Poona Municipal Corporation (Supra)the Division Bench held that scope of an appeal under Section 406(1) of the BPMC Act does not cover the vires of the Tax or legality of the Tax. It is always open for the civil court to entertain a suit where the question is one of legality of the tax.
9. In Municipal Council, Morshi (supra), this Court held that in an appeal under Section 169 of the Municipalities Act, it was not open to an Assessee to challenge the legality or validity of the tax itself. In other words, for challenging the legality and validity of the tax, the proper remedy would be a suit because the appellate authority under the Act is not entitled to decide upon the legality and validity of the tax.
10. In Subhash Trading Co.(supra) this Court held that the Petitioner had an alternative efficacious remedy by way of an appeal Under Section 406 of the BPMC Act against the order of the Assistant Municipal Commissioner. Therefore, the Court declined to exercise writ jurisdiction under Article 226 of the Constitution of India. Similarly, in the case of M. Sector Industries Charitable Trust (supra), this Court declined to exercise writ jurisdiction under Article 226 of the Constitution of India in relation to a property tax in view of availability of alternative and efficacious remedy by way of an appeal under the Municipalities Act. In the case of Mahratta Chamber of Commerce, Industries and Agriculture (supra) also this Court declined to exercise writ jurisdiction under Article 226 of the Constitution of India in view of availability of statutory alternative and equally efficacious remedy of an appeal under Section 406 of the BPMC Act. Similarly in the case of Small Scale Enterpreneurs Association v. State of Maharashtra (supra)this Court held that in view of a remedy by way of an appeal against imposition of a property tax, the writ petition was not tenable. The aforementioned decisions are based upon a well established principle that the High Court would not exercise extra ordinary jurisdiction under Article 226 and 227 of the Constitution of India when there exists an alternative and equally efficacious remedy by way of an appeal to a statutory authority. They do not consider the question of ouster of a jurisdiction of a civil court Under Section 9 of the Code of Civil Procedure and these decisions therefore are of no assistance to the Respondent.
11. The decision of the Supreme Court in NDMC v. Satish Chand, MANU/SC/0703/2003 : 2003 (10) SCC 38is to the point. The Respondent therein was owner of a basement in a property at New Delhi. The said property was assessed to tax by the Appellant municipal corporation. According to the Respondent, the basement could not be put to use because it gets filled up with sub-soil water. For this reason, the Respondent claimed that the basement could not be said to have any rateable value and therefore could not be assessed to tax. In spite of this, the Appellant assessed the said property to tax, by rejecting the objections filed by the Respondent and sent a notice of demand regarding arrears of property tax. The Respondent filed a suit for permanent injunction contending that the action of the Appellant in assessment of the said property to property tax and demanding arrears of tax was illegal and without jurisdiction. The Appellant took a preliminary objection against the maintainability of the suit, on the ground that section 84 of the Punjab Municipal Act, 1911 contained a provision of an appeal against the assessment or levy of a tax to the Deputy Commissioner or such other Officer as may be empowered by the State Government. The trial Court upheld the objection regarding the maintainability of the suit and dismissed it. However, the appeal against the judgment was allowed by the Sr. Civil Judge. The High Court dismissed the Second Appeal in limine. The Appellant approached the Supreme Court by special leave. The Supreme Court held that Section 9 of the Code of Civil Procedure gives a wide jurisdiction to the civil courts to try all suits of civil nature excepting the suits of which cognizance is either expressly or impliedly barred. An express bar is where a statute itself contains a provision that the jurisdiction of the civil court is barred. An implied bar would arise when a statute provides a special remedy to an aggrieved party like a right of appeal as contained in the Punjab Municipal Act. Allowing the appeal, the Supreme Court held that in view of a provision of an appeal Under Section 84 of the Punjab Municipal Act, the jurisdiction of a civil court to entertain a suit challenging the tax was impliedly barred.
12. From the decisions cited above, the position of law appears to be well settled. Section 9 of the Code of Civil Procedure provides that the civil court shall have jurisdiction to try all suits of a civil nature excepting the suits of which cognizance is barred either expressly or impliedly. In Dhulabai v. State of Madhya Pradesh, MANU/SC/0157/1968 : AIR 1969 SC 78, the Supreme Court has held that jurisdiction of a civil court to entertain and try a suit may be barred by an express provision of a statute or even impliedly. Although the Supreme Court has held that the implied bar to the jurisdiction of the civil court cannot be inferred lightly it did recognise that jurisdiction of a civil court can be barred by necessary implication. The fact there is a provision of an appeal is often construed as on implied bar to the jurisdiction of the civil court to entertain a suit. However, where a tax is sought to be levied without the authority of law, the jurisdiction of a civil court to entertain a suit against the levy would not be barred. If a municipality/municipal corporation seeks to impose a tax which it is not authorised by the Act to impose, a civil suit would be maintainable. For example, sub-section (1) of Section 127 of the BPMC Act requires a municipal corporation to impose two kinds of taxes viz, a property tax and a tax on vehicles, boats and animals and Sub-section (2) of Section 127 authorises a municipal corporation to levy six other types of taxes mentioned in Clauses (a) to (f) thereof. Clause (f) of sub-section (2) of Section 127 permits a municipal corporation to levy any other tax not being a tax on professions, trades, callings and employments which the state legislature has the power under the constitution to impose in the State. If a municipal corporation seeks to impose a tax on profession, trade, callings and employments that would be clearly illegal being contrary to the provisions of Clause (f) of sub-section (2) of Section 127 of the BPMC Act. If such a tax is levied, it would not be necessary for a citizen to file an appeal against the tax Under Section 406 of the BPMC Act and it would be open for him to challenge the levy and/or demand of the tax by filing of a civil suit. For, the levy of the tax is not authorised by the Act and consequently, the jurisdiction of a civil court to challenge recovery of such tax cannot be said to be impliedly barred by the Act.
13. Octroi undoubtedly is a tax which the municipal corporation is entitled to levy under Clause (a) of sub-section (2) of section127 of the BPMC act. An appeal lies Under Section 406 of the BPMC Act against the levy of an octroi. Consequently, the jurisdiction of a civil court to entertain a suit against the octroi levied, is implied barred as held by the Supreme Court in the case of NDMC v. Satish Chand (supra).The octroi, however, can be levied only in accordance with the Octroi Rules and at the rates specified in the Rules. If there is a flagrant violation of the Octroi Rules or tax (octroi) is levied at a rate higher than the maximum rate permitted under the Rules, it cannot be said that the octroi is levied under the Octroi Rules framed under the Act. The levy which is not in accordance with the Octroi Rules or the schedule to the rules being not a levy under the Rules and under the Act can be challenged by an ordinary suit filed in a civil court under Section 9 of the Code of Civil Procedure. To illustrate, Rule 3 of the Octroi Rules provides that the octroi shall not be levied by the Corporation on any goods at the rate exceeding the maximum rate specified in column 3 of the schedule. Entry 1 of the Octroi Rules provides that the maximum rate of octroi on grains, flour, pulse and cereals etc. shall be 1 % ad valorem. If the municipal corporation were to levy octroi say at the rate of 2 % on grains, flour and pulses i.e in excess of the maximum permissible limit, the levy would be clearly contrary to the Octroi Rules and contrary to law. It would then be open to a citizen to challenge the levy of an octroi levied at the rate of 2% on grains, flour and pulses by means of a suit in a civil court. This is especially so because Section 406 contemplates that no appeal against any tax, the amount of disputed tax claimed from the Appellant has been deposited by the Appellant with the Commissioner. Though in case of a tax which is levied in accordance with law, the condition of deposit of a disputed tax may be valid, the condition of deposit even of the tax which is ex- facie illegal and without authority of law cannot be said to be an adequate and effectious remedy, for a citizen who is not liable to pay illegal tax and the person has no means to pay the illegally demanded tax would have no remedy under the Act. Where the demand of a tax is ex-facie illegal and without authority of law, the jurisdiction of a civil court to entertain and try the suit against the illegal demand of tax cannot be said to be impliedly barred.
14. Another illustration that can be given is in respect of a tax which the state legislature is not empowered to impose in the State under the Constitution of India. The State Government cannot authorise a municipal corporation to levy a tax within its limits which the State Legislature itself cannot impose. Apart from the constitutional bar the prohibition is specifically embodied in clause (f) of sub-section (2) of Section 127 of the BPMC Act. Say, if a municipal corporation decides to impose a tax on the income earned by a citizen carrying on a business within its limits, such a tax being in the nature of income tax which cannot be imposed by a state, the municipal corporation cannot to impose a tax on the income of a citizen. In breach, if a municipal corporation seeks to impose a tax on the income of a person, such a tax being clearly without the authority of law a suit would lie if against such tax if sought to be imposed by the municipal corporation.
15. I would now proceed to consider the argument of Mr. Tulzapurkar that the notice dated 22 September 2010 was without authority of law and consequently, all further proceedings initiated and continued in pursuance of the notice culminating in the demand of octroi were illegal and without authority of law.
Rule 30 of the Octroi Rules reads as under:
30 Expeditious disposal of refund applications. (1) All applications for refund shall be promptly dealt with and when a claim has been found to be in order, intimation shall be given to the applicant to receive the amount and payment of refund shall be made on demand.
(2) If a Municipal officer not below the rank of Octroi Inspector considers that examination of specified statements, registers or documents of the importer is necessary to determine any issue relating to (a) octroi paid or to be paid, (b) the observance of conditions by the importer on the basis of which any exemption or concession is or was claimed, (c) declaration made by the importer or (d) such other matters the importer shall, upon requisition in writing made by such officers, produce before him forthwith the relevant statements, registers and documents. No such requisition shall be made by such officer after the expiry of a period of one year from the date of making any declaration or the data of payment of the Octroi or the deposit or where no such payment is made for any reason, the date, on which the goods are cleared from the place of import, as the case may be.
16. Sub-rule (1) of Rule 30 relates to the applications for refund of an octroi. Sub-rule (2) of Rule 30 empowers a municipal officer not below the rank of an Octroi Inspector to issue a requisition to any importer to produce before him the relevant statements, registers and documents relating to the octroi paid or to be paid and other matters connected therewith. Sub-rule (2) however provides that no such requisition shall be made after the expiry of the period of one year from the date of making any declaration or to the date of demand of octroi. The power of a municipal corporation and its officers to demand inspection of the books can be exercised within a period of one year from the date of import. In other words, no inspection can be demanded of a period earlier than the period of one year prior to the date of issuing of a notice or requisition. By a notice dated 22 September 2010, submitted Mr. Tulzapurkar, the Respondent could not have demanded inspection of records of the period not earlier than 22 September 2009. However by the notice dated 22 September 2010, the Respondent municipal corporation demanded inspection for a period from 20 September 2009 to 20 September 2010 i.e for a period which was beyond the period of one year prior to the date of the requisition/notice. This was clearly without jurisdiction and contrary to the provisions of Rule 30 of the Octroi Rules. It is true that the requisition for inspection was of two days in excess of the maximum permissible period of 1 year. It was however contended, and in my view rightly, before me by the learned Counsel for the Respondent that the period of two days should be ignored and notice should be held to be valid only in respect of the inspection carried out of the register between 22 September 2009 and 20 September 2010. So construed the notice was not illegal.
17. Mr. Tulzapurkar also invited my attention to Rule 16 of the Octroi Rules which reads thus:
16. Provisions to determine value-Where octroi is leviable ad-valorem (a) if the original invoice is produced by the importer and accepted by the Octroi Officer, the value of the goods means the value made up of the cost price of the goods as ascertained from that invoice plus freight charges carrier chargers, shipping dues, insurance, excise duties, sales tax, vend fee countervailing duty and all other incidental charges incurred by the importer till the arrival of the goods within the octroi limits and
b) Where the value as at (a) above is not ascertainable on account of non-availability or no-production of the original invoice at the time of import or when the genuineness of the invoice produced is in doubt, it shall mean wholesale cash price as determined by the Octroi Officer at the Octori Naka having regard to the value of articles fixed by the Commissioner on the basis of which the articles of like kind or quality are sold or are capable of being sold at the time and place of import, without any abatement or deduction whatsoever except of the amount of octroi payable on importation thereof.
18. He submitted that under Clause (a), while determining the value of the goods imported only the freight charges, carrier charges, shipping dues, insurance, excise dues, sales tax, vend fee, countervailing duty and charges incidental to the import incurred by importer can be added to the invoice value. The profit which the import would make on re-sale of the goods within the octroi limits cannot be added in determining the value of the goods. Inclusion of the profit on re-sale made by the importer in determining the value of the goods for the purpose of levy of octroi is contrary to Rule 16 and therefore, the addition of such profit was ultra virus Rule 16. It is true that ordinarily a profit made or to be made by a trader on re-sale of the goods cannot be taken into consideration while determining the value of the goods for the purpose of an octroi. However, the case of the Appellant that the entire amount of making charges is the profit of the Appellant cannot be accepted. When any manufacturing processes is applied to a raw material, or to any intermediate goods which are converted into another marketable commodity certain value addition takes place. There is always a difference between the price of the raw material or the intermediate goods and the price of the final marketable product but the entire price difference is not necessarily the profit of the manufacturer/seller. The manufacturer who converts the raw material or intermediate goods into a marketable commodity incurs some expenditure in applying any manufacturing process for such conversion. The entire difference between the price of the final product and the intermediate product does not represent the profit but the difference minus the expenditure incurred by the manufacturer of goods for the conversion is the profit. Applying the aforesaid principle to the present case, the difference between the price of an ornament made of a gold (with or without jewels and precious/semi precious stones) and the price of actual gold (and jewels and precious/semiprecious stones) used for making of the ornament is not the profit earned by the Appellant. The Appellant is required to employ skilled artisans for converting gold into gold ornaments. Certain amount of energy in the form of heating and/or for operation of tools is also be required to be used for the purpose of conversion of gold into gold ornaments. There could also be host of other expenses like rent paid or to be paid for the premises where the operation of making ornaments is performed. The expenditure incurred by the Appellant in payment of salary of the artisans, energy consumed for such conversion, the rent paid or payable for use of the premises where such conversion take place and several other expenses which may be incurred for the purpose of conversion of gold into gold ornaments go into the value or the manufacturing costs of the gold ornaments. It is that value which would ordinarily be regarded as the value of the goods for the purposes of levy of the octroi. Neither the price of the gold used/consumed for the manufacture of the gold ornaments nor the final sale price would be the value of the gold ornaments for the purposes of the octroi. Undoubtedly, the Respondent municipal corporation would be required to determine the assessable value/price on which the octroi can be levied in accordance with the Octroi Rules. The power to determine this value undoubtedly rests with the Respondent and its officers. It cannot be said that any decision taken by the Respondents/its officers competent to decide the value for the purpose of levy of octroi is without power or in excess of their jurisdiction. The error, if any, in determination of the assessable value for the purpose of levy of octroi would be an error within the powers or within the jurisdiction of the Respondent and its officers. Such an error can be corrected in an appeal under Section 406 of the BPMC Act. A civil suit would not be an appropriate remedy and the civil court would not have jurisdiction to decide the issue. The jurisdiction of the civil court is excluded by necessary implication by reason of a provision of an appeal against determination of an octroi (which is a tax) contained in Section 406 of the BPMC Act.
19. For these reasons, the impugned order of the Civil Judge that it had no jurisdiction to entertain and try the suit is upheld. Appeal is accordingly dismissed but in the circumstances of the case without any order as to costs.
20. Before I part, I must refer to the submission made by Mr. Tulzapurkar on the day when the matter was closed for decision after last hearing. He submitted that in the event the appeal is dismissed, interim protection which has been granted by this Court vide order dated 9 December 2010 be continued for some time to enable the Appellant to take appropriate action. It is accordingly ordered that the interim protection shall remain in force for a period of six weeks from today.
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