Custom, Excise & Service Tax Tribunal
Yes vs Represented By : Shri Willingdon ... on 13 August, 2012
CUSTOMS EXCISE & SERVICE TAX APPELLATE TRIBUNAL, West Zonal Bench, Ahmedabad COURT-II Appeal No.E/1960/10 Arising out of OIO No.22-29/DEMAND/COMMR-I/2010, dt.26.11.10 Passed by Commissioner of Central Excise & Customs, Vadodara For approval and signature : Hon'ble Mr. M.V. Ravindran, Member (Judicial) Hon'ble Mr. B.S.V. Murthy, Member (Technical) 1 Whether Press Reporter may be allowed to see the Order for publication as per Rule 27 of the CESTAT (Procedure) Rules, 1982? No 2 Whether it should be released under Rule 27 of CESTAT (Procedure) Rules, 1982 for publication in any authoritative report or not? Yes 3 Whether their Lordships wish to see the fair copy of the Order? Seen 4 Whether Order is to be circulated to the Departmental authorities? Yes Appellant (s) : M/s. GSFC Ltd. Represented by : Shri Willingdon Christian, Adv Respondent (s) : CCE Vadodara
Represented by : Shri S.K. Mall, A.R. CORAM :
Hon'ble Mr. M.V. Ravindran, Member (Judicial) Hon'ble Mr. B.S.V. Murthy, Member (Technical) Date of Hearing : 13.08.12 Date of Decision :
ORDER No. _____________ /WZB/AHD/2012 Per : Mr. B.S.V. Murthy;
The issue involved in this case is whether appellant is eligible for the cenvat credit on Low Sulphur Heavy Stock (LSHS) used as fuel in the generation of steam which was in turn used in the manufacture of exempted fertiliser.
2. Nine show cause notices were issued from time to time covering the period from September 1997 to September 2001. One of these show cause notices covering the period from September 1997 to January 1998 was decided against the appellant. On an appeal filed by the appellant, the Tribunal decided the issue in favour of the appellant. This was upheld by the Honble Supreme Court on an appeal filed by the Revenue. Thereafter the remaining show cause notices were taken up for adjudication and in the impugned order it has been held that appellant is not eligible for the cenvat credit of duty paid on LSHS used as fuel amounting to Rs.34,36,60,312/- and interest of Rs.3,13,62,988/-. No penalty was imposed. While passing the order, the ld. Commissioner did not follow the decision of the Tribunal upheld by the Honble Supreme Court in the appellants own case on the ground that in a subsequent decision, the Apex Court in the case of Gujarat Narmada Fertilisers Ltd. (GNFC) 2009 (240) ELT 661 (S.C.) has held that GNFC is not eligible for cenvat credit of duty paid on LSHS used in the manufacture of steam which was in turn used in the manufacture of fertilisers on the ground that such facility is not available in terms of provisions of Rule 6 of Cenvat Credit Rules.
3. Ld. counsel on behalf of the appellants submitted that the ratios of decisions in the case of appellant and GNFC are entirely different and can be said to be poles apart. He submits that Commissioner cannot ignore a decision in the case of the same appellant in preference to some other partys case and that too when the ratio is totally different.
3.1 The ratio decidendi consists of statement of principles of law applicable to the legal problems disclosed by the facts. He relies on the decision of the Honble Supreme Court in Dalbir Singh & Ors. Vs. State of Punjab AIR 1979 SC 1384 in support of his submission that the ratio decidendi in the case of GNFC would not be applicable to their case. He submits that the decisions in the case of GNFC and in the case of appellant were based on the arguments placed before the Honble Supreme Court and the decision in the case of GNFC cannot be disturbed unilaterally just because the GNFC case was not argued the way G.S.F.C. case was argued. Further, he would submit that the principle of res-judicata will apply and relies upon several decisions in support of his submission.
3.2 Further he also submits that the reliance of the Revenue on the decision in the case of C.K. Gangadharan Vs. Commissioner of Income Tax 2008-TIOL-140-SC-IT-LB is also not relevant since subsequently Honble Supreme Court in the case of J.K. Charitable Trust 2008 (232) ELT 769 (S.C.). took the view that if a decision has been given in the case of the appellant himself the decision will be binding in respect of the same appellant.
3.3 He also submits that according to definition of inputs, even after several amendments in the case of fuel used for generation of steam or electricity, the input definition provided that credit of duty paid on inputs used as fuel in the manufacture of final products or for any other purpose would be available. He submits that in this case the phrase for any other purpose would cover the situation in the case of the appellant. According to him this phrase signifies liberty to use electricity or steam for any purpose other than the purpose of manufacture of final products i.e. other than dutiable final products.
3.4. Ld. A.R. on the other hand submits that the decision of the Honble Supreme Court in the appellants own case cannot be binding in view of the fact that Honble Supreme Court in that case had observed that the issue has already been considered in the case of Raymond Ltd. 2000 (117) ELT 104 (Tri.) by the Tribunal in favour of the appellant and the same has been upheld by the Apex Court. The Apex Court observed that department had not filed an appeal against this decision and with this observation rejected the appeal filed by the Revenue. Therefore it can not be said that the decision was on merits.
3.5 Further, he also submits that the reliance of the appellant on the decision of the Tribunal in the case of Ballarpur Industries Ltd. 2000 (116) ELT 312 (Tri.) is also not appropriate since the Apex Court themselves observed that the issue in the case of Ballarpur Industries Ltd. was different. In the case of Ballarpur Industries Ltd. the issue dealt with was whether credit could be availed on LSHS even prior to 16.3.95 when clause (d) of Rule 57A covering inputs used as fuel for generation of steam or electricity under explanation of Rule 57A was introduced. He submits that since Apex Court simply allowed the appeal filed by the appellant on the ground that the decision of the Tribunal in the case of Raymond Ltd. on the same issue had been accepted by the Government and did not consider the merits of the case nor did it discuss the issue in detail by considering the legal principles, it cannot be binding in view of the fact that in the case of GNFC, Honble Supreme Court was examining the provisions of Rule 6(1) and Rule 6(2) of the Cenvat Credit Rules which are pari materia to the earlier rules as existed from time to time, the decision in the case of GNFC which is against the appellant should prevail. He also relies upon the decision in the case of Hira Cements 2006 (194) ELT 257 (S.C.) to submit that the issue has attained finality only as regards the period covered by the decision of the Apex Court earlier. In this case Honble Supreme Court has taken a view that if an appeal has been decided on the ground that Revenue had accepted a judgment earlier, it cannot be treated as res-judicata. In the case of BSNL 2006 (2) STR 161 (S.C.), Honble Supreme Court had taken a view that res-judicata does not apply in matters pertaining to tax for different assessment years. The Honble Supreme Court also observed that where facts and law in a subsequent assessment year are the same, no authority whether quasi judicial or judicial can generally be permitted to take a different view. However, the Apex Court observed that this mandate is subject to only to the usual getaways of distinguishing the earlier decision or where the earlier decision is per in curium. Therefore, in this case since the earlier decision of the Honble Supreme Court was on the ground that department had not filed appeal in the case of Raymond Ltd. and subsequently Honble Supreme Court had considered the issue in the case of GNFC and came to a conclusion against the appellant, the subsequent decision which according to Article 143 of Constitution is the law laid down by the Honble Supreme Court and is binding on everyone, the Commissioner has correctly followed that decision and not the earlier decision of the Apex Court in the case of GSFC.
4. As regards the input he submits that it was never the intention of the legislature to offer dual benefit and therefore restriction of the benefit of cenvat credit was imposed under Rule 57C, 57AD of Central Excise Rules, 1944 and Rule 6 of Cenvat Credit Rules. He submits that in view of the provisions which categorically provide that no credit of specified duty shall be allowed on such quantity of inputs used in the manufacture of final products which are exempt from the whole of duty, subject to exceptions as indicated therein, appellant is not eligible for the cenvat credit.
5. We have considered the submissions made by both the sides. There is no dispute that according to definition of inputs, when an input is used as fuel for generation of steam or electricity which is in turn used for manufacture of final products or for any other purpose in the factory credit is admissible. There is also no dispute that in spite of amendments of Rules from time to time during the period under consideration, the provisions have remained the same as regards disallowance of credit in certain circumstances as provided under Rule 57C. According to Rule 57C of Central Excise Rules, 1944, no credit of specified duty shall be allowed on such quantity of inputs which is used in the manufacture of final products which are exempt from the whole of duty of excise leviable thereon or chargeable to nil rate of duty except when the final products are ---- (omitted since not relevant).
6. The issue that arises is whether the definition of input as provided under Rule 57B(iv) as in existed up to 31.3.2000 and Rule 57AB of Central Excise Rules, 1944 as in existed up to 30.06.2001 according to which cenvat credit is available when the input is used as fuel or for generation of steam or electricity used for manufacture of final products or for any other purpose would prevail in spite of provisions of Rule 57C which provides credit subject to certain conditions.
7. Ld. counsel for the appellants submitted that the decision of the Apex Court upholding eligibility for credit in their own case for the period from September 1997 to January 1998 has to be treated as final and in spite of the decision to the contrary of the Apex Court in the case of GNFC (supra) cannot be considered. We proceed to examine the decision of the Apex Court in the case of appellants themselves.
8. Before we proceed, we have to consider the decision of the Tribunal in the case of Raymond Ltd. (supra) in view of the fact that Apex Court had allowed the credit for the appellant on the ground that in terms of the decision of the Tribunal in the case of Raymond Ltd. as regards the credit is applicable since department had accepted the decision of the Tribunal and had not filed an appeal.
9. Paragraph 12 of the decision of the Tribunal in the case of Raymond Ltd. is relevant and accordingly is reproduced below:
12.What then is the meaning of the term for any other purposes contained in the relevant clause in the amended rule? If the object were to limit the use of the fuel only to manufacture of finished dutiable product, these words would become unnecessary; even without them credit would be taken for that purposes. The term for any other purposes must therefore necessarily contemplate the use of the steam for the purposes other than manufacture of dutiable final product. Such use can only be for manufacture of the final product that is not dutiable or for any other purposes within the factory of production. We must remember that the term final product is defined in Rule 57A(1) as finished excisable goods. Therefore, any other purpose would necessarily mean a purpose other than production of finished excisable goods. It is therefore reasonable to conclude that the effect of amendments made to rule in May, 1995 was to permit credit of duty paid on inputs used to manufacture steam which was in turn used for manufacture of exempted or nil duty rated final product or for any other purposes.
10. An analysis of the above paragraph would show that one of the main considerations that weighed while rendering this decision was that inputs were used to manufacture steam which was in turn used for manufacture of exempted or nil duty rated final products or for any other purpose. The Tribunal took the view that the words any other purpose would necessarily mean a purpose other than production of finished excisable goods. This would show that what weighed with the Tribunal to render this decision was the fact that steam or electricity was the intermediate product and not the final product according to the decision. It was this decision which was not appealed against by the department and the Honble Supreme Court while considering the appeal filed by the appellant in their own case, identified two issues to be decided as submitted by the ld. D.R. The first issue was decided by the Tribunal-LB in the case of Ballarpur Industries Ltd. The issue involved was whether credit on steam or electricity would not be available prior to 16.03.95 the duty on which credit was specifically made available to the fuel used for generation of steam or electricity. That issue did not arise in the case of GSFC-the appellant. As regards the second issue which was whether credit is available in respect of fuel used for production of steam, the Honble Supreme Court observed as follows:
9.On the second contention raised by the Respondent, namely, that as per Rule 57B(1)(iv), the Modvat credit was available on the inputs used for generation of electricity or steam, used for manufacture of final products or for any other purpose, within the factory of production. The Tribunal decided the case in favour of the Assessee relying upon a decision of the Tribunal in the case of Raymond Ltd. v. Commissioner of Central Excise, Mumbai III, 2000 (37) RLT 447 (CEGAT), wherein it has been held that the Modvat credit would be available on inputs used to manufacture steam which was in turn used for manufacture of exempted or nil duty rated final product or for any other purpose. It is stated before us that no appeal has been preferred by the Revenue against the decision in the aforesaid case. The same has thus become final.
10. . As regards the second issue involved in the case, the Revenue has accepted the decision in the case of Raymond Ltd. (supra), as it did not file any appeal against the said decision in this Court. The second issue is already decided in favour of the Assessee. The decision rendered by the Tribunal is, thus, confirmed. The appeal is dismissed leaving the parties to bear their own costs.
11. From the above it can be seen that the Apex Court did not consider or discuss the legal provisions or facts in detail except to observe that since the Revenue had accepted the decision in the case of Raymond Ltd. that decision has to be followed and there was no need for any review.
12. It was submitted by the ld. counsel that in the decision of the Apex Court in their own case, the ratio decidendi was that modvat credit is admissible to them and he relied upon the decision of the Honble Supreme Court in the case of Dalbir Singh & Ors. Vs. State of Punjab wherein it has been explained what is the ratio of decidendi in a case. The observations of the Apex Court relevant to the present case according to the ld. counsel are contained in paragraph 22 which is reproduced below:
According to the well-settled theory of precedents every decision contains three basic ingredients:
(i) findings of material facts, direct and inferential. An inferential finding of facts is the inference which the Judge draws from the direct, or perceptible facts;
(ii) statements of the principles of law applicable to the legal problems disclosed by the facts; and
(ii) judgment based on the combined effect of (i) and (ii) above.
For the purposes of the parties themselves and their privies, ingredient No. (iii) is the material element is the decision for it determines finally their rights and liabilities in relation to the subject that estops the parties from reopening the dispute. However, for the purposes of the doctrine of precedents, ingredient No. (ii) is the vital element in the decision. This indeed is the ratio decidendi. (5) It is not everything said by a Judge when giving judgment that constitutes a precedent. The only thing in a Judges decision binding a party is the principle upon which the case is decided and for this reason it is important to analyse a decision and isolate from it the ratio decidendi. In the leading case of Qaulcast (Wolverhampton) Ltd. V. Haynes 1959 AC 743 it was laid down that the ratio decidendi may be defined as a statement of law applied to the legal problems raised by the facts as found, upon which the decision is based. The other two elements in the decision are not precedents. The judgment is not binding (except directly on the parties themselves), nor are the findings of facts. This means that even where the direct facts of an earlier case appear to be identical to those of the case before the Court, the Judge is not bound to draw the same inference as drawn in the earlier case.
13. It was observed by the Apex Court that as regards (i) findings of material facts, it is the material element in the decision and it determines the parties from reopening the dispute. The statements on the principles of law applicable to the legal problems disclosed by the facts would form the ratio decidendi according to the Apex Court.
14. The ld. A.R. on behalf of the Revenue relied upon the decision in the case of Hira Cements (supra). In the case of Hira Cements, the Commissioner had dropped proceedings by order dated 21.09.01 as regards valuation of goods and use of brand name. An appeal was filed against penalties imposed which was dismissed. In that situation, it was the claim of the Hira Cements that as regards SSI exemption and valuation, the order dated 21.09.01 attained finality since it had been accepted by the appellant. It was argued before the Apex Court that once the order dated 21.09.01 attained finality, Revenue did not have any locus standi to maintain an appeal since a finding had been arrived by the Commissioner as well as the Tribunal to the effect that it is not the (Hira Cements) who had been using the brand name of the said Hira Cements. The Apex Court made the following observations after considering the submissions made by both the sides.
Before us, the parties have placed the entire facts. We may also place on record that it has been conceded before us by the learned counsel appearing on behalf of the Respondent that the earlier order dated 26-9-2001 shall not operate as a res-judicata but, as noticed hereinbefore, the only contention raised was that once the Revenue accepts a judgment, it cannot raise the said question once again.
15. With these observations, Apex Court remanded the matter to the Tribunal to decide it afresh considering all aspects of the matter.
16. The ld. A.R. relied upon the decision of the Honble Supreme Court in the case of BSNL wherein the Apex Court observed as follows:
18.?The decisions cited have uniformly held that res judicata does not apply in matters pertaining to tax for different assessment years because res judicata applies to debar Courts from entertaining issues on the same cause of action whereas the cause of action for each assessment year is distinct. The Courts will generally adopt an earlier pronouncement of the law or a conclusion of fact unless there is a new ground urged or a material change in the factual position. The reason why Courts have held parties to the opinion expressed in a decision in one assessment year to the same opinion in a subsequent year is not because of any principle of res judicata but because of the theory of precedent or the precedential value of the earlier pronouncement. Where facts and law in a subsequent assessment year are the same, no authority whether quasi judicial or judicial can generally be permitted to take a different view. This mandate is subject only to the usual gateways of distinguishing the earlier decision or where the earlier decision is per incuriam. However, these are fetters only on a coordinate bench which, failing the possibility of availing of either of these gateways, may yet differ with the view expressed and refer the matter to a bench of superior strength or in some cases to a bench of superior jurisdiction.
19.?In our opinion, the preliminary objection raised by the State of U.P. therefore, rests on a faulty premise. The contention of the petitioners/appellants in these matters is not that the decision in State of U.P. v. U.O.I (supra) for that assessment year should be set aside, but that it should be overruled as an authority or precedent. Therefore, the decisions in Devi Lal Modi v. Sales Tax Officer (supra) and in Hurra v. Hurra (supra) are not germane.
20.?A decision can be set aside in the same lis on a prayer for review or an application for recall or Under Art. 32 in the peculiar circumstances mentioned in Hurra v. Hurra. As we have said overruling of a decision takes place in a subsequent lis where the precedential value of the decision is called in question. No one can dispute that in our judicial system it is open to a court of superior jurisdiction or strength before which a decision of a Bench of lower strength is cited as an authority, to overrule it. This overruling would not operate to upset the binding nature of the decision on the parties to an earlier lis in that lis, for whom the principle of res judicata would continue to operate. But in tax cases relating to a subsequent year involving the same issue as an earlier year, the court can differ from the view expressed if the case is distinguishable or per incuriam. The decision in State of U.P. v. Union of India related to the year 1988. Admittedly, the present dispute relates to a subsequent period. Here a coordinate Bench has referred the matter to a Larger Bench. This Bench being of superior strength, we can, if we so find, declare that the earlier decision does not represent the law. None of the decisions cited by the State of U.P. are authorities for the proposition that we cannot, in the circumstances of this case, do so. This preliminary objection of the State of U.P. is therefore rejected.
17. Relying upon the above two decisions the ld. A.R. would submit that the principle of res-judicata would not apply in this case. As regards ratio decidendi, he submits that the decision in the case of Hira Cements would support his submission. In the case of Hira Cements also the situation was similar as in the case of the appellants. In their own case the order passed by the Commissioner had been accepted by the Revenue for one period but yet the Apex Court took the view that the matter can be reopened. In this case also, the Tribunals decision in the case of Raymond Ltd. has been accepted by the Revenue and not appealed against and Apex Court decided in favour of the appellant only on the ground that the decision of the Tribunal in the case of Raymond Ltd. had become final. Therefore, he submits that there is no ratio decidendi in this case.
18. We find considerable force in the arguments advanced by the ld. A.R. As regards res-judicata, the observations of the Honble Supreme Court in the case of BSNL are squarely applicable. The department is not reopening the assessment for the period from September 1997 to January 1998 which has attained finality with the decision of the Apex Court. For subsequent period, the question that is to be considered is whether it can be said that the decision of the Apex Court can be said to have provided a ratio decidendi. Obviously as submitted by the ld. A.R. in the case of Hira Cements, the Honble Supreme Court has taken a view that if a decision has been taken and accepted it would not bar the Revenue for reopening the issue for a subsequent period. Moreover, the observations of the Honble Supreme Court in the case of BSNL and the paragraphs reproduced above are also very relevant to the issue. Just because the assessment for one period is completed, the Revenue is not barred from not following the decision relating to that period for subsequent period if there is no decision on merits or settling legal principles. In this case as can be seen from the decision of the Tribunal in the case of Raymond Ltd. and the decision of the Apex Court in the case of GSFC relying upon Raymond Ltd. reproduced above, it becomes quite clear that Apex Court did not go into the legal aspects in detail at all. Since the facts leading to the dispute and the decision given by the Tribunal were not appealed against, the Apex Court did not feel the need for going into the merits at all and on that ground the decision was given in favour of the appellant. In view of the decision in the case of BSNL and Hira Cements and also in view of the decision in the case of GNFC by the Apex Court subsequently, the department is definitely free to reopen the assessment if the view taken in GNFC case is contrary. In the GNFC, the Apex Court considered the appeals filed by four assessees and had taken the facts in the case of GNFC for coming to a conclusion. The facts in GNFC case and in the case of the present appellant are the same. The Honble Supreme Court had reproduced the relevant rules during the relevant period and had considered the submissions and thereafter came to a conclusion. The Honble Supreme Court in their findings in paragraph 9 & 10 held as under:
9.?As can be seen from the submissions, the contention of the assessee is that exclusion of fuel-inputs from the purview of sub-rule (2) of Rule 6 would mean that such inputs are also automatically excluded from sub-rule (1) whereas according to the Department sub-rule (1) is a general rule which provides, that except for the circumstances mentioned in sub-rule (2), CENVAT credit shall not be allowed on such quantity of inputs used in the manufacture of exempted goods and even though fuel-inputs are excluded from sub-rule (2), such inputs would still fall under sub-rule (1).
10.?In our view, sub-rule (1) is plenary. It restates a principle, namely, that CENVAT credit for duty paid on inputs used in the manufacture of exempted final products is not allowable. This principle is in-built in the very structure of the CENVAT scheme. Sub-rule (1), therefore, merely highlights that principle. Sub-rule (1) covers all inputs, including fuel, whereas sub-rule (2) refers to non-fuel-inputs. Sub-rule (2) covers a situation where common cenvatted inputs are used in or in relation to manufacture of dutiable final product and exempted final product but the fuel-input is excluded from that sub-rule. However, exclusion of fuel-input vis-a-vis non-fuel-input would still fall in sub-rule (1). As stated above, sub-rule (1) is plenary, hence, it cannot be said that because sub-rule (2) is inapplicable to fuel-input(s), CENVAT credit is automatically available to such inputs even if they are used in the manufacture of exempted goods. The cumulative reading of sub-rules (1) and (2) makes it abundantly clear that the circumstances specified in sub-rule (2), which inter alia requires separate accounting of inputs, are not applicable to the fuel-input(s). However, the said sub-rule (2) nowhere says that the legal effect of sub-rule (1) will stand terminated in respect of fuel-inputs which do not fall in sub-rule (2). In other words, the legal effect of sub-rule (1) has to be applied to all inputs including fuel-inputs, only exception being non-fuel-inputs, for which one has to maintain separate accounts or in its absence pay 8% /10% of the total price of the exempted final products. Therefore, sub-rule (1) shall apply in respect of goods used as fuel and on such application, the credit will not be permissible on such quantity of fuel which is used in the manufacture of exempted goods. In our view, the above aspect has not been properly appreciated by the Gujarat High Court in the above case of M/s. Gujarat Narmada Valley reported in 2006 (193) E.L.T. 136 (supra).
19. We have already observed that the Tribunal while considering the issue in Raymond Ltd. had taken the view that in view of the fact that fuel was used for generation of steam or electricity and these are not final products but intermediate products, the restrictions are not applicable and they are covered by the phrase for any other purpose. The Honble Supreme Court has taken the view that if the fuel is used for the manufacture of non dutiable final product, credit is not eligible. It may be seen that the Tribunal had not considered the provisions of Rule 6 and had also not considered the fact that Rule 6(1) is the plenary rule. Since in the case of GNFC, the Honble Supreme Court settled principles of law applicable to the legal problems disclosed by the facts, it leads to a clear ratio decidendi as observed in the case of Dalbir Singh & Ors (supra). Therefore the decision in the case of GNFC has to be applied to the facts of this case.
20. At this stage, we also have to take note of another submission of the ld. A.R. According to him, all the quasi judicial and judicial authorities and executive are bound by the law laid down by the Honble Supreme Court as per the Article 143 of the Constitution. The decision of the Apex Court in the GNFC was rendered on 17.08.09 whereas the decision in the case of GSFC was rendered on 16.07.08. Not only the decision of the Apex Court in GNFC was subsequent to the decision in the case of GSFC but also in the case of GNFC, Apex Court had considered the relevant provisions of the law, applied them to the facts which are similar to the case of GSFC and came to the conclusion and therefore the ratio decidendi in that case would be definitely applicable to the present case.
21. In fact the ld. counsel had also relied upon the decision in the case of Geep Industrial Syndicate Ltd. 1997 (90) ELT 271 (S.C.) to support his submission that a decision in the case of the appellant has to be preferred to a decision in the case of another assessee. We feel that in view of the discussion above, where we have analysed the facts and circumstances and the legal provisions, the decision is not applicable to the facts of this case. Therefore, we do not consider it necessary to deal with this issue.
22. In view of the above discussion, we find no merit in the appeal and reject the same.
(Operative portion pronounced in the Court on _________________)
(M.V. Ravindran) (B.S.V. Murthy)
Member (Judicial) Member (Technical)
.JK
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