ITO, Ward - 45(2), Kolkata, Kolkata v. M/s. Satyanarayan Shiwratan, Kolkata

ITA 551/KOL/2010 | 2006-2007
Pronouncement Date: 09-03-2011

Appeal Details

RSA Number 55123514 RSA 2010
Assessee PAN AAKFS3828E
Bench Kolkata
Appeal Number ITA 551/KOL/2010
Duration Of Justice 11 month(s) 23 day(s)
Appellant ITO, Ward - 45(2), Kolkata, Kolkata
Respondent M/s. Satyanarayan Shiwratan, Kolkata
Appeal Type Income Tax Appeal
Pronouncement Date 09-03-2011
Appeal Filed By Department
Bench Allotted C
Tribunal Order Date 09-03-2011
Assessment Year 2006-2007
Appeal Filed On 17-03-2010
Judgment Text
IN THE INCOME TAX APPELLATE TRIBUNAL C BENCH : KOLKATA () BEFORE /AND . ! . '# ) [BEFORE HONBLE SRI MAHAVIR SINGH JM & HONBLE SRI C. D. RAO AM] $ $ $ $ / I.T.A NO. 551/KOL/2010 %& '( %& '( %& '( %& '(/ // / ASSESSMENT YEAR : 2006-07 INCOME-TAX OFFICER WD-45(2) KOLKATA VS M/S. SATY ANARAYAN SHIWRATAN (PA NO.AAKFS 3828 E) ( *+ /APPELLANT ) ( -*+/ RESPONDENT ) FOR THE APPELLANT: SRI A. K. PRAMANIK FOR THE RESPONDENT: SRI J. M. THARD '. / ORDER PER MAHAVIR SINGH JM ( ) THIS APPEAL FILED BY REVENUE IS ARISING OUT OF THE ORDER OF CIT(A)-XXX KOLKATA IN APPEAL NO.164/CIT(A)-XXX/WARD-45(2)/2008-09 VIDE ORDER DATED 04.01.2010. THE ASSESSMENT WAS FRAMED BY ITO WD-45(2) KOLKATA U/S . 143(3)(II) OF THE INCOME TAX ACT 1961 (HEREINAFTER REFERRED TO AS THE ACT) FO R ASSESSMENT YEAR 2006-07 VIDE ORDER DATED 12.12.2008. 2. THE FIRST ISSUE IN THIS APPEAL OF REVENUE IS AGA INST THE ORDER OF CIT(A) DELETING THE DISALLOWANCE MADE BY THE ASSESSING OFFICER BY I NVOKING THE PROVISIONS OF SECTION 40(A)(IA) OF THE ACT. FOR THIS THE REVENUE HAS RA ISED THE FOLLOWING GROUND NO. 1: 1. THAT THE LD. CIT(A) ERRED IN DELETING THE ADDITI ON OF RS.48 838/- ON ACCOUNT OF DISALLOWANCE U/S. 40(A)(IA). 3. WE HAVE HEARD RIVAL CONTENTIONS AND GONE THROUGH FACTS AND CIRCUMSTANCES OF THE CASE. WE FIND THAT THE ASSESSING OFFICER HAS MADE DISALLOWANCE FOR SHORT DEDUCTION OF TAX BY INVOKING THE PROVISIONS OF SECTION 40(A)(IA) OF THE ACT FOR AN AMOUNT OF RS.2 77 989/- IN THE ABSENCE OF DETAILS FILED BEFOR E THE ASSESSING OFFICER OR IN THE 2 ABSENCE OF NON-DEDUCTION OF TDS. THE CIT(A) DELETE D THE ADDITION OF RS.48 383/- AND SUSTAINED THE BALANCE ADDITION OF RS.2 29 151/- BY STATING THAT THE ASSESSEE HAS PRODUCED EVIDENCE OF TAX DEDUCTED FROM THE PAYMENTS MADE TO JAGRUTI TEXTILE PRINTERS AND PLACED BEFORE HIM AND ACCORDINGLY HE DELETED THE ADDITION. WE FIND FROM THE RECORDS THAT REVENUE COULD NOT CONTEND BEFORE US THAT THE TDS IS NOT DEDUCTED ON THE ABOVE PAYMENT OF RS.48 838/- AND THE ASSESSEE HAS NOT SUBMITTED T HE EVIDENCE BEFORE CIT(A). WE FIND THAT CIT(A) AFTER VERIFYING THE EVIDENCE HAS ALLOWE D THE CLAIM OF THE ASSESSEE. AND IT IS NOT THE CASE OF REVENUE THAT THE EXPENDITURE IS BOG US OR NON GENUINE. HENCE THERE IS NO REASON TO INTERFERE WITH THE ORDER OF THE CIT(A) AS HE AFTER VERIFYING TDS CERTIFICATES ALLOWED THE CLAIM OF THE ASSESSEE. ACCORDINGLY WE CONFIRM THE ORDER OF THE CIT(A) AND THIS ISSUE OF THE REVENUES APPEAL IS DISMISSED. 4. THE SECOND ISSUE IN THIS APPEAL OF THE REVENUE I S AGAINST THE ORDER OF THE CIT(A) DELETING THE ADDITION MADE BY THE ASSESSING OFFICER ON ACCOUNT OF UNSECURED LOAN AND CONSEQUENTIAL INTEREST THEREON. THE ASSESSING OFFIC ER MADE ADDITION U/S. 68 OF THE ACT IN RESPECT OF UNSECURED LOAN RECEIVED BY ASSESSEE FROM SMT. GYATRI DEVI CHOWDHURY FOR RS. 2 LACS AND ARUN KUMAR CHOWDHURY HUF FOR RS.3 LA CS AND CONSEQUENTIAL INTEREST THEREON. FOR THIS THE REVENUE HAS RAISED THE FOLLO WING GROUND NO 2: THAT THE LD. CIT(A) ERRED IN DELETING THE ADDITION OF RS.2 00 000/- + 22 767/- + 3 00 000/- + 34 151/- ON ACCOUNT OF UNSECURED LOAN & INTEREST. 5. WE HAVE HEARD RIVAL CONTENTIONS AND GONE THROUGH FACTS AND CIRCUMSTANCES OF THE CASE. BEFORE THE ASSESSING OFFICER THERE WERE TWO C ASH CREDITS I.E. SMT. GAYATRI DEVI CHOWDHURY AND SRI ARUN KUMAR CHOWDHURY HUF AND ASS ESSEE COULD NOT PRODUCE LOAN CREDITORS AND THE SUPPORTING EVIDENCE. THE ASSESSIN G OFFICER MADE THE ADDITION BY TREATING THE SAME AS UNEXPLAINED CASH CREDITS AND C ONSEQUENTIAL INTEREST WAS ALSO DISALLOWED. AGGRIEVED ASSESSEE PREFERRED APPEAL B EFORE CIT(A). THE CIT(A) DELETED ADDITIONS BY GIVING FOLLOWING FINDINGS: THE APPELLANT CLAIMED TO HAVE RAISED LOAN OF RS. 2 LAKH FROM SMT. GAYETRI DEVI CHOWDHURY. THE APPELLANT FURNISHED DETAILS B EFORE THE A.O REGARDING THE CREDIT. THE APPELLANT FURNISHED THE CONFIRMATION L ETTER GIVEN BY THE CREDITOR 3 TO THE A.O. COPIES OF PROFIT AND LOSS ACCOUNT BAL ANCE SHEET AND COMPUTATION OF INCOME FOR THE ASSESSMENT YEAR 2005-06 AND 06-07 A RE FURNISHED. THE APPELLANT ALSO FURNISHED COPY OF PAN AND CONFIRMAT ION OF ACCOUNT. THE COPIES OF ACKNOWLEDGEMENT FOR FILING RETURN OF INCOME ARE AL SO FURNISHED. A COPY OF THE AFFIDAVIT EXECUTED BY SMT. GAYETRI DEVI CHOWDHURY IS ALSO FURNISHED. THE EVIDENCE PRESENTED BY THE APPELLANT CLEARLY INDICA TES THAT CREDITOR IS AN INCOME TAX ASSESSEE AND HER IDENTITY IS ESTABLISHED. THE PROFIT AND LOSS ACCOUNT FOR ASSESSMENT YEAR 2006-07 INDICATES THAT THE CREDITO RS HAS INCOME OF RS. 85 973/-. THE CAPITAL ACCOUNT OF THE CREDITOR DISCLOSED BALA NCE OF RS. 5 44 750/-. THE BALANCE SHEET ALSO DISCLOSED CASH IN HAND OF RS. 1 07 695/-. THE FINANCIAL DETAILS CLEARLY INDICATE THE CREDITORS CREDITWORTHINESS. I N VIEW OF THE EVIDENCE PRESENTED BY THE APPELLANT THE GENUINENESS OF THE TRANSACTION IS NOT DOUBTFUL. THE A.O IS DIRECTED TO DELETE THE ADDITION OF RS. 2 LAKH AND ALSO THE DISALLOWANCE OF INTEREST OF RS. 22 767/-. THE APPELLANT CLAIMED TO HAVE RAISED LOAN OF RS. 3 LAKH FROM ARUN KUMAR CHOWDHURY HUF. THE APPELLANT FURNISHED COPIES OF PROFIT AND LOSS ACCOUNT BALANCE SHEET FOR THE ASSESSMENT YEAR 200 5-06 AND 2006-07OF THE CREDITOR. THE APPELLANT FURNISHED COPIES OF CONFI RMATION OF LOAN AND THE BANK ACCOUNT. THE APPELLANT ALSO FURNISHED COPIES OF AC KNOWLEDGEMENT FOR FILING RETURN OF INCOME BY THE CREDITOR AND THE AFFIDAVIT EXECUTED BY THE CREDITOR. IT IS SEEN FROM THE DETAILS OF THE ASSESSMENT YEAR 2006- 07 THAT CREDITOR HAS INCOME OF RS. 69 491/-. THE CREDIT BALANCE OF THE CAPITAL AC COUNT IS RS. 341 013/-. THE BALANCE SHEET ALSO DISCLOSES LOAN GIVEN TO THE AP PELLANT. FROM THE FINANCE DETAILS PRESENTED BY THE APPELLANT CREDITWORTHIN ESS OF THE CREDITOR IS ESTABLISHED. THE ACKNOWLEDGEMENT FILED FOR TILING RETURN OF INCOME PROVES THE IDENTITY OF THE CREDITOR. IN VIEW OF THE EVIDENCE PRESENTED THE GENUINENESS OF THE TRANSACTION CANNOT BE DOUBTED. THE A.O IS DIRECTED TO DELETE THE ADDITION OF RS. 3 LAKH AND ALSO THE INTEREST RELATING TO THE L OAN OF RS 34 151/-. 6. WE FIND THAT THE ASSESSEE FOR THE FIRST TIME HAS PRODUCED THESE EVIDENCE BEFORE THE ASSESSING OFFICER I.E. THE CONFIRMATION PAN OF THE CREDITORS AND NOW BEFORE US THEY HAVE PRODUCED COPIES OF BANK ACCOUNT IN RESPECT OF ARUN CHOWDHURY HUF WHERE CASH WAS DEPOSITED ON 27.6.2005 IN ITS BANK ACCOUNT AMOU NTING TO RS.3 LACS AND IN CASE OF MRS. GAYATRI DEVI CHOWDHURY CASH WAS DEPOSITED ON 2 7.6.2005 AMOUNTING TO RS. 2 LACS AND ON THE VERY SAME DAY CHEQUES WERE ISSUED IN FAV OUR OF THE ASSESSEE. THESE CHEQUES WERE ENCASHED IN THE BANK ACCOUNT OF THE ASSESSEE O N 29.6.2005. IT IS NOT CLEAR FROM THE RECORDS THAT WHAT IS THE SOURCE OF CASH DEPOSITS IN THE BANK ACCOUNTS OF BOTH THE CREDITORS AND THE ASSESSEE IS UNABLE TO PRODUCE THE CREDITORS BEFORE THE AO DESPITE ISSUANCE OF SUMMONS U/S. 131 OF THE ACT. SINCE THE ASSESSEE HAS PRODUCED THESE DOCUMENTS EITHER BEFORE THE CIT(A) OR NOW BEFORE US WE AFTER ADMITTING THESE EVIDENCE SET ASIDE THIS ISSUE TO THE FILE OF THE A SSESSING OFFICER TO RE-DECIDE THIS ISSUE IN 4 ACCORDANCE WITH LAW. ACCORDINGLY THIS ISSUE OF TH E REVENUES APPEAL IS SET ASIDE TO THE FILE OF THE ASSESSING OFFICER AND ALLOWED FOR STATI STICAL PURPOSES. 7. THE NEXT ISSUE IN THIS APPEAL OF THE REVENUE IS AGAINST THE ORDER OF CIT(A) DELETING THE ADDITION OF KEYMAN INSURANCE POLICY. FOR THIS THE REVENUE HAS RAISED THE FOLLOWING GROUND NO. 3 : 3. THAT THE LD. CIT(A) ERRED IN DELETING THE ADDITI ON OF RS.1 99 234/- ON ACCOUNT OF INSURANCE PREMIUM. 8. WE HAVE HEARD RIVAL CONTENTIONS AND GONE THROUGH FACTS AND CIRCUMSTANCES OF THE CASE. THE ASSESSING OFFICER MADE DISALLOWANCE OF I NSURANCE PREMIUM BY STATING THAT THE INSURANCE PREMIUM PAID IS IN THE NAME OF ASHOK KUMAR JHUNJHUNWALA AND IT IS NOT UNDER KEYMAN INSURANCE POLICY FALLING UNDER KEYMAN INSURANCE SCHEME. THE CIT(A) ALLOWED THE CLAIM OF THE ASSESSEE BY TAKING INTO CO NSIDERATION LETTER ISSUED BY LIC DATED 27.12.2008 WHEREIN IT IS STATED BY LIC THAT THIS P OLICY WAS TAKEN UNDER KEYMAN INSURANCE SCHEME. WE FIND THAT NEITHER THE ASSESSI NG OFFICER NOR THE CIT(A) HAS GONE INTO THE PROVISIONS OF SECTION 36(1)(IB) OF THE ACT AS APPLICABLE TO THE ASSESSEE FOR THE ASSESSMENT YEAR 2006-07 WHETHER THE POLICY IS TAKE N AS PER THE RELEVANT PROVISION OR NOT. LET THE ASSESSING OFFICER EXAMINE THE ISSUE I N THE LIGHT OF THE PROVISIONS OF SECTION 36(1)(IB) OF THE ACT AND DECIDE ACCORDINGLY. THIS ISSUE OF THE REVENUES APPEAL IS SET ASIDE TO THE FILE OF THE ASSESSING OFFICER AND ALLO WED FOR STATISTICAL PURPOSES. 9. THE NEXT ISSUE IN THIS APPEAL OF THE REVENUE IS AGAINST THE ORDER OF THE CIT(A) DELETING THE ADDITION OF RS.52 400/- MADE BY THE AS SESSING OFFICER ON ACCOUNT OF ACCRUED INTEREST ON FDR. FOR THIS THE REVENUE HAS RAISED THE FOLLOWING GROUND NO 4: 4. THAT THE LD. CIT(A) ERRED IN DELETING THE ADDITI ON OF RS.52 400/- ON ACCOUNT OF INTEREST ON F.D. . 10. WE HAVE HEARD RIVAL CONTENTIONS AND GONE THROUG H FACTS AND CIRCUMSTANCES OF THE CASE. WE FIND THAT THE ASSESSING OFFICER HAS MADE ADDITION ON THE PREMISE THAT THE ASSESSEE HAS NOT DECLARED ANY ACCRUED INTEREST AND ACCORDINGLY HE COMPUTED 10% 5 INTEREST ON FDR MAINTAINED WITH CENTRAL BANK OF IND IA BY ASSESSEE FOR AN AMOUNT OF RS.5.24 LACS. AGGRIEVED AGAINST THE ADDITION OF AC CRUED INTEREST ASSESSEE PREFERRED APPEAL BEFORE THE CIT(A) WHO DELETED THE ADDITION BY NOTING THAT THE ASSESSEE HAS ALREADY DISCLOSED ACCRUED INTEREST ON THIS FDR IN I TS ACCOUNT OF RS.24 000/-. AGGRIEVED REVENUE CAME IN APPEAL BEFORE US. 11. WE FIND THAT THE ASSESSEE BEFORE THE ASSESSING OFFICER AS WELL AS BEFORE THE CIT(A) FILED DETAIL EVEN NOW WHICH IS AVAILABLE WI TH US AT ASSESSEES PAPER BOOK PAGES 31 AND 32 WHEREBY INTEREST @ 6% IS CREDITED IN ITS BOOKS OF ACCOUNT OF THE ASSESSEE AT RS.24 000/-. WE FIND NO INFIRMITY IN THE ORDER OF THE CIT(A) DELETING THIS ADDITION IN VIEW OF EVIDENCES AVAILABLE BEFORE HIM. ACCORDINGL Y THIS ISSUE OF THE REVENUES APPEAL IS DISMISSED. 12. THE NEXT ISSUE IN THIS APPEAL OF THE REVENUE IS AGAINST THE ORDER OF CIT(A) DELETING THE DISALLOWANCE MADE BY THE ASSESSING OFF ICER U/S. 40A(3) OF THE ACT. FOR THIS THE REVENUE HAS RAISED THE FOLLOWING GROUND N O 5: 5. THAT THE LD. CIT(A) ERRED IN DELETING THE ADDITI ON OF RS.3 36 651/- ON ACCOUNT OF DISALLOWANCE U/S. 40A(3). 13. THE BRIEF FACTS LEADING TO THE ABOVE ISSUE ARE THAT THE ASSESSEE IS IN THE BUSINESS OF SALE AND PURCHASE OF SAREES I.E. TRADING IN SARE ES. DURING THE COURSE OF ASSESSMENT PROCEEDINGS THE ASSESSING OFFICER NOTED FROM THE C OPIES OF LEDGER ACCOUNT THAT THE ASSESSEE HAD MADE PAYMENTS IN EXCESS OF RS.20 000/- IN CASH IN RESPECT OF EIGHT PARTIES ON VARIOUS DATES. HE NARRATED THE TOTAL PAYMENTS I .E. IN THE NAME OF MEHUL PRINTS JETPUR RS.3 95 000/- JAY HANUMAN PROCESSOR JETPUR RS.1 0 4 000/- JAY RADHEN PRINT JETPUR RS.1 25 000/- RAHUL CORPORATION JETPUR RS.60 000/- MOHD. USMAN & COMPANY MOUNATH B. RS.2 34 256/- GOPINATH TEXTILE SURAT R S.30 000/- ARUNA SAREE CENTRE MOUNATH BHANJAN RS.3 45 000/- AND ZIAUR RAHMAN MAT IUR RAHMAN MAU RS.3 90 000/- ACCORDINGLY HE MADE DISALLOWANCE TO THE EXTENT OF 20% AT RS.3 36 651/- AND ADDED BACK TO THE TOTAL INCOME OF THE ASSESSEE. AGGRIEVE D ASSESSEE PREFERRED APPEAL BEFORE 6 THE CIT(A) AND HE DELETED THE ADDITION BY NOTING TH AT THESE PAYMENTS ARE BY DEMAND DRAFTS PURCHASED FROM THE BANK AND FOR THIS HE GAV E FOLLOWING FINDINGS: THE APPELLANT OBTAINED DEMAND DRAFTS FROM THE DEBTO RS IN THE NAME OF THE CREDITORS OF THE APPELLANT. THIS DEMAND DRAFTS RE CEIVED FROM THE DEBTORS ARE ENTERED IN THE LEDGER ACCOUNTS OF THE DEBTORS. TH E DDS ARE POSTED IN THE CREDITORS ACCOUNTS FOR ADJUSTMENT AGAINST PAYMENTS REQUIRED TO BE MADE BY THE APPELLANT. THE RELEVANT ENTRIES IN THE CASH BOOK AND THE LEDGERS ARE PROPERLY REFLECTED. THE PRACTICE OF OBTAINING DRAFTS IN FA VOUR OF THE APPELLANTS CREDITORS FROM THE DEBTORS IS NOT A NORMAL BUSINESS PRACTICE . HOWEVER THE FACT REMAINS THAT THE APPELLANT HAS OBTAINED SUCH DDS WHICH AR E UTILIZED FOR MAKING PAYMENT TO THE CREDITORS. THE PROVISIONS OF SEC. 40A(3) AR E APPLICABLE WHEN CASH PAYMENTS ARE MADE IN THE INSTANT CASE THE APPELLANT HAS MA DE PAYMENT BY THE DD AND HENCE PROVISIONS OF SEC. PROVISIONS OF SEC. 40A(3) HAVE NO APPLICATION TO DDS RECEIVED FROM THE DEBTORS AND GIVEN TO THE CREDITO RS ARE PROPERLY REFLECTED IN INDIVIDUAL LEDGER ACCOUNTS OF THE DEBTORS AND CRED ITORS. SINCE CASH PAYMENTS ARE NOT MADE THE APPELLANT DISALLOWANCE U/S. 40A(3) I S NO CORRECT. THE A.O. IS DIRECTED TO DELETE ADDITION OF RS.3 36 651/-. AGGRIEVED NOW THE REVENUE IS IN APPEAL BEFORE US. 14. WE HAVE HEARD RIVAL CONTENTIONS AND GONE THROUG H FACTS AND CIRCUMSTANCES OF THE CASE. THE ASSESSEE NOW BEFORE US HAS FILED COMPREH ENSIVE DETAILS IN ITS PAPER BOOK AT PAGES 33 TO 55 I.E. STATEMENT OF PAYMENTS MADE TO C REDITORS ALONG WITH DD NOS. AND NAME OF ISSUING BANK. IT WAS STATED BY THE ASSESSE E THAT THIS WAS EXPLAINED TO THE ASSESSING OFFICER I.E. MODE OF PAYMENT TO CREDITORS . THE ASSESSEE HAS CONFIRMED THIS FACT BY FILING CERTIFICATE ISSUED BY BANKERS CONFIR MING THE RECEIPTS BY ACCOUNT PAYEE CHEQUES/DDS. EVEN THE CERTIFICATES WERE ISSUED BY THE CREDITORS WHICH ARE IN THE ASSESSEES PAPER BOOK AT PAGES 33 AND 34 AND COMPL ETE RECONCILIATION IS ALSO SUBMITTED WHICH PROVES THAT THE PAYMENTS AS PER REVISED LEDGE R STATEMENT IS BY WAY OF ACCOUNT PAYEE DRAFTS OR CHEQUES TO THE CREDITORS. THE ASSE SSEE HAS IDENTIFIED AT LEAST 20 ENTRIES OUT OF 55 AND DEMONSTRATED BEFORE US ON TEST CHECK BASIS THAT THERE IS NO CASH PAYMENT IN THESE CASES. ONCE IT IS ESTABLISHED THAT THERE IS NO CASH PAYMENT TO THE CREDITORS AND IT IS A MERE CARELESSNESS ON THE PART OF THE ASSESSEE TO FILE INCOMPLETE INFORMATION BEFORE THE ASSESSING OFFICER WHEREBY HE PRESUMED THAT THE SE PAYMENTS ARE IN CASH CANNOT BE MADE THE BASIS FOR SUSTAINING THE ADDITION. ACCORDI NGLY WE ARE OF THE VIEW THAT THE PAYMENTS ARE MADE BY ACCOUNT PAYEE DDS OR ACCOUNT P AYEE CHEQUES AS REFLECTED IN 7 ASSESSEES PAPER BOOK AT PAGES 33 AND 34 WHEREBY T HE ASSESSEE HAS FILED RECONCILIATION OF EACH AND EVERY ENTRY AND ACCORDINGLY WE CONFIRM THE DELETION OF DISALLOWANCE BY CIT(A) AND THIS ISSUE OF THE REVENUES APPEAL IS DI SMISSED. 15. IN THE RESULT THE REVENUES APPEAL IS PARTLY A LLOWED FOR STATISTICAL PURPOSES. 16. ORDER IS PRONOUNCED IN THE OPEN COURT ON 9 TH MARCH 2011. SD/- SD/- . ! . '# (C. D. RAO) (MAHAVIR SINGH) ACCOUNTANT MEMBER JUDICIAL MEMBER ( !# !# !# !#) )) ) DATED 9 TH DAY OF MARCH 2011 /0 %12 3 JD.(SR.P.S.) '. 4 5 6'5'7- COPY OF THE ORDER FORWARDED TO: 1 . *+ / APPELLANT ITO WARD-45(2) KOLKATA. 2 -*+ / RESPONDENT M/S. SATYANARAYAN SHIWRATAN 17 PAGE YA PATTY STREET 3 RD FLOOR KOLKATA-7.. 3 . .% / THE CIT(A) KOLKATA 4. .% ( )/ CIT KOLKATA. 5 . >? % / DR KOLKATA BENCHES KOLKATA -5 / TRUE COPY '.%@/ BY ORDER 2 /ASSTT. REGISTRAR .