Control Techniques India Private Limited, CHENNAI V. DCIT Corporate Circle 1(2), CHENNAI

ITA 2095/CHNY/2017

• Counselvise Citation: [2021] 108 COUNSELVISE.COM (IT) 6647 (ITAT-CHENNAI)
• Duration Of Justice: 3 year(s) 7 month(s) 15 day(s)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 12-04-2021
• Appeal Filed By: Assessee
• Order Result: Allowed
• Bench Allotted: D
• Next Hearing Date: 17-03-2021
• Assessment Year: 2013-2014
• Appeal Filed On: 28-08-2017
• Result in Favour of: Assessee
• Court: TRIBUNAL
• Department Lawyers: G SRINIVASA RAO; MRS R ANITA
• Assessee Lawyers: ASHIK SHA
• Keywords: Transfer pricing; International transaction; Set aside
• Section: 92

Judgement Text

./ ITA NO.2095/CHNY/2017 /ASSESSMENT YEAR: 2013-14 M/S.CONTROL TECHNIQUES INDIA- PVT. LTD., 117-B, DEVELOPED PLOT, INDUSTRIAL ESTATE, PERUNGUDI, CHENNAI-96. V S. THE DY. COMMISSIONER OF INCOME TAX, CORPORATE CIRCLE-1(2), CHENNAI. [PAN: AAACC 1343 B ] ( /APPELLANT) ( /RESPONDENT) / APPELLANT BY : MR.ASHIK SHA, CA /RESPONDENT BY : MR.G. SRINIVASA RAO, CIT & MRS. R. ANITA, JCIT /DATE OF HEARING : 17.03.2021 /DATE OF PRONOUNCEMENT : 12.04.2021 / O R D E R PER G. MANJUNATHA, ACCOUNTANT MEMBER: THIS APPEAL FILED BY THE ASSESSEE IS DIRECTED AGAI NST THE FINAL ASSESSMENT ORDER PASSED BY THE ASSESSING OFFICER U/ S.143(3) R.W.S.144C(13) OF THE INCOME TAX ACT, 1961 (IN SHOR T ACT') DATED 30.06.2017, IN TURN WHICH WAS PASSED IN PURSUANT TO THE DIRECTIONS OF THE DISPUTE RESOLUTION PANEL-2, BANGALORE, ISSUED U/S.1 44C(5) OF THE IT ACT, 1961, AND PERTAINS TO THE ASSESSMENT YEAR 2013-14. , , IN THE INCOME TAX APPELLATE TRIBUNAL D BENCH: CHENNAI . , . , , BEFORE SHRI V. DURGA RAO, JUDICIAL MEMBER AND SHRI G. MANJUNATHA, ACCOUNTANT MEMBER ITA NO.2095/CHNY/2017 :: 2 :: 2. THE ASSESSEE HAS RAISED THE FOLLOWING GROUNDS OF APPEAL: THE GROUNDS MENTIONED HEREIN ARE WITHOUT PREJUDICE TO ONE ANOTHER. 1. THE ORDERS OF THE LEARNED ASSESSING OFFICER (H EREINAFTER REFERRED TO AS 'LD, AO'), THE TRANSFER PRICING OFFICER (HEREINAFTER REFERRED TO AS 'LD. TPO') AND THE HONOURABLE DISPUTE RESOLUTION PANEL (HEREINAFTER RE FERRED TO AS 'LD. DRP') ARE CONTRARY TO THE LAW, FACTS AND CIRCUMSTANCES OF THE CASE AND IN ANY CASE, HAVE BEEN MADE IN VIOLATION OF THE PRINCIPLES OF EQUITY AND N ATURAL JUSTICE, 2. THE ID. TPO, THE ID. AO AND THE ID, DRP HAVE E RRED IN CONCLUDING THE ARM'S LENGTH PRICE OF THE INTRA-GROUP SERVICES RECEIVED R ELATING TO MIS, VICE PRESIDENT EXECUTIVE, FINANCE, STRATEGIC PROCUREMENT, ETC, (HE REINAFTER REFERRED TO AS 'MANAGEMENT SERVICES') AS NIL AS AGAINST INR 1,51,7 9,164 DETERMINED BY THE APPELLANT, 3. THE ID, DRP HAS ERRED IN NOT FOLLOWING THE DIR ECTIONS OF THIS HON'BLE TRIBUNAL IN APPELLANTS OWN CASE FOR THE IMMEDIATELY PRECEDING A Y 2012-13, WHEREIN THE HON'BLE TRIBUNAL IN PRINCIPLE AGREED THAT TNMM AS T HE MOST APPROPRIATE METHOD. 4. THE ID. TPO, THE ID. AO AND THE ID. DRP HAVE E RRED IN MAKING THE ADJUSTMENT UNDER SECTION 92 OF THE ACT VIOLATING THE PROVISION S OF THE LAW AND IN EXCESS OF THEIR JURISDICTION. 5. THE ID. TPO AND THE ID. AO AND THE ID, DRP HAV E ERRED IN HOLDING THE ARM'S LENGTH VALUE OF MANAGEMENT SERVICES TO BE NIL WITHO UT FIRST ESTABLISHING ANY REASON FOR THE REJECTION OF THE APPELLANT'S TRANSFER PRICI NG DOCUMENTATION, WHEN THE SAME DOCUMENTATION AND BENCHMARKING APPROACH WHICH INCLU DED THE MANAGEMENT SERVICES AS AN OPERATING COST WAS ACCEPTED BY THEM AS REGARDS THE OTHER INTERNATIONAL TRANSACTIONS. 6. THE ID. TPO, THE LD.AO AND THE ID, DRP HAVE ER RED IN NOT ACCEPTING THE CLOSELY LINKED AND INTEGRAL NATURE OF MANAGEMENT SERVICES T O THE APPELLANT'S BUSINESS AND IN NOT CONSIDERING THE AGGREGATION APPROACH ADOPTED BY THE APPELLANT IN ITS BENCHMARKING. 7. THE ID, TPO, THE ID. AO AND THE LD.DRP HAVE ER RED IN MAKING THE ADJUSTMENT PURPORTEDLY UNDER THE CUP METHOD, WITHOUT FIRST EST ABLISHING ANY COMPARABLE UNCONTROLLED TRANSACTION TO ARRIVE AT SUCH A CONCLU SION. 8. THE ID. TPO, THE ID, AO AND THE LD. DRP HAVE E RRED IN CONCLUDING, CONTRARY TO THE FACTS OF THE CASE, THAT THE APPELLANT DID NOT R ECEIVE ANY SERVICES FROM ITS AES; THAT THE SERVICES RECEIVED WERE INCIDENTAL AND IN T HE NATURE OF STEWARDSHIP OR SHAREHOLDER SERVICES; AND THAT THE SERVICES WERE DU PLICATIVE IN NATURE, 9. THE LD. TPO AND THE ID. DRP ERRED IN NOT CONSI DERING THE INFORMATION AND DOCUMENTS SUBMITTED BY THE APPELLANT. 10. THE APPELLANT CRAVES LEAVE TO ADD, SUBSTITUTE, AMEND, DELETE, OR OTHERWISE MODIFY ANY OF THE GROUNDS OF APPEAL STATED HEREINAB OVE BEFORE COMMENCEMENT OF OR AT THE TIME OF HEARING. ITA NO.2095/CHNY/2017 :: 3 :: 3. THE BRIEF FACTS OF THE CASE ARE THAT THE ASSESSE E, M/S.CONTROL TECHNIQUES INDIA PVT. LTD., IS THE WHOLLY OWNED SUB SIDIARY OF M/S.CONTROL TECHNIQUES INDIA PVT. LTD., UK (CTL-UK). THE ASSES SEE IS ENGAGED IN THE BUSINESS OF MANUFACTURING AND SALE OF ELECTRIC DRIV ES FOR ELECTRIC MOTORS. DURING THE YEAR UNDER CONSIDERATION, THE ASSESSEE H AS REPORTED VARIOUS INTERNATIONAL TRANSACTIONS ENTERED INTO WITH ITS AS SOCIATED ENTERPRISES (IN SHORT AE') WHICH ARE TABULATED BELOW: NATURE OF INTERNATIONAL TRANSACTION AMOUNT (IN RS.) MAM PLI MARGIN OF TAXPAYER MARGIN OF COMPARABLES PURCHASE OF RAW MATERIALS, COMPONENTS, ETC. 277922366 TNMM OP/SALES 7.06% 5.16% PAYMENT OF MANAGEMENT FEES 22984500 SERVICE INCOME 733951 WARRANTY CHARGES RECEIVED 5414352 SALES 1477162 WARRANTY CHARGES PAID 134415 REIMBURSEMENT OF EXPENSES PAID 1038339 REIMBURSEMENT OF EXPENSES RECEIVED 3202737 TOTAL 312773407 4. THE ASSESSEE HAS ADOPTED TRANSACTION NET MARGIN METHOD (IN SHORT TNMM') AS MOST APPROPRIATE METHOD AND CLAIMED THAT AS A TESTED PARTY. THE ASSESSEE HAS ARRIVED PLI MARGIN OF 7.06% AND CO MPARED WITH MARGIN OF COMPARABLES WHICH WAS AT 5.16%. THE ASSESSEE HA S AGGREGATED ALL TRANSACTIONS AND BENCH MARKED UNDER TRANSACTION NOT MARGIN METHOD. DURING THE ASSESSMENT PROCEEDINGS, A REFERENCE WAS MADE TO TPO TO DETERMINE THE ALP OF INTERNATIONAL TRANSACTIONS OF THE ASSESSEE WITH ITS AE. ITA NO.2095/CHNY/2017 :: 4 :: THE TPO HAS ACCEPTED TNMM SELECTED BY THE ASSESSEE AS MOST APPROPRIATE METHOD AND HAS ACCEPTED TRANSACTIONS WITH ITS AE AR E AT ALP. HOWEVER, SUGGESTED DOWNWARD ADJUSTMENT ON ACCOUNT OF MANAGEM ENT FEES PAID TO CTL-UK FOR RS.1,57,23,722/- ON THE GROUND THAT THE ASSESSEE HAS NOT FURNISHED ANY EVIDENCES TO PROVE THAT, IN FACT, SER VICES HAVE BEEN AVAILED FROM ITS AE AND ALSO ADOPTION OF TNMM AS MOST APPRO PRIATE METHOD IS CORRECT IN THE GIVEN FACTS AND CIRCUMSTANCES OF THE CASE AND HENCE, OUT OF TOTAL EXPENDITURE BEING PAYMENT OF MANAGEMENT FEES OF RS.2,29,84,500/- HAS ALLOWED, EXPENSES RELATING TO MARKETING OF RS.7 2,60,778/- AND BALANCE AMOUNT OF RS.1,57,23,722/- HAS BEEN SUGGESTED AS DO WNWARD ADJUSTMENT TOWARDS PAYMENT ON ACCOUNT OF MANAGEMENT FEES. 5. CONSEQUENT TO THE TP ADJUSTMENT AS SUGGESTED BY THE TPO, THE AO HAS PASSED DRAFT ASSESSMENT ORDER U/S.143(3) R.W.S. 144C(13) OF THE ACT ON 23.11.2016 AND PROPOSED DOWNWARD ADJUSTMENT OF R S.1,51,79,164/- TOWARDS PAYMENT OF MANAGEMENT FEES. THE ASSESSEE H AS FIELD ITS OBJECTION AGAINST DRAFT ASSESSMENT ORDER BEFORE THE DRP, BANG ALORE, AND CHALLENGED TP ADJUSTMENT SUGGESTED BY THE TPO ALONG WITH VARIO US EVIDENCES. THE DRP VIDE ITS ORDER DATED 17.05.2017 HAS UPHELD DOWN WARD ADJUSTMENT SUGGESTED BY THE TPO TOWARDS PAYMENT OF MANAGEMENT FEES ON THE GROUND THAT THE ASSESSEE HAS NOT PROVIDED ANY RATIONALE FO R ADOPTING TNMM AS MOST APPROPRIATE METHOD. THE DRP, FURTHER, HELD TH AT EACH TRANSACTION HAS TO BE EVALUATED SEPARATELY AND THE NATURE OF EXPEND ITURE INCURRED BY THE ASSESSEE, IT IS DIFFICULT TO ACCEPT THE ARGUMENTS T HAT WHEN ALL TRANSACTIONS ITA NO.2095/CHNY/2017 :: 5 :: ARE TESTED BY ADOPTING TNMM AS MOST APPROPRIATE MET HOD, SEGREGATION OF FEW TRANSACTIONS AND APPLYING CUP METHOD IS INCORRE CT. THE DRP, FURTHER, HELD THAT THE ASSESSEE HAS NOT FURNISHED ANY EVIDEN CE TO PROVE THAT IT HAD RECEIVED SERVICE FROM ITS AE WITH REGARD TO PAYMENT OF MANAGEMENT FEES EXCEPT FOR MARKETING SERVICES. PURSUANT TO THE DIR ECTIONS OF THE DRP, THE AO HAS PASSED FINAL ASSESSMENT ORDER ON 30.06.2017 U/S.143(3) R.W.S.144C(13) OF THE ACT AND MADE ADDITIONS OF RS. 1,51,79,164/- TOWARDS DOWNWARD ADJUSTMENT ON ACCOUNT OF MANAGEMENT FEES P AID TO CTL-UK. AGGRIEVED BY THE FINAL ASSESSMENT ORDER, THE ASSESS EE HAS FILED THIS APPEAL BEFORE US. 6. THE LD.AR FOR THE ASSESSEE SUBMITTED THAT THE IS SUE IS SQUARELY COVERED IN FAVOUR OF THE ASSESSEE BY THE DECISION O F ITAT IN ASSESSEES OWN CASE FOR THE AY 2012-13, WHERE UNDER IDENTICAL CIRC UMSTANCES, THE TRIBUNAL HAS IN PRINCIPLE ACCEPTED THE ARGUMENTS OF THE ASSE SSEE THAT WHEN TNMM IS ADOPTED AS MOST APPROPRIATE METHOD AND FURTHER, THE TRANSACTIONS OF THE ASSESSEE WITH ITS AE ARE ACCEPTED AT ALP THAN SEGRE GATION OF ONE TRANSACTION AND APPLYING CUP METHOD TO DETERMINE TH E ALP IS INCORRECT. HOWEVER, SET ASIDE THE APPEAL TO THE FILE OF THE TP O ON THE GROUND THAT THE ASSESSEE HAS FAILED TO FILE EVIDENCES TO PROVE SERV ICES RECEIVED FROM ITS AE WITH A DIRECTION TO THE TPO TO RE-CONSIDER THE ISSU E. HE, FURTHER, SUBMITTED THAT AFTER THE DECISION OF THE ITAT IN ASSESSEES O WN CASE, THE ISSUE IS BEING NOW SETTLED BY THE DECISION OF THE HONBLE DELHI HI GH COURT IN THE CASE OF MAGNETI MARELLI POWERTRAIN INDIA V. DCIT REPORTED I N 389 ITR 469, WHEREIN, ITA NO.2095/CHNY/2017 :: 6 :: THE HONBLE DELHI HIGH COURT CLEARLY HELD THAT HAVI NG ACCEPTED THE TNMM AS THE MOST APPROPRIATE METHOD, IT WAS NOT OPEN TO THE TPO TO SEGREGATE ONLY ONE ELEMENT I.E. PAYMENT OF TECHNICAL ASSISTAN CE FEE TO AN ENTIRELY DIFFERENT (CUP METHOD) METHOD. THE HONBLE SUPREME COURT AFFIRMED THE FINDINGS OF THE HONBLE DELHI HIGH COURT WHILE DISM ISSING THE SLP FILED BY THE REVENUE VIDE ITS ORDER DATED 25.10.2016. THERE FORE, NOW THE ISSUE IS ALSO SETTLED BY THE DECISION OF THE HONBLE SUPREME COURT THAT WHEN ALL TRANSACTIONS OF THE ASSESSEE WITH ITS AE RECKONED U NDER ONE METHOD I.E. TNMM AND TRANSACTIONS ARE ALP THEN SEGREGATING ONE ELEMENT OF SERVICES AND APPLYING CUP METHOD IS INCORRECT. THEREFORE, T HE LD.TPO AND LD.DRP WERE ERRED IN APPLYING CUP METHOD TO MAKE DOWNWARD ADJUSTMENT TOWARDS PAYMENT OF MANAGEMENT FEES TO CTL-UK. 7. THE LD.DR, ON THE OTHER HAND, STRONGLY SUPPORTIN G THE ORDERS OF THE LD.TPO AS WELL AS THE LD.DRP SUBMITTED THAT THE TPO HAS BROUGHT OUT CLEAR FACTS TO PROVE THAT THE ASSESSEE HAS NOT FILED ANY EVIDENCES TO PROVE THE FACT OF RECEIVING SERVICES FROM ITS AE. UNLESS THE ASSESSEE DEMONSTRATE WITH EVIDENCE, RECEIPT OF SERVICES FOR PAYMENT OF M ANAGEMENT FEES, THEN THE QUESTION OF ALLOWING SUCH EXPENSES SHOULD BE TE STED IN ANY ONE OF THE SUITABLE METHOD. FURTHER, IT IS A SETTLED PRINCIP LE OF LAW THAT CUP METHOD IS MOST APPROPRIATE METHOD WHERE THIS KIND OF SERVI CES ARE AVAILED FROM ITS AE. THEREFORE, THE TPO AND THE DRP HAS RIGHTLY SUG GESTED DOWNWARD ADJUSTMENT TOWARDS MANAGEMENT FEES PAID TO ITS AE A ND HENCE, THEIR ORDERS TO BE UPHELD. ITA NO.2095/CHNY/2017 :: 7 :: 8. WE HEARD BOTH THE PARTIES, PERUSED THE MATERIAL AVAILABLE ON RECORD AND GONE THROUGH ORDERS OF THE AUTHORITIES BELOW. THE TPO HAS SUGGESTED DOWNWARD ADJUSTMENT OF MANAGEMENT FEES PAID TO CTL- UK BASICALLY ON TWO GROUNDS. THE FIRST REASON GIVEN BY THE TPO TO MAKE TP ADJUSTMENT IS THAT THE ASSESSEE HAS NOT FILED ANY EVIDENCES TO PROVE R ECEIPT OF SERVICES FROM ITS AE. THE TPO, FURTHER, WAS OF THE OPINION THAT THE SERVICES CLAIMED TO HAVE RECEIVED BY THE ASSESSEE FROM ITS AE ARE IN TH E NATURE OF SHAREHOLDERS/STEWARDSHIP SERVICES, WHICH DID NOT GI VE ANY COST BENEFIT TO THE ASSESSEE. THE ANOTHER REASON GIVEN BY THE TPO TO SUGGEST TP ADJUSTMENT IS THAT THE METHOD SELECTED BY THE ASSES SEE TO COMPARE PAYMENT OF MANAGEMENT FEES IS NOT A PROPER METHOD. BECAUSE, IF CUP IS SELECTED, THEN IT IS EASY TO COMPARE THE TRANSACTIO NS IN A SIMILAR SCENARIO, AN INDEPENDENT ENTITY WOULD NOT BE WILLING TO PAY S UCH AMOUNT FOR SERVICES SO CLAIMED TO HAVE BEEN RECEIVED BY THE ASSESSEE. WE HAVE GIVEN OUR THOUGHTFUL CONSIDERATION TO THE REASONS GIVEN BY TH E TPO TO MAKE DOWNWARD ADJUSTMENT FOR MANAGEMENT FEES PAID TO AE AND FIND THAT IN SO FAR AS SELECTION OF MOST APPROPRIATE METHOD, ALTHOU GH THE TPO IS CORRECT IN SELECTING CUP METHOD AS THE MOST APPROPRIATE METHOD BUT FAILED TO BRING ON ANY COMPARABLE TO TEST THE TRANSACTIONS OF THE A SSESSEE WITH ITS AE. FURTHER, IT IS A SETTLED PRINCIPLE OF LAW BY THE DE CISION OF THE VARIOUS HIGH COURTS INCLUDING THE DECISION OF THE HONBLE DELHI HIGH COURT IN THE CASE OF MAGNETI MARELLI POWERTRAIN INDIA V. DCIT THAT HAVIN G ACCEPTED THE TNMM AS THE MOST APPROPRIATE METHOD IN RESPECT OF ALL TR ANSACTIONS, IT WAS NOT ITA NO.2095/CHNY/2017 :: 8 :: OPEN TO THE TPO TO SELECT ONLY ONE OF THE SERVICES I.E. PAYMENT OF TECHNICAL FEES TO AN ENTIRELY DIFFERENT (CUP METHOD). THE SA ID FINDINGS OF THE HONBLE HIGH COURT HAS BEEN AFFIRMED BY THE HONBLE SUPREME COURT WHILE DISMISSING THE SLP FILED BY THE REVENUE. IN FACT, THE ITAT IN THE ASSESSEES OWN CASE FOR THE AY 2012-13 HAS TAKEN A SIMILAR VIE W AND HELD THAT IT IS NOT OPEN TO THE TPO TO SELECT A DIFFERENT METHOD FO R ONE ELEMENT OF SERVICES, WHEN IT IS ACCEPTED THE ENTIRE TRANSACTIO NS OF THE ASSESSEE WITH ITS AE ARE AT ALP UNDER TNMM. HOWEVER, THE TRIBUNA L HAS SET ASIDE THE ISSUE TO THE FILE OF THE TPO TO VERIFY THE CLAIM OF THE ASSESSEE WITH EVIDENCES OF RECEIPT OF SERVICES FROM ITS AE AND DIRECTED THE TPO TO ALLOW THE EXPENDITURE IN CASE THE ASSESSEE HAS FILED NECESSAR Y EVIDENCES TO PROVE RENDERING OF SERVICES BY ITS AE. IN THE PRESENT CA SE, FOR THE IMPUGNED ASSESSMENT YEAR, WE ARE NOT IN AGREEMENT WITH SELEC TION OF DIFFERENT METHOD (CUP) BY THE TPO FOR BENCH MARKING ONE ELEME NT OF SERVICE, WHEN ENTIRE SERVICES RECEIVED BY THE ASSESSEE FROM ITS A E ARE TESTED AT TNMM. IN PRINCIPLE, WE AGREE WITH THE ARGUMENTS OF THE LD .AR FOR THE ASSESSEE THAT SEGREGATION OF ONE ELEMENT OF SERVICES OUT OF BUNCHES OF SERVICES RECEIVED BY THE ASSESSEE FROM ITS AE AND APPLYING D IFFERENT METHOD FOR BENCH MARKING TRANSACTION IS NOT CORRECT, MOST PART ICULARLY WHEN TPO HAS ACCEPTED TRANSACTIONS OF THE ASSESSEE WITH ITS AE A RE AT ALP UNDER TNMM. HOWEVER, FACT REMAINS THAT FROM THE ORDERS OF THE L OWER AUTHORITIES, IT WAS NOTICED THAT THE TPO WANTED THE ASSESSEE TO SHOW TH AT SERVICES WERE ACTUALLY RENDERED BY ITS AE TO THE ASSESSEE. UNLES S, THE ASSESSEE ITA NO.2095/CHNY/2017 :: 9 :: SUBSTANTIATES ITS CLAIM WITH NECESSARY EVIDENCE INC LUDING INVOICES, IF ANY, RAISED BY THE AE FOR RENDERING OF SERVICES, THEN TH E CLAIM OF THE ASSESSEE CANNOT BE ACCEPTED. THEREFORE, WE ARE OF THE CONSI DERED VIEW THAT THE ISSUE NEEDS TO BE SET ASIDE TO THE FILE OF THE AO F OR LIMITED PURPOSE VERIFICATION OF FACTS WITH REGARD TO RENDERING OF S ERVICES BY THE AE TO THE ASSESSEE IN CONNECTION WITH PAYMENT OF MANAGEMENT F EES. IN CASE, THE ASSESSEE PRODUCED PARTICULARS OF ACTUAL RECEIPT OF SERVICES, THEN THE TPO IS DIRECTED TO ACCEPT THE TP STUDY CONDUCTED BY THE AS SESSEE BY APPLYING TNMM AS THE MOST APPROPRIATE METHOD AND DELETE TP A DJUSTMENT MADE TOWARDS MANAGEMENT FEES. 9. IN THE RESULT, THE APPEAL FILED BY THE ASSESSEE IS ALLOWED FOR STATISTICAL PURPOSES. ORDER PRONOUNCED ON THE 12 TH DAY OF APRIL, 2021, IN CHENNAI. S D/ - ( . ) ( V. DURGA RAO ) /JUDICIAL MEMBER S D/ - ( . ) ( G. MANJUNATHA ) /ACCOUNTANT MEMBER /CHENNAI, /DATED: 12 TH APRIL, 2021. TLN /COPY TO: 1. /APPELLANT 4. ' /CIT 2. /RESPONDENT 5. /DR 3. ' ( ) /CIT(A) 6. /GF