Appeal Details
Counselvise Citation
[2015] 140 COUNSELVISE.COM (IT) 96094 (ITAT-CHENNAI)
Assessee PAN
Bench
Appeal Number
Duration Of Justice
7 month(s) 19 day(s)
Appellant
Respondent
Appeal Type
Income Tax Appeal
Pronouncement Date
29-09-2015
Appeal Filed By
Assessee
Bench Allotted
D
Assessment Year
2011-2012
Appeal Filed On
09-02-2015
Judgement Text
, , IN THE INCOME TAX APPELLATE TRIBUNAL D BENCH, CHENNAI . , . ! '# , $ % BEFORE SHRI A.MOHAN ALANKAMONY, ACCOUNTANT MEMBER AND SHRI V. DURGA RAO, JUDICIAL MEMBER ./ I.T.A.NO.331 /MDS./2015 ( / ASSESSMENT YEAR :2011-12) M/S.SETHU VALLIAMMAL EDUCAIONAL TRUST, NO.59,VALLIAMMAL STREET, RED HILLS MAIN ROAD, AMBATTUR, CHENNAI 600 053. VS. THE DEPUTY COMMISSIONER OF INCOME TAX(EXEMTIONS-III), AYAKAR BHAVAN, ANNEXE BUILDING, CHENNAI 600 024. PAN AAATS 0126 K ( &' / APPELLANT ) ( ()&' / RESPONDENT ) / APPELLANT BY : MR.G.BASKAR,ADVOCATE / RESPONDENT BY : MR.A.B.KOLI,JCIT, D.R / DATE OF HEARING : 06.08.2015 /DATE OF PRONOUNCEMENT : 29.09.2015 * / O R D E R PER A.MOHAN ALANKAMONY , ACCOUNTANT MEMBER: THIS APPEAL IS FILED BY THE ASSESSEE, AGGRIEVED B Y THE ORDER OF THE LEARNED COMMISSIONER OF INCOME TAX(A)-VII, CHEN NAI DATED 11.11.2014 IN ITA NO.127/14-15 PASSED UNDER SEC.14 3(3) READ WITH SECTION SEC. 250 OF THE ACT. ITA NO.331/MDS/2015 2 2. THE ASSESSEE HAS RAISED SEVEN ELABORATE GROUNDS IN ITS APPEAL; HOWEVER THE CRUXES OF THE ISSUES ARE THAT:- 1. THE LD. CIT (A) HAS ERRED IN UPHOLDING THE ACTIO N OF THE LD. ASSESSING OFFICER BY DENYING EXEMPTION U/S.11 & U/S .12 OF THE ACT FOR THE FOLLOWING REASONS. I) THAT THE INDUCTION OF A MINOR MS.THARA BHASKARA N AS A TRUSTEE HAS RENDERED THE TRUST VOID AB-INITO. II) THAT THE TRUSTEES RESIDE OUTSIDE INDIA. III) THAT THE TRUST IS A PRIVATE TRUST. IV) THAT THE ABSENCE OF SAVING CLAUSES IN TRUST DE ED. 2. THE LD. CIT (A) HAS ERRED IN CONFIRMING THE ORD ER OF THE LD. ASSESSING OFFICER FOR LEVYING INTEREST U/S.234B OF THE ACT. ON THIS ISSUE WE HAVE ON SEVERAL OCCASIONS HELD THAT, LEVY OF INTEREST U/S. 234B OF THE ACT IS CONSEQUENTIAL AND THEREFORE IT IS DISPOSED OFF ACCORDINGLY. 3. THE BRIEF FACTS OF THE CASE ARE THAT THE ASSESS EE IS A PUBLIC CHARITABLE TRUST, REGISTERED ON 10.02.1989 AND RECO GNIZED U/S.12AA OF ITA NO.331/MDS/2015 3 THE ACT BY THE DEIT(E), CHENNAI ON 02.12.1992 VIDE ORDER NO.DIT(E)/2(204)/92-93, FILED ITS RETURN OF INCOME FOR ASSESSMENT YEAR 2011-12 ON 27.11.2012 ADMITTING NIL TAXABLE INCOM E. SUBSEQUENTLY, THE CASE WAS TAKEN UP FOR SCRUTINY THROUGH CASS. TH EREAFTER ON EXAMINING THE RECORDS FILED BY THE LD.A.R, THE LD. ASSESSING OFFICER FOUND THAT THE TRUST DEED DATED 10.02.1989 INDICATE D THAT THE TRUSTEE MS.THARA BHASKARAN, D/O MR.SETHU BHASKARAN WAS AGED 16 YEARS A MINOR AS ON THE DATE OF THE DECLARATION OF THE TRUS T AND WAS RESIDING AT NO.1, MEDAN TRENGGANU, PENANG MALAYASIA, A FOREI GN COUNTRY. SINCE ONE OF THE TRUSTEES IS A MINOR AND RESIDING I N FOREIGN COUNTRY, THE LD. ASSESSING OFFICER OPINED THAT THE TRUST IS INVALID. ACCORDINGLY, THE LD. ASSESSING OFFICER ISSUED SHOW-CAUSE NOTICE TO THE ASSESSEE AS TO WHY THE TRUST SHOULD NOT BE TREATED AS INVALI D. IN RESPONSE, THE ASSESSEE FILED ITS EXPLANATION AS UNDER:- MINOR AS A TRUSTEE IT HAS BEEN POINTED OUT THAT SINCE A MINOR WAS APPOINTED AS A TRUSTEE AS PER THE TRUST DEDUCTION I NCORPORATING THE TRUST, THE REGISTRATION OF THE TRUST MAY BECOME VOID AB INITIO . IT IS SUBMITTED THAT THE TRUST WAS SET UP AS A CHARITABLE TRUST BY MR. SETHU BHASKARAN AS THE FOUNDER SETTLOR OF THE TRUST. IN THE TRUST DEED AMONG OTHER TRUSTEES, THE SETTLOR HAD ALSO NAMED HIS DAUGHTER WHO WAS 16 YEARS AT THAT TIME AS ONE OF TH E TRUSTEES. IN THIS CONTEXT, WE WISH TO HUMBLY SUBMIT THAT THER E ARE FOUR ESSENTIAL ELEMENTS OF A VALID CHARITABLE TRUST ITA NO.331/MDS/2015 4 CHARITABLE OR RELIGIOUS OBJECT : THE OBJECT OR PURPOSE OF THE TRUST MUST BE A VALI D CHARITABLE PURPOSE ACCORDING TO LAW. CAPACITY TO CREATE TRUST: THE FOUNDER OR SETTLOR SHOULD BE CAPABLE OF CREATIN G A TRUST AND DEDICATING HIS PROPERTY TO THAT TRUST. CERTAINTY OF OBJECT AND DEDICATION THERETO : THE SETTLOR SHOULD INDICATE PRECISELY THE OBJECT OF THE TRUST AND THE PROPERTY IN RESPECT OF WHICH IT IS MADE. THE PROPERTY SHOULD BE DEDICATED TO THE TRUST AND THE OWNER MUST DIVEST HIMSELF OF THE OWNERSHIP OF THAT PROPERTY. CONCURRENCE WITH THE LAW: THE TRUST OR ITS OBJECTS MUST NOT BE OPPOSED TO T HE PROVISIONS OF ANY LAW FOR THE TIME BEING IN FORCE. IT IS SUBMITTED THAT ALL THESE REQUISITES HAVE BEEN COMPLIED WITH AT THE TIME OF F ORMATION OF THE TRUST AND THE TRUST WAS SET UP BY MEANS OF A REGISTERED TRUST DEED WHIC H IS ALSO ENCLOSED FOR YOUR KIND REFERENCE. IT IS ALSO SUBMITTED THAT THE TRUST DEED WAS VETTED AND APPROVED BY THE INCOME TAX DEPARTMENT AND REGISTRATION U/S. I2AA OF THE IT ACT, AS A VALID CHARITABLE TRUST HAS BEEN PROVIDED TO THE TRUST VID E LETTER DATED 02-12-1992, COPY OF WHICH IS ENCLOSED. IT IS ALSO SUBMITTED THAT THE TRUST HAS BEEN CARRYI NG OUT CHARITABLE ACTIVITIES PERTAINING TO EDUCATION PURSUANT TO THE OBJECTS CON TAINED IN THE TRUST DEED AD HAS BEEN COMPLYING WITH THE REQUIREMENTS OF THE INCOME TAX ACT AND THE RULES AND REGULATIONS THEREOF. IT IS THEREFORE SUBMITTED THA T HE APPOINTMENT AS A TRUSTEE OF A PERSON WHO WAS A MINOR AT THE TIME OF APPOINTMENT A S A TRUSTEE OF A PERSON WHO WAS A MINOR AT THE TIME OF APPOINTMENT DOES NOT IN ANY MANNER AFFECT THE VALIDITY OF THE TRUST. ITA NO.331/MDS/2015 5 HOWEVER, THE LD. ASSESSING OFFICER REJECTED THE SUB MISSIONS OF THE ASSESSEE AND TREATED THE TRUST AS INVALID TRUST AND FURTHER HELD INELIGIBLE FOR EXEMPTION U/S.11 & U/S.12 OF THE ACT DUE TO THE FOLLOWING REASONS:- (I) ONE OF THE TRUSTEES IS A MINOR. (II) THE INTENTION OF THE TRUSTEES IS TO RUN THE IN STITUTIONS AS CLOSELY HELD FAMILY PROPERTY BY INDUCTING MINOR HEIR. (III) THE TRUST DEED ALSO PROVIDED THAT SUCCESSORS AS THE TRUSTEES SHALL ONLY BE FROM THE FAMILY OF MR.SETHU KUMARAN A ND THARA BHASKARAN (SON AND MINOR DAUGHTER OF SETTLOR MR.SET HU BHASKARAN). HAVING HELD THE TRUST TO BE LEGALLY INVALID THE LD. ASSESSING OFFICER DENIED THE BENEFIT OF SECTION.11 & 12 OF THE ACT AN D ASSESSED THE INCOME OF THE ASSESSEE TRUST AS AOP AT MAXIMUM MARG INAL RATE. 4. ON APPEAL, THE LD. CIT(A) ENDORSED THE VIEW OF THE LD. ASSESSING OFFICER WITH THE FOLLOWING OBSERVATIONS:- DECISION 4. THE ONLY ISSUE INVOLVED IN THE APPEAL IS WHETHER THE TRUST IS A VALID ONE ENTITLED FOR REGISTRATION U/S I2A(A) OF THE ACT AND IN CONSEQUENCE ENTITLED FOR ITA NO.331/MDS/2015 6 EXEMPTION U/S 11 OF THE ACT OR NOT ? THE AO HELD TH AT THE ASSESSEE TRUST IS NOT ENTITLED FOR EXEMPTION U/S 11 OF THE ACT AS ONE AT THE TRUSTEES WAS A MINOR AND NOT COMPETENT TO HOLD THE POST OF TRUSTEE . PERUSAL OF THE TRUST DEED DATED 10.02.1989 REVEALS THAT MS. THARA SHASKA RAN ONE OF THE TRUSTEES WAS AGED ABOUT 16 YEARS AT THE TIME OF CON STITUTION OF THE TRUST I.E. A MINOR. IT IS ALSO NOTICED THAT MISS. THERE BHASKA RAN RESIDES AT NO.1, MEDAN TRENGGAUE FLUE, PENANG, MALAYSIA. THERE IS NO EXPLANATION FROM THE ASSESSEE AS TO HOW SHE WILL FUNCTION AS A TRUSTEE E VEN SHE IS NOT A MINOR AT THE TIME OF GRANT OF REGISTRATION U/S 12A(A) OF THE ACT. PARA 10 OF THE TRUST DEED REVEALS THAT AFTER THE LIFE TIME OF TRUSTEES SETHU KUMARAN AND THARA BHASKARAN, THEIR ELDEST LINEAL DESCENDANTS ALONE SH ALL BECOME THE TRUSTEES AND SUCCESSION TO THE TRUSTEESHIP SHALL BE ONLY FRO M THE FAMILIES OF SETHU KUMAREN AND THARA BHASKARAN AND NOT FROM THE OTHER TRUSTEES. THIS CONDITIONAL CLAUSE MAKES THE TRUST AS A PRIVATE PRO PERTY OF INDIVIDUALS AS RIGHTLY POINTED OUT BY THE ASSESSING OFFICER. WHEN THE TRUST BECOMES A PRIVATE TRUST, INDIAN TRUST ACT AND INDIAN CONTRACT ACT AUTOMATICALLY COME INTO PLAY. IN THAT SITUATION, PERSON COMPETENT TO C ONTRACT ALONE CAN BE A TRUSTEE AND MISS THERE BHASKARAN BEING A MINOR AT T HE TIME OF CONSTITUTION OF THE TRUST IS NOT CAPABLE OF HOLDING THE POST OF TRUSTEE. THIS RENDERS THE TRUST DEED VOID AB INITIO. A TRUST WHICH IS VOID AB INITIO CANNOT BE HELD A VALID ONE LEGALLY. AFTER THARA BHASKARAN BECOMING MAJOR, THE TRUST SHOULD HAVE ITA NO.331/MDS/2015 7 MADE A NEW TRUST DEED AND APPLIED FOR REGISTRATION U/S 12A(A) OF THE ACT. THIS WAS NOT DONE IN THIS CASE. 4.1 SUB-SECTION(2) OF SECTION 1 OF THE I.T. ACT, 19 61 SAYS THAT THE ACT EXTENTS TO THE WHOLE OF INDIA, IN THIS CASE, ONE OF THE TRUSTEES RESIDES ABROAD AND THE ARGUMENTS OF THE ASSESSEE ARE SILENT ON THE STATUS OF THAT TRUSTEE I.E. WHETHER SHE IS SUBJECT TO INDIAN INCOM E-TAX ACT OR NOT ? EXPEDIENCY REQUIRES THAT A TRUSTEE SHOULD BE A PERS ON WITHIN THE REACH OF THE ARM OF INDIAN COURTS. THE TRUST DEED DOES NOT C ONTAIN SPECIFIC PROVISO REGARDING ANY AMENDMENT AND APPROVAL IF ANY TO BE O BTAINED FROM THE CIT/DIT(EXERNPTIONS) AS THE CASE MAY BE. PERUSAL OF THE RECORDS REVEALS THAT MR. SETHU BHASKARAN, FOUNDER TRUSTEE, MRS. KAM ALA BHASKARAN AND MRS THARKESWARI, TRUSTEES AT NO.104. PRINSEP ST. 5. 02, SINGAPORE-188653. THE OTHER TWO TRUSTEES VIZ. MR. SETHU KUMARAN AND M RS. SETHU RANI ONLY RESIDE IN INDIA. THE ABOVE DISCREPANCIES AND INCONS ISTENEES CLEARLY ESTABLISH THAT THE ASSESSEE TRUST IS NOT ENTITLED F OR EXEMPTION 11 OF THE ACT FOR THE FOLLOWING REASONS, 1. THE TRUST DEED DATED 10.02,1989 IS VOID AB INITO . 2. ONE OF THE TRUSTEES WAS A MINOR AT THE TIME OF C ONSTITUTION OF TRUST DEED. 3. THREE OF THE TRUSTEES RESIDE IN FOREIGN COUNTRIE S. 4. CONDITIONAL CLAUSES IN THE TRUST DEED MAKES THE TRUST A PRIVATE ONE. ITA NO.331/MDS/2015 8 5. SAVING CLAUSES SUCH AS PERMISSION OF THE DEPARTM ENT FOR AMENDMENT, ALTERATION, ETC. ARE NOT AVAILABLE IN THE TRUST DEE D. IN VIEW OF THE ABOVE, I AM OF THE CONSIDERED VIEW THAT THE ASSESSEE-TRUST IS N OT ENTITLED TO EXEMPTION U/S.11 OF THE ACT. HENCE, I DECLINE TO INTERFERE IN THE ASSESSMENT PASSED BY THE AO. ALL THE GROUNDS OF APPEAL RAISED ARE DIS MISSED IN TOTO. 4. BEFORE US, THE LD.A.R ARGUED BY STATING THAT ON LY ONE OF THE TRUSTEE IS A MINOR AND RESIDING ABROAD WHILE AS ALL OTHER TRUSTEES ARE MAJORS RESIDING IN INDIA AND THEREFORE ELIGIBLE TO BE TRUSTEES. HE FURTHER SUBMITTED THAT JUST BECAUSE ONE OF THE TRUS TEES DOES NOT QUALIFY TO ASSUME THE STATUS IN THE TRUST AS A TRUSTEE WILL NOT EXTINGUISH THE EXISTENCE OF THE TRUST AND THEREBY DISENTITLING THE TRUST FROM PURSING ITS OBJECTS WHICH ARE CHARITABLE IN NATURE. THE LD. A. R. ALSO RELIED ON CERTAIN DECISIONS RENDERED BY VARIOUS HIGHER JUDICI ARIES. ON THE OTHER HAND, LD. D.R ARGUED IN SUPPORT OF THE ORDERS OF TH E REVENUE AND PLEADED THAT THEIR ORDERS MAY BE CONFIRMED. 5. WE HAVE HEARD BOTH THE PARTIES AND CAREFULLY PE RUSED THE MATERIALS AVAILABLE ON RECORD. IT IS APPARENT FROM THE ORDERS OF THE REVENUE THAT THE LD. DIT(E) AT THE TIME OF GRANTING REGISTRATION ITA NO.331/MDS/2015 9 U/S.12AA OF THE ACT HAS RECOGNIZED THE ASSESSEE TRU ST AS A VALID CHARITABLE TRUST. WHEN THE CASE CAME UP FOR ASSESS MENT, THE FACTS WITH RESPECT TO THE CREATION OF THE TRUST, APPOINTM ENT OF TRUSTEES AND ITS EXISTENCE HAS NOT CHANGED. HOWEVER, THE LD. AS SESSING OFFICER AS WELL AS THE LD. CIT (A) OPINED THAT THE TRUST IS INVALID BECAUSE ONE OF THE TRUSTEES IS A MINOR AND ANOTHER TRUSTEE IS R ESIDING ABROAD AND THEREFORE IT HAS TO BE ASSESSED AS AN AOP. IT IS P ERTINENT TO MENTION HERE THAT INDIAN TRUST ACT, 1882 IS NOT APPLICABLE TO CHARITABLE TRUST. HOWEVER, AS POINTED OUT BY THE LD. A.R, THE HONBL E APEX COURT IN THE CASES OF SHEIKH ABDUL KAYUM VS. MULLA ALIBHAI ( 1963) 3 SCR 623 AND STATE OF UTTAR PRADESH VS. BANSI DHAR & ORS . (1974) 1 SCC 446, IT WAS HELD THAT THE GENERAL PRINCIPLES OF TRU ST ADUMBRATED IN THE PROVISIONS OF THE TRUST ACT CAN BE APPLIED BY INVOK ING THE UNIVERSAL RULES OF EQUITY AND GOOD CONSCIENCE EVEN THOUGH PRO VISIONS OF THE TRUSTS ACT PROPRIO VIGORE DO NOT APPLY TO PUBLIC CH ARITABLE TRUSTS. A CAVEAT IS ADDED THEREIN THAT CARE MUST CERTAINLY BE EXERCISED NOT TO IMPORT BY ANALOGY WHAT IS NOT GERMANE TO THE GENERA L LAW OF TRUST. THEREFORE, IT IS EVIDENT THAT THE PRINCIPLES LAID D OWN IN THE INDIAN TRUST ACT, 1882 MAY BE APPLIED IN THE CASE OF PUBIC CHARI TY TRUST ITA NO.331/MDS/2015 10 CONSIDERING THE UNIVERSAL LAW OF EQUALITY AND GOOD CONSCIOUS. SECTION-7 OF THE INDIAN TRUSTS ACT, 1882 LAYS DOWN AS TO WHO MAY CREATE A TRUST I.E. ( A) BY EVERY PERSON COMPETENT TO CONTRACT, AND (B) WITH THE PERMISSION OF A PRINCIPAL CIVIL COURT OF O RIGINAL JURISDICTION, BY OR ON BEHALF OF A MINOR; BUT SUBJECT IN EACH CASE T O THE LAW FOR THE TIME BEING IN FORCE AS TO THE CIRCUMSTANCES AND EXT ENT IN AND TO WHICH THE AUTHOR OF THE TRUST MAY DISPOSE OF THE TRUST-PR OPERTY. IN THE CASE OF THE ASSESSEE, ON PERUSING THE TRUST DEED IT IS E VIDENT THAT THE TRUST IS CREATED BY MR.SETHU BHASKARAN S/O SINNIAH SETHU AGED ABOUT 55 YEARS ON THE 10 TH DAY OF FEBRUARY, 1989 IN INDIA. THESE FACTS ARE N OT DISPUTED. FURTHER, THE AUTHOR OF THE TRUST MR.SETH U BASKARAN HAS APPOINTED HIMSELF ALONG WITH MR.SETHU KUMANAN AGED 26 YEARS, MR.L.SOWMIYA MURTHY, AGED 40 MRS.KAMALA BHASKARAN A GED 52, AND MS.THARA BHASKARAN AGED 16 YEARS AS THE TRUSTEES O F THE TRUST. AS PER SECTION-10 OF THE INDIAN TRUSTS ACT, 1882 ANY P ERSON CAPABLE OF HOLDING PROPERTY MAY BE A TRUSTEE BUT WHERE THE TRU ST INVOLVES THE EXERCISE OF DISCRETION, HE CANNOT EXECUTE UNLESS HE IS COMPETENT TO CONTRACT. FURTHER, NO ONE IS BOUND TO ACCEPT A TRUS T. A TRUST IS ACCEPTED BY ANY WORDS OR ACTS OF THE TRUSTEES INDIC ATING IT REASONABLE ITA NO.331/MDS/2015 11 CERTAINTY OF SUCH ACCEPTANCE. A TRUSTEE MAY ALSO DI SCLAIM TO BE A TRUSTEE AND SHALL PREVENT THE TRUST PROPERTY FROM V ESTING IN HIM. A DISCLAIMER BY ONE OR TWO OR MORE CO-TRUSTEES VEST S THE TRUST PROPERTY IN THE OTHERS AND MAKES HIM OR THEM SOLE T RUSTEE OR TRUSTEES FROM THE DATE OF THE CREATION OF THE TRUST. THUS, IF ONE OF THE TRUSTEES APPOINTED IS NOT COMPETENT TO CONTRACT, HE CANNOT B E MADE AS A TRUSTEE AS RIGHTLY POINTED OUT BY THE REVENUE. HOW EVER, IN THIS GIVEN CASE, THERE ARE OTHER TRUSTEES ON WHOM THE PROPERTY IN THE TRUST CAN BE LEGALLY VESTED. THEREFORE, IT CANNOT BE SAID THA T THE CREATION OF THE TRUST IS VOID AB INITIO AS HELD BY THE REVENUE. FURTHER, THERE ARE NO PROVISIONS IN THE INDIAN TRUSTS ACT,1882, TO DEBAR THE TRUSTEES IF THEY RESIDE OUTSIDE INDIA. SECTION-11(1)(A) OF THE ACT O NLY PROVIDES THAT THE INCOME OF THE TRUST HAS TO BE APPLIED IN INDIA AND IN THE CASE OF THE ASSESSEE THAT IS NOT DISPUTED. MOREOVER, THERE ARE NO STATUTORY PROVISIONS IN ANY ACT TO DEBAR THE FAMILY MEMBERS O F THE AUTHOR OF THE TRUST TO BE THE TRUSTEES OF A CHARITABLE TRUST. AS LONG AS THE OBJECTS OF THE TRUST ARE CHARITABLE AND FOR THE BENEFIT OF THE GENERAL PUBLIC AT LARGE THE CHARITABLE NATURE OF THE TRUST CANNOT BE DENIED. THEREFORE, WE HEREBY DIRECT THE LD. ASSESSING OFFICER TO TREAT THE TRUST AS A ITA NO.331/MDS/2015 12 CHARITABLE TRUST RECOGNIZED U/S.12AA OF THE ACT SIN CE THE REGISTRATION GRANTED BY THE LD.DITE IS NOT WITHDRAWN AND ASSESS THE INCOME OF THE TRUST, IF ANY, IN ACCORDANCE WITH THE PROVISION S OF THE ACT AND ON MERITS. 6. IN THE RESULT, THE APPEAL OF ASSESSEE IS ALLOWED AS INDICATED HEREIN ABOVE. ORDER PRONOUNCED ON 29 TH SEPTEMBER, 2015 AT CHENNAI. SD/- SD/- ( . ! '# ) (V. DURGA RAO) ( . ) (A.MOHAN ALANKAMONY) JUDICIAL MEMBER ACCOUNTANT MEMBER CHENNAI, DATED THE 29 TH SEPTEMBER, 2015. K S SUNDARAM. !'## $%#&% /COPY TO: # 1. /APPELLANT 2. /RESPONDENT 3. # '#() /CIT(A) 4. # ' /CIT 5. %*+# , /DR 6. +-#. /GF
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