DCIT, Chengalput V. BASF Catalysts India P Ltd., Kancheepuram

ITA 651/CHNY/2016

• Counselvise Citation: [2016] 131 COUNSELVISE.COM (IT) 8078 (ITAT-CHENNAI)
• Duration Of Justice: 7 month(s) 23 day(s)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 10-11-2016
• Appeal Filed By: Department
• Order Result: Dismissed
• Bench Allotted: A
• Assessment Year: 2010-2011
• Appeal Filed On: 18-03-2016
• Result in Favour of: Assessee
• Court: TRIBUNAL
• Department Lawyers: SHIVA SRINIVAS
• Assessee Lawyers: N V BALAJI
• Keywords: Transfer pricing; Double taxation relief; International transaction; Permanent establishment
• Section: 143(3); 2

Judgement Text

, , IN THE INCOME TAX APPELLATE TRIBUNAL A BENCH, CHENNAI , . , ' # BEFORE SHRI CHANDRA POOJARI, ACCOUNTANT MEMBER AND SHRI G. PAVAN KUMAR, JUDICIAL MEMBER / I.T.A. NO. 650 & 651/MDS/2016 / ASSESSMENT YEAR : 2009-10 & 2010-11 DEPUTY COMMISSIONER OF INCOME TAX, CORPORATE CIRCLE -1(2), CHENNAI - 600 034. VS. M/S.BASF CATALYSTS INDIA P. LTD., E-17, INDL. COMPLEX, MARAIMALAI NAGAR, KANCHEEPURAM 603 209. [PAN: AAACE 2545B] ( /APPELLANT) ( /RESPONDENT) % & / APPLICANT BY : SHRI SHIVA SRINIVAS, JCIT )*% & / RESPONDENT BY : SHRI N. V, BALAJI, ADVOCATE & /DATE OF HEARING : 24.08.2016 & /DATE OF PRONOUNCEMENT : 10 .11.2016 /O R D E R PER G. PAVAN KUMAR, JUDICIAL MEMBER: THE REVENUE HAS FILED APPEALS AGAINST THE DIFFERE NT ORDERS OF CIT(A) FOR THE ASSESSMENT YEAR 2009-10 ITA NO. 70/13-14 DATED 15.12.2016 AND FOR THE ASSESSMENT YEAR 2010-11 ITA NO. 101/14-15 DATED 15. 12.2016 PASSED U/S. 143 R.W.S. 92 CA AND 250 OF THE INCOME TAX ACT. SINCE, THE ISSUE IS COMMON IN THE :-2-: I.T.A. NOS. 650 & 651/MDS/2016 APPEALS AND ARE HEARD TOGETHER AND FOR THE PURPOSE OF CONVENIENCE, WE TAKE UP FACTS NARRATED IN THE REVENUE APPEAL IN ITA NO. 651 /2016 ASSESSMENT YEAR 2010-11. 2. THE REVENUE HAS RAISED THE FOLLOWING GROUNDS: 2.1 THE LD. CIT(A) ERRED IN DIRECTING THE AO TO DELETE THE ADDITION OF RS. 92,17,894/- MADE U/S. 40(A)(I) OF THE I.T. ACT. 2.2 THE LD. CIT(A) ERRED IN HOLDING THAT THE SERVIC ES RENDERED BY THE FOREIGN COMPANY TO THE ASSESSEE COMPANY CANNOT BE HELD TO BE EITHER 'MANAGERIAL' OR 'CONSULTANCY' OR 'TECHNICAL' WITHI N THE MEANING OF SEC. 9(1)(VII) R.W. EXPLANATION THERETO. 2.3 THE LD. CIT(A) OUGHT TO HAVE APPRECIATED THE FA CT THAT THE ACCOUNTING SERVICES AND CONSULTANCY SERVICES RENDERED BY THE FOREIGN COMPANY ARE PROFESSIONAL AND CONSULTANCY SERVICES WHICH REQUIR E HIGH DEGREE OF TECHNICAL EXPERTISE IN FINANCE, ACCOUNTING, H.R. M ANAGEMENT, SOFTWARE ANALYSIS. 2.4 THE LD. CIT(A) OUGHT TO HAVE APPRECIATED THE FA CT THAT THE SERVICES OFFERED ARE NOT MERE DATA ENTRY OPERATIONS WHICH R EQUIRE HIGH DEGREE OF SKILL SETS IN THE ABOVE SAID AREAS. 3. THE BRIEF FACTS OF THE CASE THAT THE ASSESSEE CO MPANY IS IN THE BUSINESS OF MANUFACTURE AND SALE OF CATALYSTS FOR THE AUTOMO BILE INDUSTRY AND FILED THE RETURN OF INCOME ELECTRONICALLY ON 29.09.2010 WITH TOTAL I NCOME OF RS. 33,08,48,051/- THE CASE WAS SELECTED UNDER SCRUTINY AND NOTICE UNDER 1 43 (2) OF THE ACT WAS ISSUED. IN :-3-: I.T.A. NOS. 650 & 651/MDS/2016 COMPLIANCE TO THE NOTICE, THE LD. AR OF THE ASSESSE E APPEARED AND FILED DETAILS CALLED FOR AND THE CASE WAS DISCUSSED FROM TIME TO TIME. THE LD. ASSESSING OFFICER FOUND THAT THE ASSESSEE COMPANY HAS INTERNATIONAL T RANSACTIONS WITH ITS AE AND THE LD. TPO HAS PASSED ORDER DATED 11.11.2013 WITH NO A DJUSTMENTS TO THE VALUE OF INTERNATIONAL TRANSACTIONS. THE ASSESSING OFFICER CALLED FOR THE EXPLANATIONS ON DETAILS AND FOUND THAT THE ASSESSEE COMPANY HAS CLA IMED AN AMOUNT OF RS. 92,17,894/- PAID TO ITS AE AT MALAYSIA IN RESPECT O F INTERNATIONAL TRANSACTION ON ACCOUNTING AND HUMAN RESOURCE SERVICES PROVIDED WIT HOUT DEDUCTION OF TDS/WITHHOLDING TAX. THE ASSESSEE COMPANY EXPLAINE D THAT THE SERVICES PROVIDED BY BASC MALAYSIA ARE NOT TECHNICAL SERVICES OR MANA GERIAL OR CONSULTANCY NATURE AS DEFINED IN EXPLANATION 2, TO SECTION 9(1)(VII) OF T HE ACT AND ALSO AS PER THE ARTICLE 12(3) OF THE DTAA BETWEEN INDIA AND MALAYSIA. THE ASSESSEE COMPANY EMPHASISED THAT THE SERVICES RENDERED BY BASC ARE FROM INFRAST RUCTURE LOCATED IN MALAYSIA AND THE AMOUNT PAID WOULD NOT BE TAXABLE U/S. 9(1)(I) O F THE ACT AS INCOME FROM THE SERVICES ARE NOT ACCRUED OR ARISE IN INDIA. FURTHE R, THE LD. AR PRODUCED COPY OF AGREEMENT WITH DETAILS OF CONSIDERATION, TRAINING A ND SERVICES. THE LD. AO ON PERUSAL OF AGREEMENT REFERRED AT PAGE 5 TO 7 OF THE ORDER IS OF THE OPINION THAT THE SERVICES ARE COVERED UNDER PROVISIONS OF SEC. 9(1)( VII) OF THE ACT AND ARE IN THE NATURE OF TECHNICAL SERVICES. THE SERVICES AGREEME NT EXPLAINED THAT THERE WAS A VISIT OF BASC TEAM DURING THE FINANCIAL YEAR 2009-10 AND THE LD. AO FURTHER REFERRED AT PAGE 9 OF HIS ORDER THAT THERE IS A CLAUSE PROVIDED IN THE AGREEMENT ON KNOWLEDGE UP GRADATION AND TO SERVE ASSESSEE COMPANY. THE LD . AO REFERRED TO THE ARTICLE 13 OF INDIA-MALAYSIA DTAA FOR PROPER DEFINITION OF 'TE CHNICAL SERVICES' AND THE NATURE OF SERVICES ARE COVERED UNDER ARTICLE 13 OF DTAA AN D IT IS NOT IN THE NATURE OF :-4-: I.T.A. NOS. 650 & 651/MDS/2016 BUSINESS PROFITS ENVISAGED IN THE ARTICLE 7 TO GAIN IMMUNITY FROM WITHHOLDING TAX AS PER ARTICLE 5 OF DTAA. WITH THESE OBSERVATIONS, TH E ASSESSING OFFICER IS OF THE OPINION THAT THE SERVICES ARE IN THE NATURE OF MANA GERIAL, TECHNICAL SERVICES FROM AN OVERSEAS ASSOCIATION AND COVERED UNDER ARTICLE 13 O F DTAA BETWEEN INDIA AND MALAYSIA AND ASSESSEE COMPANY IS LIABLE TO DEDUCT T AX ON PAYMENTS TO BASF ASIA PACIFIC SERVICE CENTRE, (BASC) MALAYSIA U/S. 195 OF INCOME TAX ACT AND SINCE TAX IS NOT DEDUCTED ON RS. 92,17,897/- THE SAID PAYMENT IS DISALLOWED U/S. 40(A)(I) OF INCOME TAX AND PASSED ORDER WITH OTHER DISALLOWANCE S U/S. 143(3) R.W.S. 92CA DETERMINING TOTAL INCOME OF 34,22,23,938/-AND RAISE D THE DEMAND. 4. AGGRIEVED BY THE ASSESSMENT ORDER THE ASSESSEE HAS FILED AN APPEAL WITH THE CIT(A). IN THE APPELLANT PROCEEDINGS, THE LD. A R OF THE ASSESSEE ARGUED THE GROUNDS REITERATED THE SUBMISSIONS AND INFORMATION OF ASSESSMENT PROCEEDINGS AND CONTESTED THAT THE LD. AO ERRED IN DISALLOWING EXPE NDITURE OF RS. 92,17,984/- INCURRED BY THE ASSESSEE COMPANY IN RESPECT OF SHAR ED SERVICE PAYMENTS TO BASC, MALAYSIA. AS PER THE AGREEMENT, BASF INDIA LTD (BI L) HAS OUTSOURCED THE ENTIRE PAYROLL FUNCTIONS TO BASC MALAYSIA RELATING TO CLER ICAL ACTIVITIES AND MANAGERIAL POSITION HAVE BEEN REORGANISED, FURTHER THE BASC IS ENGAGED IN THE BUSINESS OF PROVIDING SERVICES RELATING TO THE ACCOUNTING, BOOK KEEPING, PAYROLL GENERATION AND PAYROLL DATA MANAGING AND THESE SERVICE FUNCTIONS A RE NOT IN THE NATURE OF TECHNICAL SERVICES AS PER THE DTAA BETWEEN INDIA AND MALAYSIA . 5. FURTHER, THE BASC, MALAYSIA IS NOT PROVIDING ANY TECHNICAL SERVICES TO THE ASSESSEE, AS PER THE EXPLANATIONS 2 TO SECTION 9(1) (VII) OF THE ACT AND SERVICES ARE IN THE NATURE OF BUSINESS ACTIVITIES RENDERED IN MALAY SIA AND NOT TAXABLE U/S. 9(1)(I) OF :-5-: I.T.A. NOS. 650 & 651/MDS/2016 THE ACT, WERE THE INCOME FROM THESE SERVICES ARE NO T ACCRUED OR ARISE FROM ANY BUSINESS CONNECTION FROM INDIA. THE INCOME OF THE SERVICE PROVIDER IS TAXABLE IN INDIA ONLY WERE THE SUCH PROVIDER CARRIED BUSINESS OPERATIONS THROUGH PERMANENT ESTABLISHMENT (PE) IN INDIA. THE LD. AO RELIED ON THE JUDICIAL DECISIONS AND CAME TO CONCLUSION THAT INCOME OF THE NON RESIDENT ENTITY H AS ARISED IN INDIA AND SERVICES ARE UTILIZED IRRESPECTIVE OF THE SERVICES PHYSICALLY RE NDERED INDIA. THE MANAGERIAL SERVICES ARE NOT DEFINED IN THE ACT AND INCLUDES CO NTROL, DIRECTING, MANAGING OR ADMINISTRATING THE BUSINESS OR PART OF BUSINESS AND THE TERM TECHNICAL SERVICES WOULD MEAN SERVICE REQUIRING EXPERTISE IN TECHNOLOG Y AND THE NATURE OF SERVICES RENDERED BY BASC MALAYSIA IS NEITHER TECHNICAL OR M ANAGERIAL OR CONSULTANCY SERVICES AND THE PAYMENT ARE NOT SUBJECT TO DEDUCTION OF TAX / WITHHOLDING OF TAX AND PROVISIONS OF SECTION 40(A)(I) ARE NOT APPLICABLE A ND PRAYED FOR ALLOWING THE APPEAL. 6. THE LD. CIT(A) CONSIDERED THE GROUNDS AND SUBMIS SIONS AND THE FINDINGS OF THE ASSESSING OFFICER HAS DEALT ELABORATELY AT P AGE NO. 3 TO 9 OF HIS ORDER ON VARIOUS ASPECTS OF SERVICE AGREEMENTS AND FUNCTIONS OF ACCOUNTING AND THE SUBMISSIONS OF BY ASSESSEE IN THE APPELLANT PROCEED INGS THROUGH LETTERS REITERATING THAT THE PAYMENTS DOES NOT FALL WITHIN THE PURVIEW OF TECHNICAL SERVICE OR MANAGERIAL TECHNICAL OR CONSULTANCY FEE. THE LD. CIT(A) MADE T HE ANALYSIS ON THE HUMAN RESOURCE (HR) SERVICES AND CONSIDERED THE FACTS AND PROVISIONS AND FOUND THAT THE ASSESSEE COMPANY IS IN THE BUSINESS OF MANUFACTURE OF CATALYST AND OUTSOURCED ACCOUNTS AND HR SERVICES TO ITS ASSOCIATE BASC, MAL AYSIA WHICH ARE PURELY ADMINISTRATIVE SERVICES IN NATURE AND DOES NOT FIT INTO FTS U/S. 9(1)(VII) OF THE ACT. FURTHER, THE CIT(A) FOUND THAT THE SERVICES RENDERE D ARE IN THE NATURE OF DATA ENTRY :-6-: I.T.A. NOS. 650 & 651/MDS/2016 OPERATIONS AND RELIED ON HIGH COURT DECISIONS AND CONCLUDED THAT THE SERVICES CANNOT BE HELD AS MANAGERIAL OR CONSULTANCY OR TECH NICAL UNDER THE PROVISIONS OF SECTION 9(1)(VII) AND DIRECTED THE ASSESSING OFFICE R TO AMEND THE ASSESSMENT ORDER AND DELETE THE ADDITION AND ALLOWED THE APPEAL OF T HE ASSESSEE. 7. AGGRIEVED BY THE ORDER OF LD. CIT(A), REVENUE HA S FILED AN APPEAL BEFORE THE TRIBUNAL. THE LD. DR ARGUED THAT THE ORDER OF LD. CIT(A) IS ERRED IN DIRECTING ASSESSING OFFICER TO DELETE THE ADDITION MADE U/S. 40(A)(I) OF THE ACT AND THE FINDINGS THAT THE SERVICES ARE NOT IN THE NATURE OF MANAGERIAL, CONSULTANCY OR TECHNICAL U/S. 9(1)(VII) OF THE ACT AND THE LD. CIT (A) ERRED THAT THE ASSESSEE COMPANY IS ASSISTED BY FOREIGN COMPANY FOR PROFESSI ONAL CONSULTANCY SERVICES, WHICH REQUIRE HIGH DEGREE OF TECHNICAL EXPERTISE IN FINAN CIAL ACCOUNTING AND REQUIRES HIGH DEGREE OF SKILL AND REITERATED THE SUBMISSIONS ON T HE TERMS OF THE SERVICE AGREEMENT REFERRED IN ASSESSMENT ORDER. THE ASSESSEE COMPANY ENTERED INTO SERVICES DISCLOSED AT PARA 7.7 OF THE ASSESSMENT ORDER AND S UCH SERVICES ARE COVERED UNDER ARTICLE 13 OF DTAA INDIA-MALAYSIA AND SHALL BE TREA TED AS TECHNICAL SERVICES AND RELIED ON THE JUDICIAL DECISIONS AND PRAYED FOR SET TING ASIDE THE ORDER OF CIT(A). 8. CONTRA, THE LD. AR OF THE ASSESSEE ARGUED THAT THE SERVICES RENDERED BY THE MALAYSIA COMPANY ARE IN THE NATURE OF DATA OPER ATING AND THERE IS NO EXPERTISE OR HIGH DEGREE OF SKILL REQUIRED FOR OPERATIONS AND THE SERVICES ARE NOT IN THE NATURE OF FEE FOR TECHNICAL SERVICES OR MANAGERIAL SERVICE S COVERED U/S. 9(1)(VII) OF THE ACT. THE ERP HAS BEEN INSTALLED AS A TECHNOLOGY WITH AE MALAYSIA AND ONLY INSTRUCTIONS ARE PROVIDED FROM INDIA TO MALAYSIA (BASC) AND THE LD. AR SUPPORTED WITH THE DTAA :-7-: I.T.A. NOS. 650 & 651/MDS/2016 AGREEMENT APPLICABILITY UNDER ARTICLE 7 AND THE MAL AYSIA COMPANY PURELY RELIED ON THE TERMS OF AGREEMENT IN PROVIDING SERVICES AND TH E PROVISIONS OF SECTION 40(A)(I) ARE NOT APPLICABLE. FURTHER, THE SERVICES PROVIDED DOES NOT FALL WITHIN THE ARTICLE 13 OF DTAA AND THERE IS NOT PERMANENT ESTABLISHMENT (P E) OF MALAYSIA COMPANY IN INDIA AND FILED PAPER BOOK WITH DETAILS OF SERVICE S AGREEMENTS, SAMPLE INVOICES AND JOURNAL VOUCHERS AND PRAYED FOR DISMISSAL OF REVENU E APPEAL. 9. WE HEARD THE RIVAL SUBMISSIONS PERUSED THE MATE RIAL ON RECORD AND JUDICIAL DECISIONS, THE LD. AR SUBMITTED THAT ASSES SEE COMPANY HAS ENTERED INTO AGREEMENT WITH BASF-ASIA PACIFIC SERVICE CENTRE (BA SC), MALAYSIA FOR PROVIDING THE SERVICES OF FINANCIAL AND ACCOUNTING, HUMAN RESOURC E AND SUCH OTHER SERVICES FROM TIME TO TIME. THE FINANCIAL SERVICES INCLUDES ACCO UNTS PAYABLE AND ACCOUNTS RECEIVABLE AND OTHER FINANCIAL REPORTS AND WHERE AS HUMAN RESOURCE (HR) INCLUDES PAYROLL PROCESSING, SALARY PAYMENTS AND GENERAL LED GER POSTING, EMPLOYEE DATA ADMINISTRATION AND PROCESSING, TRAINING, ADMINISTRA TION AND OTHERS. THE ASSESSEE COMPANY HAS MADE PAYMENT TO THE MALAYSIA COMPANY FO R SERVICES RENDERED IN THE FINANCIAL YEAR AS PER THE AGREEMENT THESE PAYMENTS ARE NOT COVERED AS TECHNICAL SERVICES OR MANAGERIAL SERVICES TO BE TAXABLE FOR D EDUCTION OF TDS/WITHHOLDING OF TAX AND APPLICABILITY OF PROVISION OF 40(A)(I) OF THE A CT. 10. WHEREAS, THE LD. DR SUBMITTED THAT THESE SERVIC ES REQUIRE EXPERTISE AND HIGH DEGREE OF SKILLS ON FINANCIAL ACCOUNTING MANAG EMENT AND FALL WITHIN THE PROVISIONS OF SECTION 9(1)(VII) OF THE ACT AND LIAB LE FOR TDS. THE LD. AR FURTHER EXPLAINED THAT THE ASSESSEE HAS ENTERED INTO THE SE RVICE AGREEMENT WITH MALAYSIA COMPANY FOR RENDERING FINANCIAL ACCOUNTING SERVICES AND THE INFORMATION /DATA IS :-8-: I.T.A. NOS. 650 & 651/MDS/2016 SENT BY INDIAN COMPANY TO MALAYSIA AND THEY ENTER T HE DATA INFORMATION AND SUBMIT TO THE ASSESSEE COMPANY. THE LD. AR DEMONSTRATED W ITH COPY OF VOUCHERS FILED IN THE PAPER BOOK AT PAGE 36 AND INVOICE COPIES OF SER VICES AT PAGE 40 TO SUBSTANTIATE THAT THE SERVICES ARE IN THE NATURE OF DATA ENTRY O PERATIONS AND THERE IS NO EXPERTISE IS NECESSARY FOR MAKING SUCH TRANSACTIONS. WE ALSO PERUSED THE PROVISIONS OF SECTION 9(1)(VII) OF THE ACT WHERE THE FEES FOR TEC HNICAL SERVICES HAVE BEEN CONSIDERED AND THE SERVICES BEING INTERNATIONAL TRA NSACTION THE DTAA AGREEMENT BETWEEN INDIA AND MALAYSIA SHALL COME INTO EFFECT. IN ARTICLE 13 OF DTAA ' FEES FOR TECHNICAL SERVICES FOR SERVICES BEING RENDERING OF ANY MANAGERIAL, TECHNICAL OR CONSULTANCY SERVICES AND INCLUDES THE PROVISION OF SERVICES FOR TECHNICAL OR OTHER WHICH DOES NOT INCLUDE PAYMENT FOR SERVICES MENTION ED IN ARTICLE 15 , 16 OF THE AGREEMENT. 11. THE MALAYSIA COMPANY (BASC) PROVIDES SERVICES U NDER ARTICLE 13 R.W.S ARTICLE 5 AND ARTICLE 7OF DTAA. THE ARTICLE 5 DEAL WITH PERMANENT ESTABLISHMENT DEFINED AS THE FIXED PLACE OF BUSINESS THROUGH WHIC H THE BUSINESS OF ENTERPRISE IS WHOLLY OR PARTLY CARRIED ON. THE FACTS ARE NOT DIS PUTED BY THE REVENUE THAT THERE IS NO PE OF THE MALAYSIA COMPANY IN INDIA AND THE SERV ICES ARE RENDERED OUTSIDE THE COUNTRY. WHEREAS, THE ARTICLE 7 DEALS WITH THE PRO FITS OF ESTABLISHMENT TAXABLE THROUGH PE OF FOREIGN COMPANY HAVING OPERATIONS. C ONSIDERING THE APPARENT FACTS, PROVISIONS OF LAW, DTAA AND UNDISPUTED FACTS THAT T HERE IS NO PE IN INDIA AND THE SERVICES ARE IN THE NATURE OF DATA OPERATING ENTRY OF ACCOUNTS AND HUMAN RESOURCE (HR) SERVICE DULY SUPPORTED WITH EVIDENCE OF SAMPLE S INVOICES AND JOURNAL VOUCHER PRODUCED, WE FOUND THAT THE SERVICES OF BASC MALAYS IA DOES NOT FALL IN THE CATEGORY U/S. 9(1)(VII) OF THE ACT AND PROVISIONS OF SECTION 40(A)(I) ARE NOT APPLICABLE, WE :-9-: I.T.A. NOS. 650 & 651/MDS/2016 FOUND LD. CIT(A) HAS DEALT ON THIS DISPUTED ISSUE E XHAUSTIVELY IN HIS ORDER VIS-A-VIS EXPLANATIONS OF THE ASSESSEE AND PASSED REASONED OR DER IN TREATING THE SERVICES AS NOT IN THE NATURE OF TECHNICAL SERVICES AND PROVISI ON OF SECTION 40(A)(I) OF THE ACT ARE NOT APPLICABLE AND WE UPHOLD THE SAME AND DISMISS T HE REVENUE APPEAL. 12. SINCE, THE FACTS ARE SIMILAR IN THE APPEAL ITA NO. 650/MDS/2016 FOR ASSESSMENT YEAR 2009-10 THE REVENUE GROUNDS ARE DIS MISSED. 13. IN THE RESULT, THE REVENUE APPEAL ITA NO. 650/M DS/2016 OF ASSESSMENT YEAR 2009-10 AND ITA NO. 651/MDS/2016 OF ASSESSMENT YEAR 2010-11 ARE DISMISSED. ORDER PRONOUNCED ON THURSDAY, THE 10TH DAY OF NOVEM BER, 2016 AT CHENNAI. SD/ - ( ) (CHANDRA POOJARI) / ACCOUNTANT MEMBER SD/ - ( . ) (G. PAVAN KUMAR) # /JUDICIAL MEMBER /CHENNAI, 0 /DATED: 10TH NOVEMBER, 2016 JPV & )'23 43 /COPY TO: 1. % /APPELLANT 2. )*% /RESPONDENT 3. 5 ( )/CIT(A) 4. 5 /CIT 5. 3 )'' /DR 6. 9 /GF.