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Whether the metal scrap o waste generated whilst repairing of worn out machineries or parts of cement manufacturing plant amounts to manufacture, and thereby, is excisable to excise duty. ?=the metal scrap and waste arising out of the repair and maintenance work of the machinery used in manufacturing of cement, by no stretch of imagination, can be treated as a subsidiary product to the cement which is the main product. The metal scrap and waste arise only when the assessee undertakes repairing and maintenance work of the capital goods and, therefore, do not arise regularly and continuously in the course of a manufacturing business of cement.

Central Excise India

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 REPORTABLE

 IN THE SUPREME COURT OF INDIA

 CIVIL APPELLATE JURISDICTION

 CIVIL APPEAL NO. 7453 OF 2008

M/s. Grasim Industries Ltd. .............. Appellant

 versus

Union of India ...........Respondent

 J U D G M E N T

H.L. Dattu, J.

1) This appeal is directed against the Judgment and 

 Order dated 31.07.2008 of the High Court of Judicature of 

 Rajasthan in Central Excise Appeal No. 60/2006. By the 

 impugned Order, the High Court has set aside the Order 

 dated 09.08.2005 of the Customs, Excise and Service Tax 

 Appellate Tribunal [hereinafter referred to as "the Tribunal"] 

 whereby the Tribunal had dropped the entire duty demand 

 and penalty imposed on the assessee. 

 1

2) The issue before us is: Whether the metal scrap or 

 waste generated whilst repairing of worn out machineries or 

 parts of cement manufacturing plant amounts to 

 manufacture, and thereby, is excisable to excise duty. 

3) The assessee is the manufacturer of the white cement. 

 The assessee repairs worn out machineries or parts of the 

 cement manufacturing plant at its workshop such as 

 damaged roller, shafts and coupling with the help of welding 

 electrodes, mild steel, cutting tools, M.S. Angles, M.S. 

 Channels, M.S. Beams, etc. In this process of repair certain 

 metal scrap or waste is generated. In a surprise inspection 

 conducted by the officials of the Central Range-II, Jodhpur, 

 it was found that the assessee has cleared various types of 

 metal scrap and waste without the payment of the excise 

 duty for the period from 1.10.1995 to 16.07.1999. A show 

 cause notice dated 05.10.2000 was issued to the assessee 

 demanding a duty of ` 10,81,736/- under Section 11A of the 

 Central Excise Act, 1944 [hereinafter referred to as "the 

 Act"] along with equal amount of penalty under Section 

 11AC of the Act and further penalty under Rule 173 Q of the 

 Central Excise Rules, 1944 [hereinafter referred to as "the 

 2

Rules"] for non-payment of excise duty on clearance of said 

metal scrap and waste. On the request of the assessee on two 

occasions, the revenue has granted extension of time, first up 

to 31.12.2000 which was further extended till 22.01.2001, in 

order to reply to the said show cause notice. Thereafter, the 

assessee further made a request for some more time to file 

reply vide letter dated 20.01.2001, the same was rejected 

whilst confirming the duty demanded and penalty proposed 

in the show cause notice vide Order dated 08.02.2001 of the 

Additional Commissioner. The assessee filed appeal before 

the Commissioner (Appeals), Jaipur. The Commissioner 

(Appeals) vide its Order dated 30.04.2004, set aside the 

demand of duty along with equal amount of penalty 

pertaining to scrap and waste arising out of the dismantling 

of used capital goods and the packing materials to the extent 

of ` 6,05,955/-. The Commissioner (Appeals) also set aside 

the demand of penalty under Rule 173Q(1)(a) of the Rules, 

whilst, upholding the demand of duty and equal amount of 

penalty of ` 4,75,781 under Section 11AC of the Act on 

metal scrap and waste generated during course of repair and 

maintenance of the machinery or parts of the plant on the 

ground that such metal scrap and waste has been generated 

 3

during mechanical working of metal in the workshop, as 

contemplated by the definition of the waste and scrap under 

Section Note 8(a) of Section XV of the Central Excise Tariff 

Act, 1985 [hereinafter referred to as "the Tariff Act"] and, in 

view of the decision of the Tribunal in Budhewala Co-op. 

Sugar Mills Ltd. vs. CCE, Chandigarh-I, 2002 (141) ELT 

490 (Tri. Delhi). Being aggrieved by the portion of the 

Order of the Commissioner (Appeals), pertaining to 

confirmation of demand of duty along with equal amount of 

penalty of ` 4,75,781 on the metal scrap and waste generated 

during repair of machinery, the assessee preferred an appeal 

before the Tribunal. The Tribunal, vide its Order dated 

09.08.2005, allowed the appeal and set aside the demand of 

duty and penalty confirmed by the said portion of the Order 

of the Commissioner (Appeals) on the ground that metal 

scrap and waste cleared by the assessee does not arise out of 

any manufacturing activity and, thereby, not excisable to any 

excise duty in view of the decision of the Tribunal in CCE v. 

Birla Corpn. Ltd., 2005 (181) ELT 263. The Revenue, 

aggrieved by this Order, filed an appeal under Section 35G 

of the Act before the High Court of Rajasthan. The High 

Court, vide its Judgment and Order dated 31.07.2008, 

 4

 allowed the appeal, set aside the Order of the Tribunal and 

 restored the Order of the Commissioner (Appeals) on the 

 ground that the generation of scrap amounts to manufacture 

 as it is incidental or ancillary to the manufacture of spare or 

 replaceable part. The spare or replaceable part comes into 

 existence as distinct product during the repairing of the parts 

 of the cement plant. Also, the generation of scrap need not 

 be in the process of manufacture of the excisable end 

 product such as cement. Being aggrieved, the assessee has 

 filed this appeal under Section 35L of the Act against the 

 judgment and order of the High Court.

4) Shri. Alok Yadav, learned counsel has appeared for 

 the assessee and the Revenue is represented by Shri. B. 

 Bhattacharyya, learned Additional Solicitor of India. We 

 will refer to their submissions while dealing with the issue 

 canvassed before us.

5) Learned counsel Shri. Alok Yadav submits that the 

 Revenue has wrongly relied on the definition of the metal 

 waste and scrap under Note 8 (a) to Section XV of the Tariff 

 Act which states- `Metal waste and scrap from the 

 manufacture or metal waste and scrap from mechanical 

 5

working of metal' in order to establish that metal scrap and 

waste arising out of the repairing and maintenance of the 

various machinery or parts of the cement manufacturing 

plant amounts to manufacture of such scrap and waste. He 

submits that nowhere the definition of waste and scrap in the 

said Note deems it to be manufacturing process. In other 

words, the definition of `waste and scrap' only gives 

coverage of the entry `waste and scrap' under Chapter 72.04 

of the Schedule to the Tariff Act and does not ipso facto lead 

to a conclusion that waste and scrap arising by the 

mechanical working of metal amounts to a process of 

manufacture in terms of Section 2(f) of the Act in order to 

attract the charging Section. He further submits that unless 

the particular excisable product falling under the particular 

tariff entry is manufactured in the sense of Section 2 (f) of 

the Act, it does not entail or attract the operation of the 

charging Section under Section 3 of the Act. Learned 

counsel refers to the wordings of the definition of the 

manufacture under Section 2(f) of the Act and relies on the 

decision of this Court in Union of India v. Delhi Cloth and 

General Mills Co. Ltd., AIR 1963 SC 791 in support of his 

submission that the High Court, vide its impugned judgment, 

 6

 has grossly erred in observing that any incidental or ancillary 

 process to the completion of any manufactured product, 

 which itself need not be end product or excisable goods, 

 would amount to manufacture and is excisable. In other 

 words, such observation of the High Court creates very 

 anomalous situation by conferring the status of manufacture 

 on every process incidental and ancillary to any 

 manufactured product which itself need not be excisable 

 manufactured end product. Learned counsel submits, by 

 placing reliance on several decisions of this Court in order to 

 buttress his contention, that the excise duty mentioned under 

 the tariff entry for the excisable goods cannot be levied in 

 terms of charging Section 3 unless such excisable goods or 

 items are produced and manufactured. In other words, the 

 event of levying of excise duty under the charging Section 3 

 is the manufacture of the excisable goods. Learned counsel 

 concludes that the manufacture of the excisable goods in 

 terms of Section 2 (f) is the prerequisite to levy excise duty.

6) Per Contra, Shri. B. Bhattacharyya, learned ASG, 

 submits that the metal scrap and waste are indisputably 

 excisable goods under Section 2(d) of the Act falling under 

 7

 the Chapter heading 72.04 read with Note 8 (a) to the 

 Section XV of the Tariff Act. He further submits that metal 

 scrap and waste as excisable goods are generated during the 

 repair and replacement of the old machinery or parts of the 

 cement manufacturing plant, which is incidental and 

 ancillary to the manufactured product, that is, cement. In 

 other words the process of generation of scrap and waste 

 amount to the manufacture in terms of Section 2(f) of the 

 Act. In support of his contention, learned ASG has relied on 

 the decision of this Court in CST v. Bharat Petroleum 

 Corpn. Ltd., (1992) 2 SCC 579. He further submits that once 

 the conditions or requirements of excisable goods and 

 manufacture as envisaged by Section 2(d) and Section 2(f), 

 respectively, of the Act are satisfied, then only, such metal 

 scrap and waste would attract the levy of excise duty under 

 the charging Section 3 of the Act. Shri. B. Bhattacharyya has 

 cited several decisions of this Court in support of his 

 submission.

7) We have heard the learned counsel for the parties. In 

 the present case, the assessee had undertook repair and 

 maintenance work of his worn out old machinery or parts of 

 8

the cement manufacturing plant for the period between 1995 

to 1999. The assessee repaired machinery or capital goods 

such as damaged roller, shafts and coupling by using 

welding electrodes, mild steel, cutting tools, M.S. Angles, 

M.S. Channels, M.S. Beams etc. In this process of repair and 

maintenance, M.S. Scrap and Iron Scrap were generated in 

the workshop. It is not in dispute that these M.S. Scrap and 

Iron Scrap are excisable goods under Section 2(d) of the Act 

falling under the Chapter heading 72.04 in the Schedule to 

the Tariff Act read with Note 8 (a) to Section XV of the 

Tariff Act as `metal scrap and waste'. We are of the opinion 

that Section Note has very limited purpose of extending 

coverage to the particular items to the relevant tariff entry in 

the Schedule for determining the applicable rate of duty and 

it cannot be readily construed to have any deeming effect in 

relation to the process of manufacture as contemplated by 

Section 2(f) of the Act, unless expressly mentioned in the 

said Section Note. In Shyam Oil Cake Ltd. v. CCE, (2005) 1 

SCC 264, this Court has held:

 "16. Thus, the amended definition enlarges the 

 scope of manufacture by roping in processes which 

 may or may not strictly amount to manufacture 

 provided those processes are specified in the 

 9

section or chapter notes of the tariff schedule as 

amounting to manufacture. It is clear that the 

legislature realised that it was not possible to put in 

an exhaustive list of various processes but that 

some methodology was required for declaring that 

a particular process amounted to manufacture. The 

language of the amended Section 2(f) indicates that 

what is required is not just specification of the 

goods but a specification of the process and a 

declaration that the same amounts to manufacture. 

Of course, the specification must be in relation to 

any goods.

 ...

23. We are in agreement with the submission that 

under the amended definition, which is an inclusive 

definition, it is not necessary that only in the 

section or chapter note it must be specified that a 

particular process amounts to manufacture. It may 

be open to so specify even in the tariff item. 

However, either in the section or chapter note or in 

the tariff entry it must be specified that the process 

amounts to manufacture. Merely setting out a 

process in the tariff entry would not be sufficient. If 

the process is indicated in the tariff entry, without 

specifying that the same amounts to manufacture, 

then the indication of the process is merely for the 

purposes of identifying the product and the rate 

which is applicable to that product. In other words, 

for a deeming provision to come into play it must 

be specifically stated that a particular process 

amounts to manufacture. In the absence of it being 

so specified the commodity would not become 

excisable merely because a separate tariff item 

exists in respect of that commodity.

24. In this case, neither in the section note nor in 

the chapter note nor in the tariff item do we find 

any indication that the process indicated is to 

amount to manufacture. To start with, the product 

was edible vegetable oil. Even after refining, it 

remains edible vegetable oil. As actual manufacture 

has not taken place, the deeming provision cannot 

 10

 be brought into play in the absence of it being 

 specifically stated that the process amounts to 

 manufacture."

8) The goods have to satisfy the test of being produced or 

 manufactured in India. It is settled law that excise duty is a 

 duty levied on manufacture of goods. Unless goods are 

 manufactured in India, they cannot be subjected to payment 

 of excise duty. Simply because a particular item is 

 mentioned in the First Schedule, it cannot become exigible 

 to excise duty. [See Hyderabad Industries Ltd. v. Union of 

 India, (1995) 5 SC 338, Moti Laminates (P) Ltd. v. CCE, 

 (1995) 3 SCC 23, CCE v. Wimco Ltd., (2007) 8 SCC 412] 

 Therefore, both on authority and on principle, for being 

 excisable to excise duty, goods must satisfy the test of being 

 produced or manufactured in India. In our opinion, the 

 charging Section 3 of the Act comes into play only when the 

 goods are excisable goods under Section 2(d) of the Act 

 falling under any of the tariff entry in the Schedule to the 

 Tariff Act and are manufactured goods in the terms of 

 Section 2(f) of the Act. Therefore, the conditions 

 contemplated under Section 2(d) and Section 2(f) has to be 

 satisfied conjunctively in order to entail imposition of excise 

 11

duty under Section 3 of the Act. The manufacture in terms 

of Section 2(f) includes any process incidental or ancillary to 

the completion of the manufactured product. This `any 

process' can be a process in manufacture or process in 

relation to manufacture of the end product, which involves 

bringing some kind of change to the raw material at various 

stages by different operations. The process in manufacture 

must have the effect of bringing change or transformation in 

the raw material and this should also lead to creation of any 

new or distinct and excisable product. The process in 

relation to manufacture means a process which is so 

integrally connected to the manufacturing of the end product 

without which, the manufacture of the end product would be 

impossible or commercially inexpedient. This Court has in 

several decisions starting from Tungabhadra Industries v. 

CTO, AIR 1961 SC 412, Union of India v. Delhi Cloth & 

General Mills Co. Ltd., AIR 1963 SC 791, South Bihar 

Sugar Mills Ltd. v. Union of India, AIR 1968 SC 922 and in 

line of other decisions has explained the meaning of the 

word `manufacture' thus: 

 "14. The Act charges duty on manufacture of 

 goods. The word `manufacture' implies a change 

 12

 but every change in the raw material is not 

 manufacture. There must be such a transformation 

 that a new and different article must emerge 

 having a distinctive name, character or use."

9) In Ujagar Prints (II) v. Union of India, (1989) 3 SCC 488, 

 this Court has laid down the test to ascertain whether 

 particular process amounts to manufacture:

 "whether the change or the series of changes 

 brought about by the application of processes take 

 the commodity to the point where, commercially, it 

 can no longer be regarded as the original 

 commodity but is, instead, recognised as a distinct 

 and new article that has emerged as a result of the 

 processes" 

10) In Hindustan Polymers v. CCE, (1989) 4 SCC 323, this 

 Court has observed: 

 "11. Excise duty is a duty on the act of 

 manufacture. Manufacture under the excise law, is 

 the process or activity which brings into being 

 articles which are known in the market as goods 

 and to be goods these must be different, 

 identifiable and distinct articles known to the 

 market as such. It is then and then only that 

 manufacture takes place attracting duty. In order 

 to be goods, it was essential that as a result of the 

 activity, goods must come into existence. For 

 articles to be goods, these must be known in the 

 market as such and these must be capable of being 

 sold or are being sold in the market as such. In 

 order, therefore, to be manufacture, there must be 

 activity which brings transformation to the article 

 in such a manner that different and distinct article 

 13

 comes into being which is known as such in the 

 market."

11) In CCE v. Rajasthan State Chemical Works, (1991) 4 

 SCC 473, this Court has considered the meaning of process 

 in relation to manufacture as thus: 

 "12. Manufacture implies a change but every 

 change is not manufacture, yet every change of an 

 article is the result of treatment, labour and 

 manipulation. Naturally, manufacture is the end 

 result of one or more processes through which the 

 original commodities are made to pass. The nature 

 and extent of processing may vary from one class 

 to another. There may be several stages of 

 processing, a different kind of processing at each 

 stage. With each process suffered the original 

 commodity experiences a change. Whenever a 

 commodity undergoes a change as a result of some 

 operation performed on it or in regard to it, such 

 operation would amount to processing of the 

 commodity. But it is only when the change or a 

 series of changes takes the commodity to the point 

 where commercially it can no longer be regarded 

 as the original commodity but instead is 

 recognised as a new and distinct article that a 

 manufacture can be said to take place.

 13. Manufacture thus involves a series of 

 processes. Process in manufacture or in relation to 

 manufacture implies not only the production but 

 the various stages through which the raw material 

 is subjected to change by different operations. It is 

 the cumulative effect of the various processes to 

 which the raw material is subjected (sic that the) 

 manufactured product emerges. Therefore, each 

 step towards such production would be a process 

 in relation to the manufacture. Where any 

 14

 particular process is so integrally connected with 

 the ultimate production of goods that but for that 

 process manufacture or processing of goods would 

 be impossible or commercially inexpedient, that 

 process is one in relation to the manufacture.

 14. The natural meaning of the word `process' is a 

 mode of treatment of certain materials in order to 

 produce a good result, a species of activity 

 performed on the subject-matter in order to 

 transform or reduce it to a certain stage. 

 According to Oxford Dictionary one of the 

 meanings of the word `process' is a `continuous 

 and regular action or succession of actions taking 

 place or carried on in a definite manner and 

 leading to the accomplishment of some result'. The 

 activity contemplated by the definition is perfectly 

 general requiring only the continuous or quick 

 succession. It is not one of the requisites that the 

 activity should involve some operation on some 

 material in order to (sic effect) its conversion to 

 some particular stage. There is nothing in the 

 natural meaning of the word `process' to exclude 

 its application to handling. There may be a 

 process which consists only in handling and there 

 may be a process which involves no handling or 

 not merely handling but use or also use. It may be 

 a process involving the handling of the material 

 and it need not be a process involving the use of 

 material. The activity may be subordinate but one 

 in relation to the further process of manufacture."

12) In Union of India v. Ahmedabad Electricity Co. Ltd., 

 (2003) 11 SCC 129, the issue before this Court was that 

 whether the process in which cinder is produced by burning 

 of coal as a fuel for producing steam to run machines used in 

 15

the factory to manufacture end product amounts to 

manufacture. This Court has held:

 "19. What is the meaning of "manufacture" in the 

 context of excise law? We have already quoted the 

 definition of the word "manufacture" as contained 

 in Section 2(f) of the Act. According to this 

 definition, manufacture includes any process 

 incidental or ancillary to the completion of a 

 manufactured product. The word "manufacture" 

 used as a verb is generally understood to mean as 

 bringing into existence a new substance. It does 

 not mean merely to produce some change in a 

 substance. To quote from a passage in the 

 Permanent Edition of Words and Phrases, Vol. 

 XXVI

 "manufacture implies a change, but every 

 change is not manufacture and yet every change 

 of an article is the result of treatment, labour and 

 manipulation. But something more is necessary 

 and there must be transformation: a new and 

 different article must emerge having a distinctive 

 name, character or use".

 "Manufacture" may involve various processes. 

 The aim of any manufacturing activity is to 

 achieve an end product. Depending on the nature 

 of manufacturing activity involved, processes 

 may be several or one. The natural meaning of 

 the word "process" is a mode of treatment of 

 some material in order to produce a good result. 

 Every process which is incidental or ancillary to 

 the completion of manufactured product is 

 included within the meaning of manufacture. The 

 word "process" has not been defined in the Act. 

 In its ordinary meaning "process" is a mode of 

 treatment of certain material in order to give a 

 desired shape to the material. It is an activity 

 performed on a given material in order to 

 transform it into something."

 16

 This Court further observed thus:

 "27. In the case in hand also, coal which leads to 

 production of cinder is not used as a raw material 

 for the end product. It is being used only for 

 ancillary purpose, that is, as a fuel. Therefore, 

 irrespective of the fact whether any manufacture is 

 involved in the production of cinder it should be 

 held to be out of the tax net for the reason that it is 

 not a raw material for the end product.

 28. In producing "cinder", there is no 

 manufacturing process involved. Coal is simply 

 burnt as fuel to produce steam. Coal is not 

 tampered with, manipulated or transformed into the 

 end product. For purposes of manufacture the raw 

 material should ultimately get a new identity by 

 virtue of the manufacturing process either on its 

 own or in conjunction or combination with other 

 raw materials. Since coal is not a raw material for 

 the end product in all the cases before us, the 

 question of getting a new identity as an end product 

 due to manufacturing process does not arise."

13) In Commissioner of Central Excise, Chennai II 

 Commissionerate v. Tarpaulin International, (2010) 9 SCC 

 103, whilst addressing the issue whether the process of 

 preparing tarpaulin made-ups by cutting and stitching the 

 tarpaulin fabric and fixing the eyelets would amount to 

 manufacture, this Court has held:

 "25. Is there any manufacture when tarpaulin 

 sheets are stitched and eyelets are made? In our 

 view, it does not change the basic characteristic of 

 the raw material and end product. The process does 

 17

 not bring into existence a new and distinct product 

 with total transformation in the original 

 commodity. The original material used i.e. the 

 tarpaulin is still called tarpaulin made-ups even 

 after undergoing the said process. Hence, it cannot 

 be said that the process is a manufacturing process. 

 Therefore, there can be no levy of Central excise 

 duty on the tarpaulin made-ups. The process of 

 stitching and fixing eyelets would not amount to 

 manufacturing process, since tarpaulin after 

 stitching and eyeleting continues to be only cotton 

 fabric. The purpose of fixing eyelets is not to 

 change the fabric. Therefore, even if there is value 

 addition the same is minimum. To attract duty there 

 should be a manufacture to result in different goods 

 and the goods sought to be subject to duty should 

 be known in the market as such."

14) In the present case, it is clear that the process of repair 

 and maintenance of the machinery of the cement 

 manufacturing plant, in which M.S. scrap and Iron scrap 

 arise, has no contribution or effect on the process of 

 manufacturing of the cement, which is the excisable end 

 product, as since welding electrodes, mild steel, cutting 

 tools, M.S. Angles, M.S. Channels, M.S. Beams etc. which 

 are used in the process of repair and maintenance are not raw 

 material used in the process of manufacturing of the cement, 

 which is the end product. The issue of getting a new identity 

 as M.S. Scrap and Iron Scrap as an end product due to 

 manufacturing process does not arise for our consideration. 

 18

 The repairing activity in any possible manner cannot be 

 called as a part of manufacturing activity in relation to 

 production of end product. Therefore, the M.S. scrap and 

 Iron scrap cannot be said to be a by-product of the final 

 product. At the best, it is the by-product of the repairing 

 process which uses welding electrodes, mild steel, cutting 

 tools, M.S. Angles, M.S. Channels, M.S. Beams etc. 

15) Learned ASG has placed reliance on the decision of this 

 Court in CST v. Bharat Petroleum Corpn. Ltd., (Supra). In 

 that case, the assessee purchased sulphuric acid and cotton 

 for the manufacturing of kerosene and yarn/cloth. In the 

 manufacturing process, the acid sludge and cotton waste 

 emerged as a distinct product having commercial identity. 

 The issue before this Court was that whether the assessee 

 can be said to manufacture acid sludge and cotton waste. 

 This Court observed that where a subsidiary product is 

 turned out regularly and continuously in the course of a 

 manufacturing business and is also sold regularly from time 

 to time, an intention can be attributed to the manufacturer to 

 manufacture and sell not merely the main item manufactured 

 but also the subsidiary products. We are afraid, the decision 

 19

 does not help the Revenue because the metal scrap and waste 

 arising out of the repair and maintenance work of the 

 machinery used in manufacturing of cement, by no stretch of 

 imagination, can be treated as a subsidiary product to the 

 cement which is the main product. The metal scrap and 

 waste arise only when the assessee undertakes repairing and 

 maintenance work of the capital goods and, therefore, do not 

 arise regularly and continuously in the course of a 

 manufacturing business of cement.

16) In view of the above, we cannot sustain the Judgment 

 and Order of the High Court dated 31.07.2008.

17) In the result, the appeal is allowed and the impugned 

 Judgment and the Order of the High Court is set aside and 

 the Order dated 09.08.2005 of the Tribunal is restored. 

 Costs are made easy.

 ................................................J.

 [H.L. DATTU]

 ................................................J.

 [CHANDRAMAULI KR. PRASAD]

 New Delhi,

 October 13, 2011. 20
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