New Rules For Appointment Of Tribunal Members Encroaches Upon Judicial Independence And Also Is Non-Compliant With The Guidelines Issued By The Supreme Court

Snehal Kanzarkar, a law student, has analyzed the new rules enacted for appointment of the Members of the Tribunal. She has argued that the new rules do not comply with the guidelines laid down by the Hon’ble Supreme Court as regards the qualifications, experience and other conditions for appointment to tribunals. She has also claimed that the rules encroach upon judicial independence and are not in compliance with the law relating to separation of powers. She has requested that requisite changes should be made to the rules so as to make them compliant with the guidelines issued by the Supreme Court

Deliberate Defiance: Tribunal, Appellate Tribunal and other Authorities (Qualifications, Experience and other Conditions of Service of Members) Rules, 2020

The appointment of the Judges of Tribunal was regulated by the Tribunal, Appellate Tribunal and other Authorities (Qualifications, Experience and other Conditions of Service of Members) Rules, 1963. The government replaced these rules with the Tribunal, Appellate Tribunal and other Authorities (Qualifications, Experience and other Conditions of Service of Members) Rules, 2017 to incorporate changes in the qualification, salary, selection, appointment and other aspects of the appointment of judges to the ITAT and AAR.

The 2017 rules were challenged in the Supreme Court and were quashed by the Court. (Rojer Mathew v. South India Bank and Another, AIR 2015 SC 1571). The Court directed the Central Government to formulate new rules. Thus, the Tribunal, Appellate Tribunal and other Authorities (Qualifications, Experience and other Conditions of Service of Members) Rules, 2020 were notified by the Central Government. This article analyses the changes in the above-mentioned rules in context of the Income Tax Appellate Tribunal and the Authority of Advance Ruling.

A. Income Tax Appellate Tribunal

1. Eligibility Criteria

1.1. The eligibility criteria remain the same for the President and Vice-President across the 2017 and 2020 rules. While the 1963 rules and the 2017 rules have the same qualification requirements for a person to be appointed as a judicial member, 2020 rules have a modified the qualification criteria for the appointment of a judicial member. Earlier (1963 and 2017) a person who had held “judicial office” for 10 years was eligible. The 2020 rules have further narrowed the eligibility criteria. According to these rules, a person who has served as a district judge or additional district judge for 10 years. Any other judicial officer is not eligible under these rules. Secondly, a person who has practiced as an advocate for 10 years was qualified to be considered for this position (1963 and 2017). Now, the number of years of practice as an advocate have been increased to 25 years to be qualified to be considered for this position.

1.2. A person who has practiced as an CA for 10 years was qualified to be considered for appointment as Accountant member (1963 and 2017). Now, the number of years of practice as a CA have been increased to 25 years to be qualified to be considered for this position. Secondly, a person who had been appointed as a member of Indian Income Tax service Group A and served for 3 years as ACIT was qualified to be considered for this position (1963 and 2017). But the qualification criteria have been increased in the 2020 rules. Now, a person has to be appointed as a member of IRS (Group A) and should have held the position of PCIT for 2 years and has been involved in adjudicatory, judicial or quasi-judicial work. 

1.3. The modified criteria for the advocates and chartered accountants coupled with the short tenure and no scope of reappointment can be discouraging for the practicing advocates and CAs to leave their flourishing practice to become members for 4 years. Neither can they cannot practice before the ITAT thereafter, nor do they have reasonable chances of being appointed as High court judges. They do not have any incentive serve as a member in the ITAT. Further, the eligibility criteria for lawyers to apply for High Courts is 10 years practice in the High Court where a judge is appointed till the age of retirement. The standard being set at 25 years of practice for ITAT memberswith a short tenure of 4 years and no option of reappointment seems unreasonable. The minimum years of practice should be reduced back to 10 years. This will attract young lawyers to join the tribunal.

2. Retirement Age and Tenure

2.1. President

  • The 1963 rules had specified a retirement age of 65 years, but no tenure was specified. Thus, a person appointed under the 1963 rules would serve in the capacity of president till the attainment of the age of 65 years.
  • The 2017 rules specified a tenure of 3 years and the age of retirement was the same i.e. 65 years. A member would retire after 3 years or on the date of the attainment of age of 65 years, whichever is earlier.
  • The 2020 rules increased the tenure to 4 years and the age of retirement to 70 years.The president appointed under these rules would retire either at the attainment of the age of 70 or at the completion of tenure of 4 years, whichever is earlier.

2.2. Vice-President

  • The 1963 rules had specified a retirement age of 62 years, but no tenure was specified. Thus, a person appointed under the 1963 rules would serve in the capacity of vice- president till the attainment of the age of 62 years.  
  • The 2017 rules specified a tenure of 3 years and the age of retirement was the same i.e. 62 years. A vice-president would retire after 3 years or on the date of the attainment of age of 62 years, whichever is earlier.
  • The 2020 rules increased the tenure to 4 years and the age of retirement to 65 years. The vice- president appointed under these rules would retire either at the attainment of the age of 65 or at the completion of tenure of 4 years, whichever is earlier. 

2.3. Judicial Member and Accountant member

  • The 1963 rules had specified a retirement age of 62 years, but no tenure was specified. Thus, a person appointed under the 1963 rules would serve in the capacity of member till the attainment of the age of 62 years.
  • The 2017 rules specified a tenure of 3 years and the age of retirement was the same i.e. 62 years. A member would retire after 3 years or on the date of the attainment of age of 62 years, whichever is earlier.
  • The 2020 rules increased the tenure to 4 years and the age of retirement to 65 years. The member appointed under these rules would retire either at the attainment of the age of 65 or at the completion of tenure of 4 years, whichever is earlier.

2.4. The Hon’ble Supreme Court explicitly stated in its decision in Rojer Mathew v. South India Bank and Another, AIR 2015 SC 1571and L. Chandra Kumar v. Union of India [ (1997) 3 SCC 261] that the term of the members of the tribunals should be “seven or five years subject to eligibility for reappointment for one more term”. The tenure of the members should be extended till the age of retirement for multiple reasons.

  • Firstly, due to the specialized and technical nature of income tax it takes a longer period for a person appointed as a member to understand and master the duties as a member of the ITAT and after attaining such expertise it would be important for such a member to serve as a member of ITAT for its increased efficiency and productivity.
  • Secondly, a longer tenure is required for the members of ITAT because the essential nature of ITAT is different from other tribunals. It is different simply by the reason that the administrative tribunals are established under Article 323 A of the Constitution and ITAT is amongst the specialized tribunals established under Article 323B. Further, ITAT is different in composition from other tribunals because of the requirement of appointment of the technical members for the adjudication process.
  • Thirdly, the increased tenure will increase the chances of the member for appointment to the post of vice-president and hence, act as an incentive for the eligible people to serve as ITAT members.

2.5. The tenure basis appointment and the absence of reappointment clause was brought in the 2017 rules which were quashed by the Hon’ble Supreme Court in the Rojer Mathew case (Supra) and reinstated in the 2020 rules. In context of the tenure, the 2020 rules have incorporated mere surface changes and have failed to incorporate the guidelines of the Hon’ble Supreme Court in the Rojer Mathew case (Supra). The guidelines regarding tribunals have been suggested by the Hon’ble Supreme Court in various cases i.e. L. Chandra Kumar case (Supra) and Rojer Mathew case (Supra), but the legislation hasn’t incorporated the guidelines in the legislations made thereafter. According to the 1963 rules, which were in effect prior to the enactment of the 2017 rules, a member would be appointed till the age of retirement. The members should be appointed till the age of retirement as this will be good for the productivity and efficiency of the ITAT and will also be a great incentive for prospective candidates.

3. Search-cum-selection committee

3.1. The members of this committee included the Chief Justice of India (or a sitting Supreme Court judge appointed by him), the president of ITAT and the secretary of Ministry of Law and Justice.

3.2. The 2017 rules modified the members to be appointed in this committee. Separate members were to be nominated for determining the appointment of the President and the Vice-president. The number of members from the Executive have been increased in this committee, thus, increasing the government participation and control in the appointment process.

3.3. The 2020 rules have still retained the high number of members from the executive in the search-cum-selection committee.

3.4. There should be judicial dominance in the selection committee of the members for ensuring the independence of the judiciary. This non-interference of executive and legislation in the process of the appointment, transfers, etc. of the judiciary has been held to be a pre-requisite for ensuring judicial independence and hence, impartial decision making in various landmark decisions of the Hon’ble Supreme Court, which include but are not limited to, S.P. Gupta v. UOI [AIR 1982 SC 149]; Supreme Court Advocates-on-Record Association v. UOI[(2015) AIR SCW5457];  In re Special Reference 1 of 1998 (Procedure Regarding Appointment of Supreme Court and High Court Judges)[AIR 1999 SC 1]; Rojer Mathew (Supra) and L. Chandra Kumar (Supra). Further, the government is the biggest litigator in the cases before ITAT. Representatives of government participating in the process of the selection of the members, who would preside over the cases between the government and the assesses, would lead to a conflict of interest. Hence, the government should not be involved in the process of the selection of the members because justice should not only be done but should also be seen to be done. Thus, the search and selection committee should be comprised of judges only.

4. Salary

4.1. The salary of Rs. 80000/- per month (under 1963 rules) for the President has been revised and increased to Rs. 2,50,000/-per month. The same amount has been included in the 2020 rules as salary.

4.2. The salary of Rs. 80000/- per month (under 1963 rules) for the Vice-Presidents and Members has been revised and increased to Rs. 2,25,000/-per month. The same amount has been included in the 2020 rules as salary.

4.3. The new rules will not affect the salary, retirement age, tenure or any other thing covered under the rules for the president, vice-president and members. They will be governed by the rules under which they were appointed. The salary of the members is a part of the features recognized by the Hon’ble Supreme Court as a part of the aspects of the judicial appointments which should be free from/ should involve minimum government interference to ensure judicial independence in Rojer Mathew case (Supra). The funding of the tribunal should not be derived from the ministry it is attached to. The tribunal is under the Ministry only for administrative purposes and this should not affect the judicial wisdom of the tribunal. While the non-interference of the executive in the appointment and transfers of the judges ensures the individual independence of the judges to discharge their duties without fear or favor, the independent trust/ fund be setup for the purpose of finances of the tribunal will ensure the institutional independence of judiciary. {Supreme Court Advocates on Record Association and Another v. Union of India (2016) 5 SCC 1}.

5. Interpretation

5.1. The absence of Interpretation clause in the 2020 rules can be indicative of the fact that that in case of an ambiguity arising under these rules, the opinion of the Central Government will not be considered but judicial decision will be final.The absence of this clause in the 2020 rules implies that in case of any ambiguity in the interpretation of the rules, the decision of the court will be the deciding factor.

6. Savings Clause

6.1. The 1963 rules and the 2017 rules had a savings clause incorporated within them. This clause regulated the power of the government to make exceptions to these rules for a specific class of people such as scheduled caste, scheduled tribes and ex-servicemen.

6.2. The absence of the savings clause under the 2020 rules can be indicative of the fact that the reservations, in relation to the age limit and other concessions to the SC, ST and ex-servicemen will not be explicitly covered as exception under these rules. They might be covered under other constitutional provisions, but the statutory protection accorded to them under the earlier rules has been taken away due to the absence of the savings clause. This can adversely affect the independence and proper functioning of the judiciary because when the power of the government is regulated by a statutory provision, it can be limited to a great extent. But, in absence of the statutory regulation, the government can have unfettered powers to make any exceptions to the procedure laid down in the rules. Even if the power is limited by constitutional provisions, a great variety of the actions of the government can be sought to be justified under “reasonable restrictions” as it is a highly subjective standard. Thus, there should be a savings clause regarding the power of the government to make exceptions because it will allow the power of the government to be regulated. 

B. Authority on Advance Rulings

7. Chairperson

7.1. The people qualified to be appointed as the Chairperson have been reduced because the criteria laid down by the 2017 rules has been further refined by the 2020 rules. A person qualified to be appointed as a Supreme Court Judge, a person who has served as the Vice-Chairman, accountant member, law member of the AAR or a person having experience and specialized knowledge in specific areas useful for the AAR is no longer qualified to be appointed as the Chairman of AAR.

7.2. The removal of these persons from the list of eligible persons can adversely affect the efficient functioning of this forum as these people have experience and knowledge which can be immensely beneficial to the Tribunal.

8. Vice-Chairman
8.1. A person who is qualified to be a Judge of the High Court is no longer qualified to be appointed as the vice-chairman.

8.2. The qualification criteria for the officers form IRS has been raised by the 2020 rules. The requirement of been involved in adjudicatory, judicial or quasi-judicial work for three years has been increased. This is in consonance with the guidelines mentioned in various judgements as the technical members also need to have some experience in adjudication, judicial or quasi-judicial work, in addition to the technical expertise of the subject. 

9. Judicial Member

9.1. The members for Indian Legal Services are no longer eligible to be appointed as judicial members. Only a person who has served as a district-judge or additional district judge for 10 years is qualified to be appointed for this position. This is in compliance with the requirement of some experience in judicial, adjudicatory and quasi-judicial work as laid down in various cases.

9.2. However, the presence of the executive in the search-cum selection committee for the members adversely affects the judicial independence, the perception of justice and the faith in the judiciary as an impartial justice system. Thus, the search-cum-selection committee for the members should comprise of judicial members only.

In a nutshell, the 2020 rules are quite similar to the 2017 rules. The guidelines laid down by the Hon’ble Supreme Court regarding the procedure for qualifications, experience and other conditions for appointment to tribunals in the Rojer Mathew case (sura),R.K. Jain v. Union of India[(1993) 4 SCC 119], L. Chandra Kumar(supra), Madras Bar Association v. Union of India[(2015) 8 SCC 583] and Gujarat Urja Vikas Nigam  Ltd. v. Essar Power Ltd. [(2016) 9 SCC 103] have not been complied with by the government while framing the 2020 rules. These rules encroach upon judicial independence, separation of powers and are not in compliance of the separation of powers. They are in defiance of the guidelines laid down by the Hon’ble Supreme Court in the Rojer Mathew case (Supra) which are binding on the government. Thus, the requisite changes should be made to these rules or new rules in compliance with the guidelines should be formulated.

Annexure: Comparison of the provision of the rules for appointment of members across the years.

Subject

1963

2017

2020

Income Tax Appellate Tribunal

Qualification for appointment as President

On merit and seniority, by the committee.

A person who:

  • Is a sitting or retired judge of a High Court
  • Has completed 7 years of service as a judge of High Court
  • Has completed 7 years of service as Vice-President of ITAT

A person who:

  • Is a sitting or retired judge of a High Court
  • Has completed 7 years of service as a judge of High Court
  • Has completed 7 years of service as Vice-President of ITAT

Qualification for appointment as Vice- President

On merit and seniority, by the committee.

Central government may appoint one or more members of the ITAT as vice-president of ITAT.

Central government may appoint one or more members of the ITAT as vice-president of ITAT.

Qualification for recruitment as Judicial Member

A person who:

  • Has held judicial office in India for 10 years or more
  • Has been a member of Indian Legal Services and has held a post in Grade II of Service or equivalent or higher post for 3 years. 
  • Has been an advocate for 10 years.

A person, who:

  • Has held a judicial office for 10 years in India
  • Has been a member of the India Legal Services and has held the post in Grade II of Service or equivalent or higher post for at least 3 years
  • Has been practicing as an advocate for 10 years or more

A person, who:

  • Has, for a combined period of 10 years, served as a district judge and additional judge India
  • Has been a member of the India Legal Services and has held the post Additional secretary or any equivalent or higher post for at least 2 years
  • Has been practicing as an advocate for 25 years or more

Qualification for recruitment as Accountant Member

A person who:

  • Has been in practice of accountancy for 10 years as a CA, a registered accountant under earlier law, partly as such registered accountant and partly as a chartered accountant.
  • Has been a member of the Indian Income Tax Service Group A and has held the position of ACIT or above for 3 years. 

Further requirements:

  • Age, not less than 35 years
  • Age, not above 50 years
  • Upper age limit may be relaxed for the government servants up to 5 years or a person belonging to SC, ST or any special category specified by the Central Government.

A person, who:

  • Has been in the practice of accountancy for 10 years
  • Has been in IRS (Group A) and has held the post of ACIT or equivalent or higher post for 3 years.

A person, who:

  • Has been in the practice of accountancy for 25 years (as a CA or partly a registered accountant and CA)
  • Has been a member of IRS (Group A) and has held the post of PCIT or equivalent or higher post for 2 years and has performed judicial, quasi-judicial or adjudicating function for three years.

Tenure and Age of retirement for President

The date on which the president attains the age of 65 years.

Three Year; 65 years

Four years or till he attains the age of 70 years, whichever is earlier

Tenure and Age of retirement for Vice- President

The date on which the vice president attains the age of 62 years.

Three years; 62 years

Four years or till he attains the age of 65 years, whichever is earlier

Tenure and Age of retirement for Judicial Member

The date on which the member attains the age of 62 years.

Three years; 62 years

Four years or till he attains the age of 65 years, whichever is earlier

Tenure and Age of retirement for Accountant member

The date on which the member attains the age of 62 years.

Three years; 62 years

Four years or till he attains the age of 65 years, whichever is earlier

Selection and Search Committee

  • Sitting Supreme Court judge (to be appointed by CJI)
  • The president
  • Secretary, Ministry of Law and Justice (Department of Legal affairs)
  • Based on merit the committee shall recommend the people to be appointed as presidents, Senior vice president and vice presidents.

Search cum selection committee for appointment of President and Vice president:

  • Chairperson- Sitting judge of Supreme Court to be nominated by the CJI
  • Member- The president, ITAT
  • Member- Secretary, to Govt. of India, Ministry of Law and Justice (Department of legal affairs)

Search cum selection committee for appointment of Judicial member and Accountant member:

  • Chairperson- A nominee of Ministry of law and justice
  • Member- Secretary, to Govt. of India, Ministry of Law and Justice (Department of legal affairs)
  • Member- The president, ITAT
  • Member- other persons nominated by central government (limited to 2 members)

Search cum selection committee for appointment of President and Vice president:

  • Chairperson- Sitting judge of Supreme Court to be nominated by the CJI
  • In case of appointment of the president; Member- The outgoing president, ITAT
  • Member- In case of the appointment of Vice- President, or Accountant Member or Judicial Members, the President, ITAT
  • Member- Secretary, to Govt. of India, Ministry of Law and Justice (Department of legal affairs)
  • Member- Secretary, to Govt. of India, Ministry of Finance (Department of Revenue)

Salary of President

Rs. 80,000/- per month; annual increment rate 3%.

Rs. 2,50,000 per month

Rs. 2,50,000 per month

Salary of Vice-President

Rs. 80,000/- per month (senior vice president and vice president); annual increment rate 3%.

Rs. 2,25,000 per month

Rs. 2,25,000 per month

Salary of the Judicial Member

Rs. 80,000/- per month; annual increment rate 3%.

Rs. 1,25,000 per month

Rs. 2,25,000 per month

Salary of the Accountant member

Rs. 80,000/- per month; annual increment rate 3%.

Rs. 1,25,000 per month

Rs. 2,25,000 per month

Applicability of the rules to the Existing members

The rules are not applicable to existing members

The rules are not applicable to existing members

Interpretation

Any questions relating to the interpretation of these rules, the decision of the Central Government shall be final.

Any questions relating to the interpretation of these rules, the decision of the Central Government shall be final.

Power to Relax

The central government can relax any of the rules for a specific class or category of persons if it is of the opinion that it is expedient to do so

The central government can relax any of the rules for a specific class or category of persons if it is of the opinion that it is expedient to do so

Saving

The rules shall not affect the reservations, relation of age limit and other concessions required to provide to SC, ST, Ex-servicemen and other categories of people in accordance with the notification issued by the Central Government

The rules shall not affect the reservations, relation of age limit and other concessions required to provide to SC, ST, Ex-servicemen and other categories of people in accordance with the notification issued by the Central Government

Authority of Advance Ruling

Appointment of the Chairman

A person, who:

  • Is, has been or is qualified to be appointed as a Supreme Court judge
  • Is or has been the Chief justice of a high court
  • Has, for at least 7 years been a vice-chairman, accountant member or law member of the Authority for Authority for Advance Ruling.
  • A person with special knowledge of & professional experience of at least 25 years in economics, business, commerce, finance accountancy, management, industry, public affairs, taxation, administration or any other matter which in opinion of the Central Government is useful to the authority.

A person, who:

  • Is or has been appointed as a Supreme Court judge
  • Is or has been the Chief justice of a high court

Appointment of the Vice-Chairman

A person who is, has been or is qualified to be a Judge of the High Court

A person who is or has been a Judge of the High Court

Member

  • Accountant member for IRS who is qualified to be a member of CBDT and an officer of the Indian Customs and Central Excise Service, who is qualified to be a member of the Central Board of Excise and Customs
  • Law member from Indian Legal Service, who is an additional secretary to government of India.
  • Law member- a person who has, for a combined period of 10 years, been a district judge or additional district judge
  • Accountant member IRS who is qualified to be a member of CBDT and an officer of the Indian Customs and Central Excise Service, who is qualified to be a member of the Central Board of Excise and Customs and has performed judicial, quasi-judicial or adjudicating function for 3 years

Selection and search committee

For post of Chairman and Vice-Chairman:

  • Chairperson- CJI or a judge of the Supreme Court nominated by CJI
  • Member- Secretary, to Govt. of India, Ministry of Law and Justice (Department of legal affairs)
  • Member- Secretary, to Govt. of India, Department of Personnel and Training

For the post of Member-

  • Chairperson- Cabinet Secretary
  • Member- Secretary, to Govt. of India, Department of Personnel and Training
  • Member- Secretary, to Govt. of India, Department of Revenue
  • Members- 2 secretaries to the Government of India to be nominated by the Central Government

For post of Chairman and Vice-Chairman, law member and accountant member:

  • Chairperson- CJI or a judge of the Supreme Court nominated by CJI
  • Member- In case of chairman, the outgoing Chairman, the outgoing chairman to the AAR
  • Member- In case of appointment of the Vice-Chairman, law member and accountant member, the chairman to the AAR
  • Member- Secretary, to Govt. of India, Department of Personnel and Training
  • Member- Secretary to the Government of India, Ministry of Personal, Public Grievances and pensions (Department of personnel and Training) 
The author is a student of the 5th Year, BA LLB (Hons.) at the Maharashtra National Law University Mumbai
Disclaimer: The contents of this document are solely for informational purpose. It does not constitute professional advice or a formal recommendation. While due care has been taken in preparing this document, the existence of mistakes and omissions herein is not ruled out. Neither the author nor itatonline.org and its affiliates accepts any liabilities for any loss or damage of any kind arising out of any inaccurate or incomplete information in this document nor for any actions taken in reliance thereon. No part of this document should be distributed or copied (except for personal, non-commercial use) without express written permission of itatonline.org
5 comments on “New Rules For Appointment Of Tribunal Members Encroaches Upon Judicial Independence And Also Is Non-Compliant With The Guidelines Issued By The Supreme Court
  1. KEEN OBSERVER says:

    It is reported in media yesterday and today that vacancies in ITAT to be filled in around one and a half months.

  2. gopal nathani says:

    very good compilation ,….tks

  3. KEEN OBSERVER says:

    The SC had in November 2019 judgement had clearly directed the government to come out with new rules keeping in mind the pitfalls,shortcomings and lacunae (whatever one can call)found in 2017 rules by the Court.The Court also asked the new rules to be before it within six months so that the interim orders can be modified.The Court was aware of TWO SITUATIONS REQUIRED AS FAR AS SOME TRIBUNALS ARE CONCERNED IN VIEW OF SECURITY OF TENURE .
    WE HAVE A SITUATION AS SUCH.THE SC IS SEIZE OF NEW RULES OF FEB 2020 SOONER OR LATER.
    If rationality is to be applied the new rules should be applicable to new advertisements of recruitments to ITAT which may come in YEAR SAY 2022-2023 and appointments in say 2024-2025.
    The way things are today and VSV coming, after ten years the matter in disputes may go down drastically in the opinion of govt and ministries and the applicants of ITAT members shall have no problems as most of new recruited would be above 55 years.
    MAY BE THE GOVT HAS DONE ITS PART OF 2018 ADVERTISEMENTS THAT IS APPOINTMENTS BEFORE 12TH FEBRUARY NEW RULES AND THE LAW MINISTRIES WOULD BE DOING ITS PART IN NEW FINANCIAL YEAR TO THE RECRUITED.

  4. S.G.Hegde Advoacte says:

    A very well researched article by law student . Congratulations

  5. Pramod says:

    So, Ongoing appointments are in limbo, as selection committee must have recommended people below 25 years or PCIT
    Another round of litigation is coming soon. Government is hell bent on damaging the appeal system.
    All this will lead to flooding of High Court with WRIT petitions due to either incompetency of tribunal or non availability of the tribunal as happening in DRT

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