CIT v. Manu Engg

122 ITR 306High Court1980#133 most cited

What is CIT v. Manu Engg authority for?

When levying a penalty under Section 271(1)(c), the Assessing Officer must clearly specify whether it is for concealment of income or furnishing inaccurate particulars. An ambiguous notice or order using "and/or" for these limbs, or a standard proforma without striking irrelevant clauses, indicates non-application of mind and renders the penalty unsustainable.

505

judgments rely on this decision, according to BharatTax’s citation analysis of 367,154 Indian tax judgments — from 2012 to 2026.

Also referred to as

CIT v. Manu Engg · Manu Engineering · Section 271(1)(c) · Section 274 · levy of penalty · penalty notice · concealment of income · furnishing inaccurate particulars of income · ambiguous penalty order · non-application of mind · penalty unsustainable

Sections most often in play

Section 271(1)(c)Section 274Section 143(3)Section 250Section 68Section 132Section 153ASection 154

Issues it is cited on

section 271(l)section 271(l)(c)furnishing inaccurate particulars of incomepenalty under section 271(1)(c)furnishing inaccurate particularssection 274non-application of mindconcealment of incomepenalty u/s 271(1)(c)levy of penaltysection 271(1)section 271

Judgments citing CIT v. Manu Engg

DCIT, Central Circle - XI, Kolkata vs. Shri Harish Kumar Sarawgi, Kolkata

In the result, the appeals of the assessee are allowed and appeals of the revenue are dismissed

ITA 1496/KOL/2011[2004-05]Status: DisposedITAT Kolkata26 Aug 2016AY 2004-05

Bench: Shri N. V. Vasudevan, Jm & Shri M. Balaganesh, Am] I.T.A Nos. 1222 To 1226/Kol/2011 Assessment Years: 2003-04 To 2007-08

For Appellant: Shri D. S. Damle, FCAFor Respondent: Shri Sallong Yaden, Addl. CIT
Section 132Section 132(4)Section 139(1)Section 153ASection 271(1)Section 271(1)(c)Section 271A

…ars. The Apex Court in the case of Ashok Pai reported in 292 ITR 11 at page 19 has held that concealment of income and furnishing inaccurate particulars of income carry different connotations. The Gujarat High Court in the case of MANU ENGINEERING reported in 122 ITR 306 and the Delhi High Court in the case of VIRGO MARKETING reported in 171 Taxman 156, has held that levy of penalty has to be clear as to the limb for which it is levied and the position being unclear penalty is not sustainable. Therefore, when the Assessing Officer proposes to invoke the first limb being concealment, then the notice has to be appr…

Harish Kumar Sarawgi, Kolkata vs. DCIT, Central Circle - XI, Kolkata

In the result, the appeals of the assessee are allowed and appeals of the revenue are dismissed

ITA 1222/KOL/2011[2003-04]Status: DisposedITAT Kolkata26 Aug 2016AY 2003-04

Bench: Shri N. V. Vasudevan, Jm & Shri M. Balaganesh, Am] I.T.A Nos. 1222 To 1226/Kol/2011 Assessment Years: 2003-04 To 2007-08

For Appellant: Shri D. S. Damle, FCAFor Respondent: Shri Sallong Yaden, Addl. CIT
Section 132Section 132(4)Section 139(1)Section 153ASection 271(1)Section 271(1)(c)Section 271A

…ars. The Apex Court in the case of Ashok Pai reported in 292 ITR 11 at page 19 has held that concealment of income and furnishing inaccurate particulars of income carry different connotations. The Gujarat High Court in the case of MANU ENGINEERING reported in 122 ITR 306 and the Delhi High Court in the case of VIRGO MARKETING reported in 171 Taxman 156, has held that levy of penalty has to be clear as to the limb for which it is levied and the position being unclear penalty is not sustainable. Therefore, when the Assessing Officer proposes to invoke the first limb being concealment, then the notice has to be appr…

M/S Rishi F. L. on Shop, Murshidabad vs. ITO, WD-4, Murshidabad

In the result, the appeal of assessee is allowed

ITA 320/KOL/2014[2006-2007]Status: DisposedITAT Kolkata24 Aug 2016AY 2006-2007

Bench: Shri Waseem Ahmed & Shri S.S.Viswanethra Ravi

Section 271(1)Section 274Section 68Section 69C

…ars. The Apex Court in the case of Ashok Pai reported in 292 ITR 11 at page 19 has held that concealment of income and furnishing inaccurate particulars of income carry different connotations. The Gujarat High Court in the case of MANU ENGINEERING reported in 122 ITR 306 and the Delhi High Court in the case of VIRGO MARKETING reported in 171 Taxman 156, has held that levy of penalty has to be clear as to the limb for which it is levied and the position being unclear penalty is not sustainable. Therefore, when the Assessing Officer proposes to invoke the first limb being concealment, then the notice has to be appr…

Bimal Kumar Mondal, Kolkata vs. CIT(A)-Xxxii, Kolkata

In the result, the appeal of assessee is allowed

ITA 256/KOL/2014[2002-2003]Status: DisposedITAT Kolkata24 Aug 2016AY 2002-2003

Bench: Shri M.Balaganesh & Shri S.S.Viswanethra Ravi

Section 143(3)Section 271(1)Section 274Section 275(1)

…ars. The Apex Court in the case of Ashok Pai reported in 292 ITR 11 at page 19 has held that concealment of income and furnishing inaccurate particulars of income carry different connotations. The Gujarat High Court in the case of MANU ENGINEERING reported in 122 ITR 306 and the Delhi High Court in the case of VIRGO MARKETING reported in 171 Taxman 156, has held that levy of penalty has to be clear as to the limb for which it is levied and the position being unclear penalty is not sustainable. Therefore, when the Assessing Officer proposes to invoke the first limb being concealment, then the notice has to be appr…

Maitree Biswas, Kolkata vs. DCIT, Cir-51, Kolkata

In the result, the appeal of assessee is allowed

ITA 204/KOL/2014[2008-2009]Status: DisposedITAT Kolkata24 Aug 2016AY 2008-2009

Bench: Shri Waseem Ahmed & Shri S.S.Viswanethra Ravi

Section 143(3)Section 271(1)Section 274

…ars. The Apex Court in the case of Ashok Pai reported in 292 ITR 11 at page 19 has held that concealment of income and furnishing inaccurate particulars of income carry different connotations. The Gujarat High Court in the case of MANU ENGINEERING reported in 122 ITR 306 and the Delhi High Court in the case of VIRGO MARKETING reported in 171 Taxman 156, has held that levy of penalty has to be clear as to the limb for which it is levied and the position being unclear penalty is not sustainable. Therefore, when the Assessing Officer proposes to invoke the first limb being concealment, then the notice has to be appr…

Chandra Narayan Mohta, Kolkata vs. Income Tax Officer, Ward - 34(3), Kolkata

In the result, the appeal of assessee is allowed

ITA 2519/KOL/2013[2006-07]Status: DisposedITAT Kolkata24 Aug 2016AY 2006-07

Bench: Shri Waseem Ahmed & Shri S.S.Viswanethra Ravi

Section 271(1)Section 271(1)(c)Section 274

…ars. The Apex Court in the case of Ashok Pai reported in 292 ITR 11 at page 19 has held that concealment of income and furnishing inaccurate particulars of income carry different connotations. The Gujarat High Court in the case of MANU ENGINEERING reported in 122 ITR 306 and the Delhi High Court in the case of VIRGO MARKETING reported in 171 Taxman 156, has held that levy of penalty has to be clear as to the limb for which it is levied and the position being unclear penalty is not sustainable. Therefore, when the Assessing Officer proposes to invoke the first limb being concealment, then the notice has to be appr…

Universal Music India P.Ltd, Mumbai vs. Asst CIT 7(3), Mumbai

In the result, the assessee’s appeal for assessment year 2010-11

ITA 6752/MUM/2014[2010-11]Status: DisposedITAT Mumbai19 Aug 2016AY 2010-11

Bench: Shri Jason P.Boaz & Shri Sandeep Gosainm/S.Universal Music India Pvt. Ltd., Samir Complex, St. Andrews Road, Bandra(W), Mumbai 400 050 Pan: Aaacp 1985C ..... Appellant Vs. The Acit, Cir. 7(3), Mumbai. .... Respondent Appellant By : S/Shri Naniwadekar & Ruturaj H. Gurjar Respondent By : Ms. Anu Krishna Agarwal

For Appellant: S/Shri Naniwadekar &For Respondent: Ms. Anu Krishna Agarwal
Section 143(1)Section 143(3)Section 271Section 271(1)(c)Section 274

…IN THE INCOME TAX APPELLATE TRIBUNAL MUMBAI BENCH “F”, MUMBAI BEFORE SHRI JASON P.BOAZ, ACCOUNTANT MEMBER AND SHRI SANDEEP GOSAIN, JUDICIAL MEMBER M/s.Universal Music India Pvt. Ltd., Samir Complex, St. Andrews Road, Bandra(W), Mumbai 400 050 PAN: AAACP 1985C ..... Appellant Vs. The ACIT, Cir. 7(3), Mumbai. .... Respondent Appellant by : S/Shri Naniwadekar & Ruturaj H. Gurjar Respondent by : Ms. Anu Krishna Agarwal Date of hearing : 10/08/2016 Date of pronouncement : 19/08/2016 ORDER PER JASON P. BOAZ,A.M: This appeal by the assessee is directed against the order of CIT(Appeals)-13, Mumbai dated 4/09/20…

Lalitkumar M Sakhala, Mumbai vs. DCIT Cir 24(1), Mumbai

In the result, the appeal of the assessee is allowed

ITA 938/MUM/2015[2009-10]Status: DisposedITAT Mumbai10 Aug 2016AY 2009-10

Bench: Sri Mahavir Singh, Jm Lalitkumar M Sakhala, Vs. D.C.I.T, Cir-24(1), C/O. Shantilal B. Chhajed, Mumbai 202, Inder Tower, K. G. Marg, Near Tilak Bhavan, Dadar (West), Mumbai 400 025 Pan: Bgeps9156C Appellant .. Respondent Appellant By Shri Satish Mody, Ar Respondent By Shri Manoj Kumar, Sr.Dr Date Of Hearing 07-07-2016 Date Of Pronouncement 10-08-2016 O R D E R Per Mahavir Singh, Jm:

Section 143(3)Section 271Section 271(1)Section 271(1)(c)Section 274Section 274(1)

…ars. The Apex Court in the case of Ashok Pai reported in 292 ITR 11 at page 19 has held that concealment of income and furnishing inaccurate particulars of income carry different connotations. The Gujarat High Court in the case of MANU ENGINEERING reported in 122 ITR 306 and the Delhi High Court in the case of VIRGO MARKETING reported in 171 Taxman 156, has held that levy of penalty has to be clear as to the limb for which it is levied and the position being unclear penalty is not sustainable. Therefore, when the Assessing Officer proposes to invoke the first limb being concealment, then the notice has to be appr…

Sejal P Savla, Mumbai vs. Asst CIT Cen Cir 33, Mumbai

ITA 3382/MUM/2015[2004-05]Status: DisposedITAT Mumbai10 Aug 2016AY 2004-05

Bench: Shri R.C. Sharma & Shri Sandeep Gosain: (A.Y : 2004-05)

For Appellant: Shri Ashok SutarFor Respondent: Shri Uday Bhaskar Jakke
Section 143(3)Section 2Section 271Section 271(1)Section 271(1)(c)

…ars. The Apex Court in the case of Ashok Pai reported in 292 ITR 11 at page 19 has held that concealment of income and furnishing inaccurate particulars of income carry different connotations, The Gujarat High Court in the case of MANU ENGINEERING reported in 122 ITR 306 and the Delhi High Court in the case of VIRGO MARKETING reported in 171 Taxman 156, has held that levy of penalty has to be clear as to the limb for which it is levied and the position being unclear penalty is not sustainable. Thom, when the Assessing Officer proposes to invoke the first limb being concealment, then the notice has to be appropria…

Allwyn D Vaz, Mumbai vs. ITO WD 26(2)(1), Mumbai

In the result, appeal of the assessee is allowed

ITA 600/MUM/2015[2010-11]Status: DisposedITAT Mumbai08 Aug 2016AY 2010-11

Bench: Shri R.C.Sharmaआमकय अऩीर सं./Ita No.600/Mum/2015 (नििाारण वषा / Assessment Year :2010-2011) Shri Allwyn D. Vaz, 103, 10 Raag Vs. Ito Wd-26(2)(1), Mumbai Complex, Opposite Royal Challenge Restaurant, Nr. Dindoshi Depot, Goregaon (East), Mumbai-400063 स्थामी रेखा सं./ जीआइआय सं./ Pan/Gir No. : Aaipv 3139 K (अऩीराथी /Appellant) (प्रत्मथी / Respondent) .. ननधाारयती की ओर से /Assessee By : Shri V.D.Parmar याजस्व की ओर से /Revenue By : Shri Pradeep Kumar Singh सुनवाई की तायीख / Date Of Hearing : 08/08/2016 घोषणा की तायीख/Date Of Pronouncement 08/08/2016 आदेश / O R D E R

For Appellant: Shri V.D.ParmarFor Respondent: Shri Pradeep Kumar Singh
Section 271Section 271(1)(c)Section 274

…. 5 The Apex Court in the case of Ashok Pai reported in 292 ITR 11 at page 19 has held that concealment of income and furnishing inaccurate particulars of income carry different connotations, The Gujarat High Court in the case of MANU ENGINEERING reported in 122 ITR 306 and the Delhi High Court in the case of VIRGO MARKETING reported in 171 Taxman 156, has held that levy of penalty has to be clear as to the limb for which it is levied and the position being unclear penalty is not sustainable. Thom, when the Assessing Officer proposes to invoke the first limb being concealment, then the notice has to be appropria…

Kartik Mehara, Kolkata vs. D.C.I.T CC - Xvii, Kolkata

In the result the appeal of the assessee is allowed

ITA 930/KOL/2013[2004-05]Status: DisposedITAT Kolkata03 Aug 2016AY 2004-05

Bench: Hon’Ble Sri N.V.Vasudevan, Jm & Shri Waseem Ahmed, Am] I.T.A No. 930/Kol/2013 Assessment Year : 2004-05 Kartik Mehra -Vs.- D.C.I.T., Central Circle-Xviii, Kolkata Kolkata [Pan : Aidpm 7054 M] (Respondent) (Appellant) For The Appellant : Ms.Varsha Jalan, Ar For The Respondent : Shri Debasish Banerjee, Jcit,Sr.Dr Date Of Hearing :20.07.2016. Date Of Pronouncement : 03.08.2016. Order Per N.V.Vasudevan, Jm

For Appellant: Ms.Varsha Jalan, ARFor Respondent: Shri Debasish Banerjee, JCIT,Sr.DR
Section 132Section 139Section 271Section 271(1)Section 271(1)(c)

…ars. The Apex Court in the case of Ashok Pai reported in 292 ITR 11 at page 19 has held that concealment of income and furnishing inaccurate particulars of income carry different connotations. The Gujarat High Court in the case of MANU ENGINEERING reported in 122 ITR 306 and the Delhi High Court in the case of VIRGO MARKETING reported in 171 Taxman 156, has held that levy of penalty has to be clear as to the limb for which it is levied and the position being unclear penalty is not sustainable. Therefore, when the Assessing Officer proposes to invoke the first limb being concealment, then the notice has to be appr…

Dr Pramod Sureka, Kolkata vs. D.C.I.T.Central Circle-Xiii, Kolkata

In the result, the appeal of assessee is allowed

ITA 2872/KOL/2013[2009-2010]Status: DisposedITAT Kolkata03 Aug 2016AY 2009-2010

Bench: : Shri P.M.Jagtap & Shri S.S. Viswanethra Ravi

For Appellant: Shri Manish Tiwari, FCA, ld.ARFor Respondent: Shri Rajat Kr. Kureel, JCIT, ld.DR
Section 271Section 271(1)Section 271(1)(c)Section 274

…ars. The Apex Court in the case of Ashok Pai reported in 292 ITR 11 at page 19 has held that concealment of income and furnishing inaccurate particulars of income carry different connotations. The Gujarat High Court in the case of MANU ENGINEERING reported in 122 ITR 306 and the Delhi High Court in the case of VIRGO MARKETING reported in 171 Taxman 156, has held that levy of penalty has to be clear as to the limb for which it is levied and the position being 5 Dr.Pramod Sureka unclear penalty is not sustainable. Therefore, when the Assessing Officer proposes to invoke the first limb being concealment, then the…

M/S Ennoble Construction vs. DCIT

In the result, the appeals of the assessee are allowed

ITA 1844/BANG/2013[2006-07]Status: DisposedITAT Bangalore29 Jul 2016AY 2006-07

Bench: Shri Sunil Kumar Yadav & Shri A.K. Garodia

For Respondent: Dr.Sibichen K. Mathew, CIT-III(DR)
Section 271Section 271(1)(c)Section 274

…ts of the Hon'ble jurisdictional High Court in the case of CIT & Anr. V. Manjunatha Cotton & Ginning Factory, 359 ITR 565 (Karn); the Hon’ble High Court of Gujarat in the cases of National Textiles v. CIT, 249 ITR 125 (Guj) & CIT v. Manu Engineering Works, 122 ITR 306 (Guj); and the decision of this Tribunal in the case of Shri E. Krishnappa v. ITO in ITA No.313 to 315/Bang/2014 dated 14.08.2015. 5. Per contra, the ld. DR has submitted that mere non-striking a particular column in the notice would not be that much to fatal the validity of penalty proceedings. 6. Having carefully examined the notices issues u…

Smt. G. Lakshmi Aruna vs. DCIT

In the result, the appeals of the assessee are allowed

ITA 1812/BANG/2013[2006-07]Status: DisposedITAT Bangalore29 Jul 2016AY 2006-07

Bench: Shri Sunil Kumar Yadav & Shri A.K. Garodia

For Respondent: Dr.Sibichen K. Mathew, CIT-III(DR)
Section 271Section 271(1)(c)Section 274

…ts of the Hon'ble jurisdictional High Court in the case of CIT & Anr. V. Manjunatha Cotton & Ginning Factory, 359 ITR 565 (Karn); the Hon’ble High Court of Gujarat in the cases of National Textiles v. CIT, 249 ITR 125 (Guj) & CIT v. Manu Engineering Works, 122 ITR 306 (Guj); and the decision of this Tribunal in the case of Shri E. Krishnappa v. ITO in ITA No.313 to 315/Bang/2014 dated 14.08.2015. 5. Per contra, the ld. DR has submitted that mere non-striking a particular column in the notice would not be that much to fatal the validity of penalty proceedings. 6. Having carefully examined the notices issues u…

Bidhan Chandra Roay, Howrah vs. Income Tax Officer, Ward - 54(4), Kolkata

In the result, the appeal of assessee is allowed

ITA 2499/KOL/2013[2005-06]Status: DisposedITAT Kolkata27 Jul 2016AY 2005-06

Bench: : Shri S.S. Viswanethra Ravi

For Appellant: Shri Sunil Surana, FCA, ld.ARFor Respondent: Shri Kalyan Nath, JCIT, ld.DR
Section 271Section 271(1)Section 271(1)(c)Section 274

…ars. The Apex Court in the case of Ashok Pai reported in 292 ITR 11 at page 19 has held that concealment of income and furnishing inaccurate particulars of income carry different connotations. The Gujarat High Court in the case of MANU ENGINEERING reported in 122 ITR 306 and the Delhi High Court in the case of VIRGO MARKETING reported in 171 Taxman 156, has held that levy of penalty has to be clear as to the limb for which it is levied and the position being unclear penalty is not sustainable. Therefore, when the Assessing Officer proposes to invoke the first limb being concealment, then the notice has to be appr…

D.C.I.T CC - VII, Kolkata vs. Sri Shyam Sunder Dhanuka, Kolkata

In the result, both the appeal of Revenue stand dismissed

ITA 1869/KOL/2013[2006-07]Status: DisposedITAT Kolkata20 Jul 2016AY 2006-07

Bench: Shri Waseem Ahmed & Shri S.S.Viswanethra Ravi

Section 131Section 139Section 153ASection 153CSection 153C(1)Section 271(1)(c)

…ars. The Apex Court in the case of Ashok Pai reported in 292 ITR 11 at page 19 has held that concealment of income and furnishing inaccurate particulars of income carry different connotations. The Gujarat High Court in the case of MANU ENGINEERING reported in 122 ITR 306 and the Delhi High Court in the case of VIRGO MARKETING reported in 171 Taxman 156, has held that levy of penalty has to be clear as to the limb for which it is levied and the position being unclear penalty is not sustainable. Therefore, when the Assessing Officer proposes to invoke the first limb being concealment, then the notice has to be appr…

Krishna Srivastava, Bangalore vs. Asst.C.I.T., Bangalore

In the result, the appeal of the assessee is allowed

ITA 1273/BANG/2015[2009-10]Status: DisposedITAT Bangalore30 Jun 2016AY 2009-10

Bench: Shri A.K. Garodia & Shri Vijay Pal Rao

For Appellant: Shri Zain Khan, C.AFor Respondent: Smt. P. Renugadevi, JCIT
Section 271Section 271(1)(c)Section 274

…lars. The Apex Court in the case of Ashok Pai reported in 292 ITR 11 at page 19 has held that concealment of income and furnishing inaccurate particulars of income carry different connotations. The Gujrat High Court in the case of MANU ENGINEERING reported in 122 ITR 306 and the Delhi High Court in the case of VIRGO MARKETING reported in 171 Taxmn 156, has held that levy of penalty has to be clear as to the limb for which it is levied and the position being unclear penalty is not sustainable. Therefore, when the Assessing Officer proposes to invoke the first limb being concealment, then the notice has to be appro…

Sujit Kumar Bhagat, Kolkata vs. I.T.O WD - 28(2), Kolkata.

In the result, the appeal of the assessee is allowed

ITA 483/KOL/2013[2006-07]Status: DisposedITAT Kolkata29 Jun 2016AY 2006-07

Bench: Shri Waseem Ahmed & Shri S.S. Viswanethra Ravi

Section 143(2)Section 143(3)Section 271(1)(c)Section 274

…I.T.A. No. 483/KOL./2013 Assessment year: 2006-2007 Page 1 of 9 IN THE INCOME TAX APPELLATE TRIBUNAL, KOLKATA ‘A’ BENCH, KOLKATA Before Shri Waseem Ahmed, Accountant Member and Shri S.S. Viswanethra Ravi, Judicial Member I.T.A. No. 483/KOL/ 2013 Assessment Year: 2006-2007 Sujit Kr. Bhagat,........................................................................Appellant C/o. Colors, 8, Ho Chi Minh Sarani, Kolkata-700 071 [PAN : ADTPB 8219 J] -Vs.- Income Tax Officer,..................................................................Respondent Ward-28(2), Kolkata, 2, Gariahat Road, Aayakar Bhawan Dakshin, Kolkat…

Super Regractories, Burdwan vs. I.T.O, Ward-1(4), Asansol

In the result, the appeal of the assessee is allowed

ITA 2229/KOL/2013[2006-07]Status: DisposedITAT Kolkata29 Jun 2016AY 2006-07

Bench: Shri Waseem Ahmed & Shri S.S. Viswanethra Ravi

Section 143(2)Section 143(3)Section 271(1)(c)Section 274Section 68

…ars. The Apex Court in the case of Ashok Pai reported in 292 ITR 11 at page 19 has held that concealment of income and furnishing inaccurate particulars of income carry different connotations. The Gujarat High Court in the case of MANU ENGINEERING reported in 122 ITR 306 and the Delhi High Court in the case of VIRGO MARKETING reported in 171 Taxman 156, has held that levy of penalty has to be clear as to the limb for which it is levied and the position being unclear penalty is not sustainable. Therefore, when the Assessing Officer proposes to invoke the first limb being concealment, then the notice has to be appr…

Ideal Unemployed Engineers Co-Operative Society Ltd., Coochbihar vs. D.C.I.T., Circle - 2, Jalpaiguri

In the result, assessee’s appeal stands allowed

ITA 2460/KOL/2013[2010-11]Status: DisposedITAT Kolkata15 Jun 2016AY 2010-11

Bench: Shri Waseem Ahmed & Shri S.S.Viswanethra Raviassessment Year :2010-11

Section 143(3)Section 271(1)(c)Section 274

…ars. The Apex Court in the case of Ashok Pai reported in 292 ITR 11 at page 19 has held that concealment of income and furnishing inaccurate particulars of income carry different connotations. The Gujarat High Court in the case of MANU ENGINEERING reported in 122 ITR 306 and the Delhi High Court in the case of VIRGO MARKETING ITA No.2460/Kol/2013 A.Y.2010-11 Ideal Unemployed Engineeers Co-Op So. Ltd. v. DCIT Cir-2, JAL Page 7 reported in 171 Taxman 156, has held that levy of penalty has to be clear as to the limb for which it is levied and the position being unclear penalty is not sustainable. Therefore, when th…