Commissioner of Customs v. Indian Oil Corporation Ltd.

267 ITR 272Supreme Court of India2004#135 most cited

What is Commissioner of Customs v. Indian Oil Corporation Ltd. authority for?

CBDT and CBEC circulars, along with administrative instructions, are binding on departmental authorities, who must not act in contravention of them. However, these circulars and instructions are not binding on courts or assessees.

501

judgments rely on this decision, according to BharatTax’s citation analysis of 367,368 Indian tax judgments — from 2015 to 2026.

Also referred to as

Commissioner of Customs v. Indian Oil Corporation Ltd. · 267 ITR 272 · CBDT circulars binding on department · CBEC circulars binding on department · administrative instructions · departmental authorities bound · not binding on assessee · not binding on court · Section 119 Income-tax Act

Also reported as

136 Taxmann 491

Sections most often in play

Section 143(2)Section 143(3)Section 147Section 142(1)Section 119Section 144Section 250Section 292B
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Issues it is cited on

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Judgments citing Commissioner of Customs v. Indian Oil Corporation Ltd.

ACIT, Ltu-2, Kolkata vs. M/S Titagarh Wagons Ltd., Kolkata

In the result, the appeal by the Revenue is dismissed

ITA 807/KOL/2015[2009-2010]Status: DisposedITAT Kolkata17 Aug 2017AY 2009-2010

Bench: Hon’Ble Shri N.V.Vasudevan, Jm & Dr.Arjun Lal Saini, Am ] Assessment Year : 2009-10

For Appellant: Shri G.H.Sema, Addl. CIT(DR)For Respondent: Shri Sujoy Sen, Advocate

…e CBDT Circular No.21/2015 referred to above. 5. It is a settled law that the Circulars issued by CBDT are binding on the Revenue. This position was confirmed by the Apex Court in the case of Commissioner of Customs vs Indian Oil Corporation Ltd. reported in 267 ITR 272 wherein their Lordships examined the earlier decisions of the Apex Court with regard to binding nature of the Circular and laid down that when a circular issued by the Board remains in operation then the Revenue is bound by it and cannot be allowed to ITA No.807/Kol/2015 M/s. Titagarh Wagons Ltd. A.Y.2009-10 plead that it is not valid or that it…

ITO(E), WD-1(4), Kolkata vs. Mamata Shankar Ballet Troupe, Kolkata

1300/Kol/2010

ITA 2137/KOL/2016[2012-13]Status: DisposedITAT Kolkata02 Aug 2017AY 2012-13

Bench: Hon’Ble Shri A.T.Varkey, Jm & Shri M.Balaganesh, Am ] I.T.A No. 1300/Kol/2010 Assessment Year : 2006-07 Mamata Shankar Ballet Troupe, -Vs- Ddit(Exemption)-Ii, Kolkata Kolkata [Pan : Aaatm8509N] (Appellant) (Respondent)

For Appellant: Shri Soumitra Choudhury, AdvocateFor Respondent: Shri Sital Chandra Das, Addl.CIT(DR)
Section 143(3)

…imits shall apply retrospectively to pending appeals also. We find that the Circular is binding on the tax authorities. This position has been confirmed by the Hon’ble Apex Court in the case of Commissioner of Customs vs Indian Oil Corporation Ltd reported in 267 ITR 272 (SC) wherein their Lordships examined the earlier decisions of the Apex Court with regard to binding nature of the Circulars and laid down that when a Circular issued by the Board remains in operation then the revenue is bound by it and cannot be allowed to plead that it is not valid or that it is contrary to the terms of the statute. Hence we ho…

ITO(E), WD-1(4), Kolkata vs. Mamata Shankar Ballet Troupe, Kolkata

1300/Kol/2010

ITA 2136/KOL/2016[2011-12]Status: DisposedITAT Kolkata02 Aug 2017AY 2011-12

Bench: Hon’Ble Shri A.T.Varkey, Jm & Shri M.Balaganesh, Am ] I.T.A No. 1300/Kol/2010 Assessment Year : 2006-07 Mamata Shankar Ballet Troupe, -Vs- Ddit(Exemption)-Ii, Kolkata Kolkata [Pan : Aaatm8509N] (Appellant) (Respondent)

For Appellant: Shri Soumitra Choudhury, AdvocateFor Respondent: Shri Sital Chandra Das, Addl.CIT(DR)
Section 143(3)

…imits shall apply retrospectively to pending appeals also. We find that the Circular is binding on the tax authorities. This position has been confirmed by the Hon’ble Apex Court in the case of Commissioner of Customs vs Indian Oil Corporation Ltd reported in 267 ITR 272 (SC) wherein their Lordships examined the earlier decisions of the Apex Court with regard to binding nature of the Circulars and laid down that when a Circular issued by the Board remains in operation then the revenue is bound by it and cannot be allowed to plead that it is not valid or that it is contrary to the terms of the statute. Hence we ho…

ITO(E), WD-1(4), Kolkata vs. Mamata Shankar Ballet Troupe, Kolkata

1300/Kol/2010

ITA 2135/KOL/2016[2010-11]Status: DisposedITAT Kolkata02 Aug 2017AY 2010-11

Bench: Hon’Ble Shri A.T.Varkey, Jm & Shri M.Balaganesh, Am ] I.T.A No. 1300/Kol/2010 Assessment Year : 2006-07 Mamata Shankar Ballet Troupe, -Vs- Ddit(Exemption)-Ii, Kolkata Kolkata [Pan : Aaatm8509N] (Appellant) (Respondent)

For Appellant: Shri Soumitra Choudhury, AdvocateFor Respondent: Shri Sital Chandra Das, Addl.CIT(DR)
Section 143(3)

…imits shall apply retrospectively to pending appeals also. We find that the Circular is binding on the tax authorities. This position has been confirmed by the Hon’ble Apex Court in the case of Commissioner of Customs vs Indian Oil Corporation Ltd reported in 267 ITR 272 (SC) wherein their Lordships examined the earlier decisions of the Apex Court with regard to binding nature of the Circulars and laid down that when a Circular issued by the Board remains in operation then the revenue is bound by it and cannot be allowed to plead that it is not valid or that it is contrary to the terms of the statute. Hence we ho…

ITO(E), WD-1(4), Kolkata vs. Mamata Shankar Ballet Troupe, Kolkata

1300/Kol/2010

ITA 2134/KOL/2016[2007-08]Status: DisposedITAT Kolkata02 Aug 2017AY 2007-08

Bench: Hon’Ble Shri A.T.Varkey, Jm & Shri M.Balaganesh, Am ] I.T.A No. 1300/Kol/2010 Assessment Year : 2006-07 Mamata Shankar Ballet Troupe, -Vs- Ddit(Exemption)-Ii, Kolkata Kolkata [Pan : Aaatm8509N] (Appellant) (Respondent)

For Appellant: Shri Soumitra Choudhury, AdvocateFor Respondent: Shri Sital Chandra Das, Addl.CIT(DR)
Section 143(3)

…imits shall apply retrospectively to pending appeals also. We find that the Circular is binding on the tax authorities. This position has been confirmed by the Hon’ble Apex Court in the case of Commissioner of Customs vs Indian Oil Corporation Ltd reported in 267 ITR 272 (SC) wherein their Lordships examined the earlier decisions of the Apex Court with regard to binding nature of the Circulars and laid down that when a Circular issued by the Board remains in operation then the revenue is bound by it and cannot be allowed to plead that it is not valid or that it is contrary to the terms of the statute. Hence we ho…

ITO(E), WD-1(4), Kolkata vs. Mamata Shankar Ballet Troupe, Kolkata

1300/Kol/2010

ITA 2133/KOL/2016[2003-04]Status: DisposedITAT Kolkata02 Aug 2017AY 2003-04

Bench: Hon’Ble Shri A.T.Varkey, Jm & Shri M.Balaganesh, Am ] I.T.A No. 1300/Kol/2010 Assessment Year : 2006-07 Mamata Shankar Ballet Troupe, -Vs- Ddit(Exemption)-Ii, Kolkata Kolkata [Pan : Aaatm8509N] (Appellant) (Respondent)

For Appellant: Shri Soumitra Choudhury, AdvocateFor Respondent: Shri Sital Chandra Das, Addl.CIT(DR)
Section 143(3)

…imits shall apply retrospectively to pending appeals also. We find that the Circular is binding on the tax authorities. This position has been confirmed by the Hon’ble Apex Court in the case of Commissioner of Customs vs Indian Oil Corporation Ltd reported in 267 ITR 272 (SC) wherein their Lordships examined the earlier decisions of the Apex Court with regard to binding nature of the Circulars and laid down that when a Circular issued by the Board remains in operation then the revenue is bound by it and cannot be allowed to plead that it is not valid or that it is contrary to the terms of the statute. Hence we ho…

ITO(E), WD-1(4), Kolkata vs. Mamata Shankar Ballet Troupe, Kolkata

1300/Kol/2010

ITA 2132/KOL/2016[2002-03]Status: DisposedITAT Kolkata02 Aug 2017AY 2002-03

Bench: Hon’Ble Shri A.T.Varkey, Jm & Shri M.Balaganesh, Am ] I.T.A No. 1300/Kol/2010 Assessment Year : 2006-07 Mamata Shankar Ballet Troupe, -Vs- Ddit(Exemption)-Ii, Kolkata Kolkata [Pan : Aaatm8509N] (Appellant) (Respondent)

For Appellant: Shri Soumitra Choudhury, AdvocateFor Respondent: Shri Sital Chandra Das, Addl.CIT(DR)
Section 143(3)

…imits shall apply retrospectively to pending appeals also. We find that the Circular is binding on the tax authorities. This position has been confirmed by the Hon’ble Apex Court in the case of Commissioner of Customs vs Indian Oil Corporation Ltd reported in 267 ITR 272 (SC) wherein their Lordships examined the earlier decisions of the Apex Court with regard to binding nature of the Circulars and laid down that when a Circular issued by the Board remains in operation then the revenue is bound by it and cannot be allowed to plead that it is not valid or that it is contrary to the terms of the statute. Hence we ho…

ITO(E), WD-1(4), Kolkata vs. Mamata Shankar Ballet Troupe, Kolkata

1300/Kol/2010

ITA 2131/KOL/2016[1998-99]Status: DisposedITAT Kolkata02 Aug 2017AY 1998-99

Bench: Hon’Ble Shri A.T.Varkey, Jm & Shri M.Balaganesh, Am ] I.T.A No. 1300/Kol/2010 Assessment Year : 2006-07 Mamata Shankar Ballet Troupe, -Vs- Ddit(Exemption)-Ii, Kolkata Kolkata [Pan : Aaatm8509N] (Appellant) (Respondent)

For Appellant: Shri Soumitra Choudhury, AdvocateFor Respondent: Shri Sital Chandra Das, Addl.CIT(DR)
Section 143(3)

…imits shall apply retrospectively to pending appeals also. We find that the Circular is binding on the tax authorities. This position has been confirmed by the Hon’ble Apex Court in the case of Commissioner of Customs vs Indian Oil Corporation Ltd reported in 267 ITR 272 (SC) wherein their Lordships examined the earlier decisions of the Apex Court with regard to binding nature of the Circulars and laid down that when a Circular issued by the Board remains in operation then the revenue is bound by it and cannot be allowed to plead that it is not valid or that it is contrary to the terms of the statute. Hence we ho…

ITO, WD-1(2), Kolkata vs. M/S Pearl Transport Company Ltd, Kolkata

In the result, appeal of revenue is dismissed

ITA 802/KOL/2014[2006-2007]Status: DisposedITAT Kolkata13 Jul 2017AY 2006-2007

Bench: "ी ऐ. ट". वक", "यायीक सद"य एवं/And "ी एम .बालागणेश, लेखा सद"य) [Before Shri A. T. Varkey, Jm & Shri M. Balaganesh, Am]

…imits shall apply retrospectively to pending appeals also. We find that the Circular is binding on the tax authorities. This position has been confirmed by the Hon’ble Apex Court in the case of Commissioner of Customs vs Indian Oil Corporation Ltd reported in 267 ITR 272 (SC). Hence, we hold that the appeal of the revenue deserves to be dismissed in terms of low tax effect vide Circular No.21 / 2015 dated 10.12.2015. Accordingly, this being a low tax effect case, we dismiss this appeal of revenue 2 Pearl Transport Co. Ltd., AY 2006-07 in limine, as unadmitted, without going into the merits of the case. In case…

DCIT(TDS) Cir-58, Kolkata vs. Punjab National Bank, Kolkata

In the result, appeal of revenue is dismissed

ITA 934/KOL/2014[2009-2010]Status: DisposedITAT Kolkata12 Jul 2017AY 2009-2010

Bench: "ी ऐ. ट". वक", "यायीक सद"य एवं/And "ी एम .बालागणेश, लेखा सद"य) [Before Shri A. T. Varkey, Jm & Shri M. Balaganesh, Am]

…imits shall apply retrospectively to pending appeals also. We find that the Circular is binding on the tax authorities. This position has been confirmed by the Hon’ble Apex Court in the case of Commissioner of Customs vs Indian Oil Corporation Ltd reported in 267 ITR 272 (SC). Hence, we hold that the appeal of the revenue deserves to be dismissed in terms of low tax effect vide Circular No.21 / 2015 dated 10.12.2015. Accordingly, this being a low tax effect 2 Punjab National Bank, AY 2009-10 case, we dismiss this appeal of revenue in limine, as unadmitted, without going into the merits of the case. In case the…

ITO, Ward-9(4), Kolkata vs. M/S Sagar Trexim(P) Ltd., Kolkata

In the result, the appeal by the Revenue is dismissed

ITA 715/KOL/2012[1996-1997]Status: DisposedITAT Kolkata31 May 2017AY 1996-1997

Bench: Hon’Ble Shri Aby. T. Varkey, Jm & Dr.Arjun Lal Saini, Am ] Assessment Year : 1996-97 I.T.O. Ward 9(4) -Versus- M/S. Sagar Trexim (P) Ltd. Kolkata Kolkata (Pan:Aaecs8194E) (Appellant) (Respondent) For The Appellant: Shri R.P. Nag, Addl, Cit For The Respondent: None Date Of Hearing : 31.05.2017 Date Of Pronouncement : 31.05.2017 Order Per Dr. A.L. Saini, Am: This Is An Appeal By The Revenue Against The Order Dated 15.03.2012 Of Cit(A)-Viii, Kolkata Relating To A.Y.1996-97. 2. Recently The Cbdt Has Issued Circular No. 21/2015, Dated 10Th December, 2015, Whereby The Monetary Limits For Filing Of Appeals By The Department Before Income Tax Appellate Tribunal & High Courts & Slp Before Supreme Court Have Been Increased As Measure For Reducing Litigation. The Revised Monetary Limits Laid Down In Para-3 Of This Circular & The Manner Of Computing Tax Effect As Laid Down In Para-4 Of This Circular Are As Follows: “3. Henceforth, Appeals/ Slps Shall Not Be Filed In Cases Where The Tax Effect Does Not Exceed The Monetary Limits Given Hereunder: - Sl. No. Appeals In Income-Tax Matters Monetary Limit (In Rs) 1. Before Appellate Tribunal 10,00,000/- 2. Before High Court 20,00,000/- 3. Before Supreme Court 25,00,000/-

For Appellant: Shri R.P. Nag, Addl, CITFor Respondent: None
Section 68

…he CBDT Circular No.21/2015 referred to above. 5. It is a settled law that the Circulars issued by CBDT are binding on the Revenue. This position was confirmed by the Apex Court in the case of Commissioner of Customs vs Indian Oil Corporation Ltd. reported in 267 ITR 272 wherein their Lordships examined the earlier decisions of the Apex Court with regard to binding nature of the Circular and laid down that when a circular issued by the Board remains in operation then the Revenue is bound by it and cannot be allowed to ITA No. 715/Kol/2012- M/s. Sagar Trexim (P) Ltd. A.Y. 1996-97 3 plead that it is not valid or t…

DCIT, Circle-3, Kolkata, Darjeeling vs. Narendra Tea Company (P) Ltd., Kolkata

In the result, all the appeals of revenue are dismissed

ITA 1517/KOL/2014[2009-10]Status: DisposedITAT Kolkata24 May 2017AY 2009-10

Bench: Shri A. T. Varkey, Jm & Dr. A. L. Saini, Am]

Section 10A

…(P) Ltd.. AYs 2009-10 to 2011-12 to pending appeals also. We find that the Circular is binding on the tax authorities. This position has been confirmed by the Hon’ble Apex Court in the case of Commissioner of Customs vs Indian Oil Corporation Ltd reported in 267 ITR 272 (SC). Hence, we hold that the appeal of the revenue deserves to be dismissed in terms of low tax effect vide Circular No.21 / 2015 dated 10.12.2015. Accordingly, this being a low tax effect case, we dismiss this appeal of revenue in limine, as unadmitted, without going into the merits of the case. In case the revenue later finds that the tax effe…

ACIT, Cir-33, Kolkata vs. Ashok Chaudhary

In the result, appeal of the revenue is dismissed

ITA 654/KOL/2014[2008-2009]Status: DisposedITAT Kolkata18 May 2017AY 2008-2009

Bench: Shri P. M. Jagtap, Am & Shri A. T. Varkey, Jm]

…1 Ashok Chaudhary, AY 2008-09 IN THE INCOME TAX APPELLATE TRIBUNAL “A” BENCH: KOLKATA [Before Shri P. M. Jagtap, AM & Shri A. T. Varkey, JM] I.T.A. No. 654/Kol/2014 Assessment Year: 2008-09 Assistant Commissioner of Income-tax, Vs. Ashok Chaudhary, Circle-33, Kolkata (PAN:ACRPC5234B). Appellant Respondent Date of Hearing 18.05.2017 Date of Pronouncement 18.05.2017 For the Appellant Shri Sallong Yaden, Addl. CIT For the Respondent Shri Shital Khemka, AR ORDER Per Shri A.T.Varkey, JM This is an appeal filed by the revenue against the order of Ld. CIT(A)-X1X, Kolkata dated 07.01.2014 for AY 2008-09. 2. At the…

ACIT, Circle-35, Kolkata vs. M/S. N.M. Exports, Kolkata

In the result, the appeals by the Revenue are dismissed

ITA 2016/KOL/2014[2005-2006]Status: DisposedITAT Kolkata03 May 2017AY 2005-2006

Bench: Hon’Ble Shri N.V.Vasudevan, Jm & Shri M.Balaganesh, Am ]

For Appellant: Shri Goulen Hangshing, CIT(DR)For Respondent: Shri S.M.Surana, Advocate

…e CBDT Circular No.21/2015 referred to above. 5. It is a settled law that the Circulars issued by CBDT are binding on the Revenue. This position was confirmed by the Apex Court in the case of Commissioner of Customs vs Indian Oil Corporation Ltd. reported in 267 ITR 272 wherein their Lordships examined the earlier decisions of the Apex Court with regard to binding nature of the Circular and laid down that when a circular issued by the Board remains in operation then the Revenue is bound by it and cannot be allowed to ITA No.2016&2017/Kol/2014- M/s. N.M.Exports A.Y.2005-06 & 2006-07 plead that it is not valid or…

ACIT, Circle-Murshidabad, Murshidabad vs. M/S. Suman Modern Rice Mill Pvt. Ltd., Murshidabad

In the result, the appeal by the Revenue is dismissed

ITA 1968/KOL/2014[2010-2011]Status: DisposedITAT Kolkata03 May 2017AY 2010-2011

Bench: Hon’Ble Shri N.V.Vasudevan, Jm & Shri Waseem Ahmed, Am ]

For Appellant: Shri Rajat Kumar Kureel, JCIT., Sr.DRFor Respondent: Shri Anil Kochar, AR

…e CBDT Circular No.21/2015 referred to above. 5. It is a settled law that the Circulars issued by CBDT are binding on the Revenue. This position was confirmed by the Apex Court in the case of Commissioner of Customs vs Indian Oil Corporation Ltd. reported in 267 ITR 272 wherein their Lordships examined the earlier decisions of the Apex Court with regard to binding nature of the Circular and laid down that when a circular issued by the Board remains in operation then the Revenue is bound by it and cannot be allowed to ITA No.1968/Kol/2014 M/s. Suman Modern Rice Mill Pvt. Ltd. A.Y.2010-11 plead that it is not val…

Income Tax Officer-Ward-3(2), Kolkata vs. M/S Refraset Engineers(India) Pvt. Ltd., Kolkata

In the result, the appeal by the Revenue is dismissed

ITA 2871/KOL/2013[2005-2006]Status: DisposedITAT Kolkata03 May 2017AY 2005-2006

Bench: Hon’Ble Shri N.V.Vasudevan, Jm & Shri Waseem Ahmed, Am ]

For Appellant: Shri Rajat Kumar Kureel, JCIT., Sr.DRFor Respondent: Shri Manish Tiwari, AR

…e CBDT Circular No.21/2015 referred to above. 5. It is a settled law that the Circulars issued by CBDT are binding on the Revenue. This position was confirmed by the Apex Court in the case of Commissioner of Customs vs Indian Oil Corporation Ltd. reported in 267 ITR 272 wherein their Lordships examined the earlier decisions of the Apex Court with regard to binding nature of the Circular and laid down that when a circular issued by the Board remains in operation then the Revenue is bound by it and cannot be allowed to ITA No..2871/Kol/2013-M/s. Refraset Engineers (India)Pvt.Ltd. A.Y.2005-06 plead that it is not…

DCIT, New Delhi vs. Shri Ajay Kumar, Noida

The appeals of the Revenue are dismissed

ITA 4214/DEL/2014[2011-12]Status: DisposedITAT Delhi24 Apr 2017AY 2011-12

Bench: Shri G.D. Agrawal & Shri K.N. Charry

…its shall apply retrospectively to pending appeals also. We find that the Circular is binding on the tax authorities. This position has been confirmed by the Hon’ble Apex Court in the case of Commissioner of Customs vs Indian Oil Corporation Ltd reported in 267 ITR 272 (SC). Hence, we hold that the appeal of the revenue deserves to be dismissed in terms of low tax effect vide Circular No.21 / 2015 dated 10.12.2015. Accordingly, this being a low tax effect case, we dismiss this appeal of revenue in limine, as un-admitted, without going into the merits of the case. 4. Ld. AR not pressed the cross objections. He…

DCIT, New Delhi vs. Shri Ajay Kumar, Noida

The appeals of the Revenue are dismissed

ITA 4213/DEL/2014[2010-11]Status: DisposedITAT Delhi24 Apr 2017AY 2010-11

Bench: Shri G.D. Agrawal & Shri K.N. Charry

…its shall apply retrospectively to pending appeals also. We find that the Circular is binding on the tax authorities. This position has been confirmed by the Hon’ble Apex Court in the case of Commissioner of Customs vs Indian Oil Corporation Ltd reported in 267 ITR 272 (SC). Hence, we hold that the appeal of the revenue deserves to be dismissed in terms of low tax effect vide Circular No.21 / 2015 dated 10.12.2015. Accordingly, this being a low tax effect case, we dismiss this appeal of revenue in limine, as un-admitted, without going into the merits of the case. 4. Ld. AR not pressed the cross objections. He…

ACIT, New Delhi vs. Sh. Anil Arora, Delhi

In the result, the appeal of the revenue is dismissed

ITA 3436/DEL/2014[2008-09]Status: DisposedITAT Delhi20 Apr 2017AY 2008-09

Bench: Shri G.D. Agrawal, Hon’Ble & Shri K.N. Charry

…its shall apply retrospectively to pending appeals also. We find that the Circular is binding on the tax authorities. This position has been confirmed by the Hon’ble Apex Court in the case of Commissioner of Customs vs Indian Oil Corporation Ltd reported in 267 ITR 272 (SC). Hence, we hold that the appeal of the revenue deserves to be dismissed in terms of low tax effect vide Circular No.21 / 2015 dated 10.12.2015. 3 Accordingly, this being a low tax effect case, we dismiss this appeal of revenue in limine, as un-admitted, without going into the merits of the case. 4. In the result, the appeal of the revenu…

DCIT, New Delhi vs. M/S. Bodhi Properties Pvt. Ltd., New Delhi

In the result, the appeal of the revenue is dismissed

ITA 3401/DEL/2014[2006-07]Status: DisposedITAT Delhi20 Apr 2017AY 2006-07

Bench: Shri G.D. Agrawal, Hon’Ble & Shri K.N. Charry

…its shall apply retrospectively to pending appeals also. We find that the Circular is binding on the tax authorities. This position has been confirmed by the Hon’ble Apex Court in the case of Commissioner of Customs vs Indian Oil Corporation Ltd reported in 267 ITR 272 (SC). Hence, we hold that the appeal of the revenue deserves to be dismissed in terms of low tax effect vide Circular No.21 / 2015 dated 10.12.2015. Accordingly, this being a low tax effect case, we dismiss this appeal 3 of revenue in limine, as unadmitted, without going into the merits of the case. 4. In the result, the appeal of the revenue…