What is Smt. Tarulata Shyam v. CIT authority for?

Taxing statutes must be interpreted strictly, assuming that the law-making authority does not commit a mistake or make an omission. There is no room for purposive interpretation under direct tax laws.

How many judgments cite Smt. Tarulata Shyam v. CIT?

209 judgments on BharatTax cite Smt. Tarulata Shyam v. CIT (108 ITR 345), spanning 2009 to 2026.

Which sections of the Income Tax Act does Smt. Tarulata Shyam v. CIT come up under?

It is most often cited in judgments turning on Section 143(3), Section 147, Section 132, Section 148, Section 5, Section 4.

Smt. Tarulata Shyam v. CIT (108 ITR 345)

Jairam Gulumal Diyalani, Bharuch vs. ITO, Ward1(5), Bharuch

In the result, appeal of the assessee is allowed

ITA 171/SRT/2019[2014-15]Status: DisposedITAT Surat30 Jan 2023AY 2014-15

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकर अपील सं./Ita No.171/Srt/2019 ("नधा"रणवष" / Assessment Year: (2014-15) (Virtual Court Hearing) Jairam Gulumal Diyalani Income Tax Officer, M/S Tulsi Saree, Main Bazar, Ward-1(5), Bharuch Vs. Jambusar, Dist. Bharuch- 392150 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Acgpd 8463 L (Appellant) (Respondent) िनधा"रती की ओर से /Assessee By : Shri Mehul K Patel, Advocate राज"व क" ओर से /Respondent By : Shri Ashok B. Koli, Cit-D.R सुनवाई की तारीख/ Date Of Hearing : 17/01/2023 घोषणा की तारीख/Date Of Pronouncement : 30/01/2023 आदेश / Order Per Dr. A. L. Saini, Am: By Way Of This Appeal, The Assessee Has Challenged The Correctness Of The Order Passed By The Learned Principal Commissioner Of Income Tax-3, Vadodara (In Short “Ld. Pcit”] Dated 07.12.2018, Under Section 263 Of The Income Tax Act, 1961 (Hereinafter Referred To As “The Act”), For Assessment Year 2014-15. 2. Grounds Of Appeal Raised By The Assessee Are As Follows: “1.0 The Learned Commissioner Of Income Tax-3, Baroda, Has Erred In Law & On Facts In Holding That The Assessment Order Dated 29-12-2016 Passed Under Section 143(3) Of The Income Tax Act, 1961 Is Erroneous & Prejudicial To The Interest Of Revenue & Thereby Erred In Invoking The Provisions Of Section 263 Of The I T Act. 2.0 The Learned Commissioner Of Income Tax-3, Baroda Has Erred In Law & On Facts In Directing The Assessing Officer To Make Additions Of Rs.9,00,000/- On Account Of Total Sums Received From Investment Made In Property Situated At Mumbai. 2.1 The Learned Commissioner Of Income Tax-3, Baroda Ought To Have Appreciated That The Overall Additions On Account Of The Total Amount Received Have Already Been Made In One Year Or The Other & That There Is No Loss Of Revenue.

For Appellant: Shri Mehul K Patel, AdvocateFor Respondent: Shri Ashok B. Koli, CIT-D.R

Section 133ASection 139(1)Section 143(3)Section 263

…before or after the relevant previous year are wholly immaterial in assessing income of the year. Useful reference may be made to the decision of the Hon'ble Supreme Court in ITA No. 171/SRT/2019 A.Y.14-15 Jairam G Diyalani the case of Tarulata Shyam Vs. CIT 108 ITR 345 (SC). Further, as per section 5(1) of the I.T. Act, 1961, the total income of any previous year of a person who is a resident includes all income from whatever source derived which- (a) is received or is deemed to be received in India in such year by or on behalf of such person; or (b) accrues or arises or is deemed to accrue or arise to him in I…

Shri Ramalingam Nagarajan, Chennai vs. ITO, Ncw - 21 (3), Chennai

In the result, appeal filed by the assessee is dismissed

ITA 1729/CHNY/2019[2015-16]Status: DisposedITAT Chennai11 Jan 2023AY 2015-16

Bench: Shri Mahavir Singh, Hon’Ble & Shri G. Manjunatha, Hon’Ble

For Appellant: Mr.N.Arjunraj, CAFor Respondent: Mr. AR.V.Sreenivasan

Section 54Section 54(2)

…enefit of exemption u/s.54 of the Act. The Ld.CIT(A) after considering relevant submissions of the assessee and also by relying upon the decision of the Hon’ble Supreme Court in the case of Smt.Tarulata Shyam and Others v. CIT West Bengal reported in [1977] 108 ITR 345 (SC) rejected the arguments of the assessee and sustained the additions made by the AO towards disallowance of exemption claimed u/s.54 of the Act. The relevant findings of the Ld.CIT(A) are as under: 5.1 CIT’s decision: The findings of the A.O as per the assessment order have been considered. Further, the written submissions filed by the A.R…

Trilok Parumal Motiani, Mumbai vs. ITO 21(3)(4), Mumbai

In the result, the first question must be answered in the affirmative and in favour of the Revenue

ITA 4542/MUM/2019[2012-13]Status: DisposedITAT Mumbai06 Jan 2023AY 2012-13

Bench: Shri Sandeep Singh Karhail & Shri Gagan Goyaltrilok Parumal Motiani, 213/214, Kalyandas Udyog Bhavan, Near Century Bazar, Prabhadevi, Mumbai-400025. Pan: Aahpm3289N ...... Appellant Vs. Ito-21(3)(4), 206, Piramal Chamber, Lalbaug, Mumbai-400012 ..... Respondent Appellant By : Sh. M. Subramanian Respondent By : Sh. Purnesh Gururani, Sr.Dr Date Of Hearing : 13/10/2022 Date Of Pronouncement : 06/01/2023 Order Per Gagan Goyal, A.M: This Appeal By The Assessee Is Directed Against The Order Of Commissioner Of Income Tax (Appeal)-48, Mumbai (For Short ‘Cit(A)’) Dated 30.04.2019 Under Section 143(3) Of The Income Tax Act, 1961 (For Short ‘The Act’) For A.Y. 2012-13. The Assessee Has Raised The Following Grounds Of Appeal:

For Appellant: Sh. M. SubramanianFor Respondent: Sh. Purnesh Gururani, Sr.DR

Section 143(3)Section 2(22)(e)Section 48

…IN THE INCOME TAX APPELLATE TRIBUNAL MUMBAI BENCH “SMC”, MUMBAI BEFORE SHRI SANDEEP SINGH KARHAIL, JUDICIAL MEMBER AND SHRI GAGAN GOYAL, ACCOUNTANT MEMBER Trilok Parumal Motiani, 213/214, Kalyandas Udyog Bhavan, Near Century Bazar, Prabhadevi, Mumbai-400025. PAN: AAHPM3289N ...... Appellant Vs. ITO-21(3)(4), 206, Piramal Chamber, Lalbaug, Mumbai-400012 ..... Respondent Appellant by : Sh. M. Subramanian Respondent by : Sh. Purnesh Gururani, Sr.DR Date of hearing : 13/10/2022 Date of pronouncement : 06/01/2023 ORDER PER GAGAN GOYAL, A.M: This appeal by the assessee is directed against the order of Commissioner o…

Shri Sanjay Shantilal Jain, Mumbai vs. JCIT, Central Range-8, Mumbai

In the result, the appeals of the assessee for assessment year

ITA 6140/MUM/2018[2011-12]Status: DisposedITAT Mumbai30 Nov 2022AY 2011-12

Bench: Shri Om Prakash Kant () & Shri Sandeep Singh Karhail () Assessment Year: 2011-12 & Assessment Year: 2011-12 & Assessment Year: 2012-13 & Assessment Year: 2013-14 & Assessment Year: 2014-15

For Respondent: Assessee by Mr. Rushabh Mehta

Section 269SSection 271DSection 273B

…s made by the company in the usual and true commercial sense, Le, profits made by the company in the usual and true commercial sense, Le, profits made by the company in the usual and true sense of the term. 18.6 In the case of Smt. TarulataShyam v. CIT [1977] 108 ITR 345 (SC), the 18.6 In the case of Smt. TarulataShyam v. CIT [1977] 108 ITR 345 (SC), the 18.6 In the case of Smt. TarulataShyam v. CIT [1977] 108 ITR 345 (SC), the Hon'ble Supreme Court had held that the position reflected in the books at Hon'ble Supreme Court had held that the position reflected in the books at Hon'ble Supreme Court had held that th…

ACIT Central Cir. 6(4), Mumbai vs. Shri Ajay Virendra Arora, Mumbai

In the result, the appeal filed by the revenue stands dismissed

ITA 2149/MUM/2021[2017-18]Status: DisposedITAT Mumbai22 Nov 2022AY 2017-18

Bench: Shri Amit Shukla, Jm & Shri S. Rifaur Rahman, Am आयकरअपीलसं./ I.T.A. No. 2149/Mum/2021 (निर्धारणवर्ा / Assessment Year: 2017-18) Shri Ajay Virendra Acit-Cen.Circle – 6(4), Arora, R. No. 1925, 19Th Floor, Air 6Th Floor, S14, Solitaire India Building, Nariman बिधम/ Corporate Park, Guru Point, Mumbai-400 021 Vs. Hargovindji Marg, Chakala, Andheri(East), Mumbai-400 093 स्थायीलेखासं./जीआइआरसं./ Pan No. Addpa6742R (अपीलाथी/Appellant) (प्रत्यथी / Respondent) : अपीलाथीकीओरसे/ Appellant By : Shri Salil Mishra, Ld. Dr प्रत्यथीकीओरसे/Respondent By : Shri Jitendra Jain/ Shri Ravikant Pathak, Ld. Ars सुनवाईकीतारीख/ : 03.10.2022 Date Of Hearing घोषणाकीतारीख / : 22.11.2022 Date Of Pronouncement आदेश / O R D E R Per Amit Shukla: The Aforesaid Appeal Has Been Filed By The Revenue Against The Impugned Order Dated 25.08.2021, Passed By Ld. Cit(A)-54, Mumbai For The Quantum Of Assessment Passed U/S 153A R.W.S.

For Appellant: Shri Salil Mishra, Ld. DRFor Respondent: Shri Jitendra Jain/ Shri

Section 153ASection 19Section 2Section 2(22)(e)

…ount, which does not provide definition of the same." 4. "On the facts and in the circumstances of the case and in law, the learned CIT(A) has erred in not considering the decisions of the Hon'ble Supreme Court in the case of Tarulata Shyam & Ors. Vs. CIT(SC) 108 ITR 345 and Sarada Vs. CIT (SC) 229 ITR 444." 2. The facts in brief are that, assessee has been showing salary income in the capacity of a Directors in; D‟ Decor Home Fabrics Pvt. Ltd., Home Idea Curtain Fabrics and Home Idea Upholstery Pvt. Ltd. The assessee has also shown income from house property, capital gains and other sources. The return of income…

ACIT, Circle- 29(1), New Delhi vs. Krishak Bharati Cooperative Ltd., New Delhi

In the result, the appeals of the assessee are allowed and that of the Revenue are dismissed

ITA 7242/DEL/2018[2014-15]Status: DisposedITAT Delhi14 Nov 2022AY 2014-15

Bench: Sh. N. K. Choudharydr. B. R. R. Kumarita No. 6364/Del/2018 : Asstt. Year : 2013-14 Ita No. 6365/Del/2018 : Asstt. Year : 2014-15 M/S Krishak Bharati Cooperative Ltd., Vs Acit, A-60, Kailash Colony, Circle-30(1), New Delhi-110048 New Delhi-110002 (Appellant) (Respondent) Pan No. Aaaak0203G Ita No. 7241/Del/2018 : Asstt. Year : 2013-14 Ita No. 7242/Del/2018 : Asstt. Year : 2014-15 Acit, Vs M/S Krishak Bharati Cooperative Ltd., Circle-29(1), A-60, Kailash Colony, New Delhi-110002 New Delhi-110048 (Appellant) (Respondent) Pan No. Aaaak0203G Assessee By : Sh. K.V.S.R. Krishna, Ca & Sh. Aman Goel, Ca Revenue By : Ms. Sapna Bhatia, Cit Dr & Sh. Ravi Kant Choudhary, Sr. Dr Date Of Hearing: 01.09.2022 Date Of Pronouncement: 14.11.2022

For Appellant: Sh. K.V.S.R. Krishna, CA &For Respondent: Ms. Sapna Bhatia, CIT DR &

Section 143(3)Section 14ASection 90

…income during the year should also be considered for arriving at the average of investment.” 6. “On the facts and in the circumstances of the case, the Ld. CIT(A) did not consider the ratio of judgment of Hon’ble Supreme Court in the case of Tarulata Shyam, 108 ITR 345 wherein it was that held that there is no scope importing into the statute words which are not there.” 7. “The Appellant reserves the right to raise any further and additional grounds of appeal at the item of hearing oral arguments including reliance on additional case laws.” Revenue Appeal ITA No. 7241/Del/2018 : A.Y. 2013-14 ITA No. 7242/Del/…

ACIT, Circle- 29(1), New Delhi vs. Krishak Bharati Cooperative Ltd., New Delhi

In the result, the appeals of the assessee are allowed and that of the Revenue are dismissed

ITA 7241/DEL/2018[2013-14]Status: DisposedITAT Delhi14 Nov 2022AY 2013-14

Bench: Sh. N. K. Choudharydr. B. R. R. Kumarita No. 6364/Del/2018 : Asstt. Year : 2013-14 Ita No. 6365/Del/2018 : Asstt. Year : 2014-15 M/S Krishak Bharati Cooperative Ltd., Vs Acit, A-60, Kailash Colony, Circle-30(1), New Delhi-110048 New Delhi-110002 (Appellant) (Respondent) Pan No. Aaaak0203G Ita No. 7241/Del/2018 : Asstt. Year : 2013-14 Ita No. 7242/Del/2018 : Asstt. Year : 2014-15 Acit, Vs M/S Krishak Bharati Cooperative Ltd., Circle-29(1), A-60, Kailash Colony, New Delhi-110002 New Delhi-110048 (Appellant) (Respondent) Pan No. Aaaak0203G Assessee By : Sh. K.V.S.R. Krishna, Ca & Sh. Aman Goel, Ca Revenue By : Ms. Sapna Bhatia, Cit Dr & Sh. Ravi Kant Choudhary, Sr. Dr Date Of Hearing: 01.09.2022 Date Of Pronouncement: 14.11.2022

For Appellant: Sh. K.V.S.R. Krishna, CA &For Respondent: Ms. Sapna Bhatia, CIT DR &

Section 143(3)Section 14ASection 90

…income during the year should also be considered for arriving at the average of investment.” 6. “On the facts and in the circumstances of the case, the Ld. CIT(A) did not consider the ratio of judgment of Hon’ble Supreme Court in the case of Tarulata Shyam, 108 ITR 345 wherein it was that held that there is no scope importing into the statute words which are not there.” 7. “The Appellant reserves the right to raise any further and additional grounds of appeal at the item of hearing oral arguments including reliance on additional case laws.” Revenue Appeal ITA No. 7241/Del/2018 : A.Y. 2013-14 ITA No. 7242/Del/…

Krishak Bharati Cooperative Ltd., New Delhi vs. ACIT, Circle- 30(1), New Delhi

In the result, the appeals of the assessee are allowed and that of the Revenue are dismissed

ITA 6365/DEL/2018[2014-15]Status: DisposedITAT Delhi14 Nov 2022AY 2014-15

Bench: Sh. N. K. Choudharydr. B. R. R. Kumarita No. 6364/Del/2018 : Asstt. Year : 2013-14 Ita No. 6365/Del/2018 : Asstt. Year : 2014-15 M/S Krishak Bharati Cooperative Ltd., Vs Acit, A-60, Kailash Colony, Circle-30(1), New Delhi-110048 New Delhi-110002 (Appellant) (Respondent) Pan No. Aaaak0203G Ita No. 7241/Del/2018 : Asstt. Year : 2013-14 Ita No. 7242/Del/2018 : Asstt. Year : 2014-15 Acit, Vs M/S Krishak Bharati Cooperative Ltd., Circle-29(1), A-60, Kailash Colony, New Delhi-110002 New Delhi-110048 (Appellant) (Respondent) Pan No. Aaaak0203G Assessee By : Sh. K.V.S.R. Krishna, Ca & Sh. Aman Goel, Ca Revenue By : Ms. Sapna Bhatia, Cit Dr & Sh. Ravi Kant Choudhary, Sr. Dr Date Of Hearing: 01.09.2022 Date Of Pronouncement: 14.11.2022

For Appellant: Sh. K.V.S.R. Krishna, CA &For Respondent: Ms. Sapna Bhatia, CIT DR &

Section 143(3)Section 14ASection 90

…income during the year should also be considered for arriving at the average of investment.” 6. “On the facts and in the circumstances of the case, the Ld. CIT(A) did not consider the ratio of judgment of Hon’ble Supreme Court in the case of Tarulata Shyam, 108 ITR 345 wherein it was that held that there is no scope importing into the statute words which are not there.” 7. “The Appellant reserves the right to raise any further and additional grounds of appeal at the item of hearing oral arguments including reliance on additional case laws.” Revenue Appeal ITA No. 7241/Del/2018 : A.Y. 2013-14 ITA No. 7242/Del/…

Krishak Bharati Cooperative Ltd., New Delhi vs. ACIT, Circle- 30(1), New Delhi

In the result, the appeals of the assessee are allowed and that of the Revenue are dismissed

ITA 6364/DEL/2018[2013-14]Status: DisposedITAT Delhi14 Nov 2022AY 2013-14

Bench: Sh. N. K. Choudharydr. B. R. R. Kumarita No. 6364/Del/2018 : Asstt. Year : 2013-14 Ita No. 6365/Del/2018 : Asstt. Year : 2014-15 M/S Krishak Bharati Cooperative Ltd., Vs Acit, A-60, Kailash Colony, Circle-30(1), New Delhi-110048 New Delhi-110002 (Appellant) (Respondent) Pan No. Aaaak0203G Ita No. 7241/Del/2018 : Asstt. Year : 2013-14 Ita No. 7242/Del/2018 : Asstt. Year : 2014-15 Acit, Vs M/S Krishak Bharati Cooperative Ltd., Circle-29(1), A-60, Kailash Colony, New Delhi-110002 New Delhi-110048 (Appellant) (Respondent) Pan No. Aaaak0203G Assessee By : Sh. K.V.S.R. Krishna, Ca & Sh. Aman Goel, Ca Revenue By : Ms. Sapna Bhatia, Cit Dr & Sh. Ravi Kant Choudhary, Sr. Dr Date Of Hearing: 01.09.2022 Date Of Pronouncement: 14.11.2022

For Appellant: Sh. K.V.S.R. Krishna, CA &For Respondent: Ms. Sapna Bhatia, CIT DR &

Section 143(3)Section 14ASection 90

…income during the year should also be considered for arriving at the average of investment.” 6. “On the facts and in the circumstances of the case, the Ld. CIT(A) did not consider the ratio of judgment of Hon’ble Supreme Court in the case of Tarulata Shyam, 108 ITR 345 wherein it was that held that there is no scope importing into the statute words which are not there.” 7. “The Appellant reserves the right to raise any further and additional grounds of appeal at the item of hearing oral arguments including reliance on additional case laws.” Revenue Appeal ITA No. 7241/Del/2018 : A.Y. 2013-14 ITA No. 7242/Del/…

DCIT-Ltu - 2, Mumbai vs. Ambuja Cements Ltd, Mumbai

In the result, the appeal of the revenue is dismissed

ITA 2958/MUM/2019[2010-11]Status: DisposedITAT Mumbai07 Nov 2022AY 2010-11

Section 143(3)Section 14A

…man 623/237 ITR 589 (SC) - Prakash Nath Khanna v. CIT [2004] 135 Taxman 327/266 ITR 1 (SC) ITA Nos. 1889 and 1241/Mum/2018, 2384, 2958, 3475 and 3843/Mum/2019 Assessment years: 2010-11, 2011-12 and 2012-13 Page 41 of 99 - Smt. Tarulata Shyam v. CIT [1977] 108 ITR 345 (SC) - Padmasundara Rao v. State of Tamil Nadu [2002] 255 ITR 147 (SC) Apart from the above, it was also pointed out that DTC Bill 2013 has proposed expressly that additional depreciation would be allowed in the FY in which the P&M is used for the first time and those provisions are not made with retrospective effect. It was argued that the leg…

DCIT (Ltu) 1, Mumbai vs. Ambuja Cements Ltd, Mumbai

In the result, the appeal of the revenue is thus dismissed

ITA 3307/MUM/2015[2008-09]Status: DisposedITAT Mumbai07 Nov 2022AY 2008-09

Section 115JSection 14Section 143(3)Section 14A

…can be remedied only by legislation and not by judicial interpretation :— - Orissa State Warehousing Corpn. v. CIT [1999] 103 Taxman 623/237 ITR 589 (SC) - Prakash Nath Khanna v. CIT [2004] 135 Taxman 327/266 ITR 1 (SC) - Smt. Tarulata Shyam v. CIT [1977] 108 ITR 345 (SC) - Padmasundara Rao v. State of Tamil Nadu [2002] 255 ITR 147 (SC) ITA Nos.2968/Mum/2015 & 1665/Mum/2019 ITA Nos. 3307/Mum/2015 & 2428/Mum/2019 Assessment years: 2008-09 and 2009-10 Page 35 of 51 Apart from the above, it was also pointed out that DTC Bill 2013 has proposed expressly that additional depreciation would be allowed in the FY in…

Asst CIT Ltu, Mumbai vs. Ambuja Cements Ltd, Mumbai

In the result, the appeal of the revenue is dismissed

ITA 6405/MUM/2013[2007-08]Status: DisposedITAT Mumbai07 Nov 2022AY 2007-08

Section 143(3)Section 28

…can be remedied only by legislation and not by judicial interpretation :— - Orissa State Warehousing Corpn. v. CIT [1999] 103 Taxman 623/237 ITR 589 (SC) - Prakash Nath Khanna v. CIT [2004] 135 Taxman 327/266 ITR 1 (SC) - Smt. Tarulata Shyam v. CIT [1977] 108 ITR 345 (SC) - Padmasundara Rao v. State of Tamil Nadu [2002] 255 ITR 147 (SC) Apart from the above, it was also pointed out that DTC Bill 2013 has proposed expressly that additional depreciation would be allowed in the FY in which the P&M is used for the first time and those provisions are not made with retrospective effect. It was argued that the leg…

Ambuja Cements Ltd ( Formerly Known As Gujarat Ambuja Cements Ltd), Mumbai vs. Addl CIT 3(1), Mumbai

In the result, the appeal of the revenue is thus dismissed

ITA 2428/MUM/2013[2006-07]Status: DisposedITAT Mumbai07 Nov 2022AY 2006-07

Section 115JSection 14Section 143(3)Section 14A

…can be remedied only by legislation and not by judicial interpretation :— - Orissa State Warehousing Corpn. v. CIT [1999] 103 Taxman 623/237 ITR 589 (SC) - Prakash Nath Khanna v. CIT [2004] 135 Taxman 327/266 ITR 1 (SC) - Smt. Tarulata Shyam v. CIT [1977] 108 ITR 345 (SC) - Padmasundara Rao v. State of Tamil Nadu [2002] 255 ITR 147 (SC) ITA Nos.2968/Mum/2015 & 1665/Mum/2019 ITA Nos. 3307/Mum/2015 & 2428/Mum/2019 Assessment years: 2008-09 and 2009-10 Page 35 of 51 Apart from the above, it was also pointed out that DTC Bill 2013 has proposed expressly that additional depreciation would be allowed in the FY in…

Dr. L.S. Ravi Prakash, Bangalore vs. Deputy Commissioner of Income Tax, Circle-5(1), Bangalore

In the result, the appeal of the assessee is partly allowed

ITA 30/BANG/2021[2011-12]Status: DisposedITAT Bangalore28 Oct 2022AY 2011-12

Bench: Shri Chandra Poojari & Smt. Beena Pillaiassessment Year: 2011-12

For Appellant: Shri G. Sathyanarayana, A.RFor Respondent: Shri Praveen Karanth, D.R

Section 78

…eme Court has held in the case of P.Sarada (Supra), that the legal fiction embodied in sec. 2(22)(e) comes into play as soon as monies were paid by a company. The very same view was expressed by the Apex Court in the case of Smt. Tarulata Shyam Vs. CIT (1977)(108 ITR 345). The Cochin bench of Tribunal in the case of Gordhandas Khimji (supra) considered the decision of Hon’ble Supreme Court in the case of Tarulata Shyam (Supra) and has expressed the view that the deemed dividend assessable in any of the earlier years has to be reduced from the accumulated profits, even if it was not assessed in that year. The rele…