ADDL. COMMISSIONER OF INCOME TAXversusBHARAT V. PATEL

                         [2018] 7 S.C.R. 1067                            1067


           ADDL. COMMISSIONER OF INCOME TAX                              A
                                  v.
                         BHARAT V. PATEL
                   (Civil Appeal No. 4380 of 2018)
                          APRIL 24, 2018                                 B
  [R. K. AGRAWAL AND ABHAY MANOHAR SAPRE, JJ.]
       Income Tax Act, 1961 – s.17(2) – ‘Perquisite’ – Amendment
thereto, if retrospective – Respondent, Chairman and MD of Procter
and Gamble (P&G), India (subsidiary of (P&G) USA) was issued
                                                                         C
Stock Appreciation Rights (SARs) by (P&G) USA and received an
amount of Rs.6,80,40,724/- on its redemption – Issue as to the
taxability of the amount so received by the Respondent on redemption
of SARs – Held: “Perquisite” is usually a non-cash benefit given by
an employer to an employee in addition to entitled salary or
remuneration – In order to bring the perquisite transferred by the       D
employer to the employees within the ambit of tax, legislature brought
an amendment u/s.17 by inserting Clause (iiia) in s.17(2) of the IT
Act through the Finance Act, 1999 with effect from 01.04.2000 which
was later omitted by the Finance Act, 2000 – Since, the transaction
in the instant case pertains prior to 01.04.2000, hence, it cannot be
                                                                         E
covered under the said clause in the absence of an express provision
of retrospective effect – Finance Act, 1999 – Finance Act, 2000 –
Interpretation of Statutes.
       Interpretation of Statutes – Taxing Statutes – Held: Taxing
provisions to be construed strictly so that no person who is otherwise
                                                                         F
not liable to pay tax, be made liable to pay tax.
      Income Tax Act, 1961– s.28(iv) – When not applicable –
Respondent, employee of (P&G), India, (subsidiary of (P&G) USA)
was issued Stock Appreciation Rights (SARs.) and received an
amount of Rs.6,80,40,724/- from (P&G),USA on its redemption –
Alternate plea of Revenue that the case of the respondent came           G
within the ambit of s.28(iv) – Held: Applicability of s.28(iv) is
confined only to the case where there is any business or profession
related transaction involved – However, in the instant case there is
nothing as such and thus cannot be covered u/s.28(iv) for the
purpose of tax liability.                                                H
                               1067
1068            SUPREME COURT REPORTS                      [2018] 7 S.C.R.


 A           Dismissing the appeals, the Court
              HELD: 1.1 The word “Perquisite” in common parlance may
       be defined as any perk or benefit attached to an employee or
       position besides salary or remuneration. These are usually non-
       cash benefits given by an employer to an employee in addition to
 B     entitled salary or remuneration. It may be said that these benefits
       are generally provided by the employers in order to retain the
       talented employees in the organization. There are various
       instances of perquisite such as concessional rent accommodation
       provided by the employer, any sum paid by an employer in respect
       of an obligation which was actually payable by the employee etc.
 C     Section 17(2) of the Income Tax Act, 1961 was enacted by the
       legislature to give the broad view of term perquisite. On the other
       hand, the word ‘Capital Gains’ means a profit from the sale of
       property or an investment. It may be short term or long term
       depending upon the facts and circumstances of each case. This
 D     gain or profit is charged to tax in the year in which transfer of the
       capital assets takes place. [Para 9] [1072-G, H; 1073-A-B]
             1.2 In order to bring the perquisite transferred by the
       employer to the employees within the ambit of tax, legislature
       brought an amendment under Section 17 of the IT Act by inserting
 E     Clause (iiia) in Section 17(2) of the IT Act through the Finance
       Act, 1999 (27 of 1999) with effect from 01.04.2000, which was
       later on omitted by the Finance Act, 2000. The intention behind
       the said amendment brought by the legislature was to bring the
       benefits transferred by the employer to the employees as in the
       instant case, within the ambit of the Income Tax Act, 1961. It was
 F     the first time when the legislature specified the meaning of the
       cost for acquiring specific securities. Only by this amendment,
       legislature determined what would constitute the specific
       securities. By this amendment, legislature clearly covered the
       direct or indirect transfer of specified securities from the employer
 G     to the employees during or after the employment. On a perusal
       of the said clause, it is evident that the case of the Respondent
       falls under such clause. However, since the transaction in the
       instant case pertains to prior to 01.04.2000, hence, such
       transaction cannot be covered under the said clause in the absence
       of an express provision of retrospective effect. There is no force
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         ADDL. COMMISSIONER OF INCOME TAX v.                              1069
                  BHARAT V. PATEL

in the argument of the Revenue that the case of the Respondent            A
would fall under the ambit of Section 17(2) (iii) of the IT Act instead
of Section 17(2) (iiia) of the IT Act. It is a fundamental principle
of law that a receipt under the IT Act must be made taxable before
it can be treated as income. Courts cannot construe the law in
such a way that brings an individual within the ambit of Income
                                                                          B
Tax Act to pay tax who otherwise is not liable to pay. In the
absence of any such specific provision, if an individual is subjected
to pay tax, it would amount to the violation of his Constitutional
Right. [Paras 12, 13] [1074-B; 1075-A-D]
       1.3 On a first look of the Section 28(iv) of the IT Act, it is
apparent that such benefit or perquisite shall have arisen from           C
the business activities or profession whereas in the instant case
there is nothing as such. The applicability of Section 28(iv) is
confined only to the case where there is any business or profession
related transaction involved. Hence, the instant case cannot be
covered under Section 28(iv) of the IT Act for the purpose of tax         D
liability. [Para 17] [1078-B]
      1.4 The Respondent got the Stock Appreciation Rights
(SARs) and, eventually received an amount on account of its
redemption prior to 01.04.2000 on which the amendment of
Finance Act, 1999 (27 of 1999) came into force. In the absence of         E
any express statutory provision regarding the applicability of such
amendment from retrospective effect, there is no force in the
argument of the Revenue that such amendment came into force
retrospectively. It is well established rule of interpretation that
taxing provisions shall be construed strictly so that no person
who is otherwise not liable to pay tax, be made liable to pay tax.        F
[Para 18] [1078-C-D]
      Commissioner of Income Tax v. Infosys Technologies
      Ltd. [2008] 297 ITR 167 (SC) – relied on.
      Sumit Bhattacharya v. ACIT Circle 16(1) Mumbai                      G
      [2008] 112 ITD 1 (MUM.) (SB) – referred to.
                        Case Law Reference
      [2008] 112 ITD 1 (MUM.)           referred to        Para 7
      [2008] 297 ITR 167 (SC)           relied on          Para 8
                                                                          H
1070            SUPREME COURT REPORTS                          [2018] 7 S.C.R.


 A           CIVIL APPELLATE JURISDICTION: Civil Appeal No. 4380
       of 2018.
             From the Judgment and Order dated 23.12.2014 of the High Court
       of Gujarat at Ahmedabad in Tax Appeal No. 6 of 2004
                                        WITH
 B
             Civil Appeal No. 4381 of 2018.
             Arijit Prasad, Subhash Acharya, Mrs. Anil Katiyar, Advs. for the
       Appellant.
             Ajay Vohra, Sr. Adv., Ms. Ruby Singh Ahuja, Ms. Deepti Sarin,
 C     Shubham Saigal, Ms. Manik Karanjawala, Ms. Aakanksha Munjhal (for
       M/s. Karanjawala & Co.), Advs. for the Respondent.
             The Judgment of the Court was delivered by
             R. K. AGRAWAL, J 1. Leave granted.
 D           2. These appeals have been preferred against the impugned
       judgment and order dated 23.12.2014 passed by the High Court of Gujarat
       at Ahmedabad in Tax Appeal Nos. 6 and 14 of 2004 whereby the Division
       Bench of the High Court dismissed the appeals filed by the Revenue
       while upholding the decision of the Income Tax Appellant Tribunal (for
       brevity ‘the Tribunal’) dated 27.06.2003.
 E
             3. Brief facts:-
              (a) On 10.09.1998, the Respondent, who is the Chairman and
       Managing Director of Procter and Gamble (P&G), India, filed his income
       tax return for the Assessment Year 1998-99 and declaring the total income
 F     at Rs 40,13,820/-.
             (b) The Assessing Officer, vide order dated 12.02.2001, concluded
       the assessment proceeding under Section 143(3) of the Income Tax
       Act, 1961 (in short ‘the IT Act’) and determined the total income of the
       Respondent at Rs 7,23,11,013/- against the declared income.
 G           (c) Being aggrieved, the Respondent preferred an appeal before
       the Commissioner of Income Tax (Appeals) being No. CAB/I-643/2000-
       2001. After considering the case, learned CIT (Appeals), vide order
       dated 28.03.2002, dismissed the appeal of the Respondent after
       comprehensively discussing the taxability of the alleged amount and
       upholding the Assessment Order passed by the Assessing Officer.
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          ADDL. COMMISSIONER OF INCOME TAX v.                               1071
            BHARAT V. PATEL [R.K. AGRAWAL, J.]

       (d) Being dissatisfied, the Respondent carried the matter before     A
the Tribunal. The Tribunal, vide order dated 27.06.2003, in ITA No. 2241/
Ahd/2002 partly allowed the appeal filed by the Respondent.
      (e) At this juncture, the Respondent as well as the Revenue both
preferred cross appeals before the High Court of Gujarat at Ahmedabad.
       (f) At the same time, consequent to the decision of the Tribunal     B
dated 27.06.2003, the Assessing Officer started the proceeding side by
side to give effect to the order dated 27.06.2003. Vide order dated
15.09.2003, the Assessing Officer held that the difference being sum of
Rs 6,80,40,649/- paid to the Respondent by P&G, USA shall be treated
as capital gains on transfer/redemption of shares, and hence, the           C
Respondent is liable to pay tax on capital gains. Being aggrieved with
the order dated 15.09.2003, the Respondent filed an appeal before the
CIT (Appeals) being No. CAB/V-37/04-05 which was upheld by learned
CIT (Appeals) in favour of Assessing Officer while dismissing the appeal
of the Respondent.
                                                                            D
      (g) Being dissatisfied, the Respondent further preferred an appeal
before the Tribunal. The Tribunal, vide order dated 24.09.2010, dismissed
the appeal. The decision of the Tribunal dated 24.09.2010 was not
challenged further.
       (h) The Division Bench of the High Court, vide judgment and          E
order dated 23.12.2004, allowed the appeal filed by the Respondent while
dismissing the appeal of the Revenue.
      (i) Hence, the present appeals have been filed by the Revenue
before this Court.
       4. We have given our thoughtful consideration to the submissions     F
of leaned senior counsel for the parties and perused the factual matrix
of the case.
      Point(s) for consideration:-
       5. Whether in the present facts and circumstances of the case,
any interference by this Court is required with the impugned decision of    G
the High Court?
      Rival contentions:-
      6. At the outset, learned counsel for the Revenue contended that
the High Court erred in law while upholding that the amount received on     H
1072             SUPREME COURT REPORTS                           [2018] 7 S.C.R.


 A     redemption of Stock Appreciation Rights (SARs) is to be treated as
       capital gains and not perquisite under section 17(2)(iii) of the IT Act.
       However, the same is not taxable under the category of capital gains
       since no consideration had passed from the Respondent.
              7. In support of his argument, learned counsel placed reliance on
 B     Sumit Bhattacharya vs. ACIT Circle 16(1), Mumbai - [2008] 112
       ITD 1 (MUM.) (SB) and contended that the Respondent, having received
       an amount on redemption of Stock Appreciation Rights (SARs) as an
       employee of the company and there was an employer-employee
       relationship subsisting at the relevant point of time, therefore, the amount
       received on redemption of Share Appreciation Rights must be treated as
 C     taxable income under the head income from “Salaries”. Learned counsel
       finally contended that the impugned decision of the High Court deserves
       to be set aside.
              8. Per contra, learned senior counsel appearing for the Respondent
       submitted that the amount received by the Respondent from redemption
 D     of Stock Appreciation Rights (SARs) can be treated only as capital gains
       and cannot be treated as perquisite under Section 17(2) (iii) of the IT
       Act or under Section 28 (iv) of the IT Act. However, it was pointed out
       that the said capital gains cannot be said to arose to the Respondent
       since there was no consideration paid as the cost of acquisition by the
 E     Respondent. It was also submitted that such amount received on account
       of redemption of Stock Appreciation Rights could have been taxed if at
       all under the provisions of Clause (iiia) of Section 17(2) of the IT Act.
       Finally, it was also submitted that the question of law sought to be raised
       by the Revenue is no more res integra as settled by this Court in the
       case of Commissioner of Income Tax vs. Infosys Technologies Ltd.,
 F     [2008] 297 ITR 167 (SC). Hence, these appeals deserve to be dismissed
       at the threshold.
             Discussion:-
             9. Before examining the case at hand, it is pertinent to have an
 G     understanding of the words “Perquisite” and “Capital Gains”. The word
       “Perquisite” in common parlance may be defined as any perk or benefit
       attached to an employee or position besides salary or remuneration.
       Broadly speaking, these are usually non-cash benefits given by an
       employer to an employee in addition to entitled salary or remuneration.

 H
          ADDL. COMMISSIONER OF INCOME TAX v.                                  1073
            BHARAT V. PATEL [R.K. AGRAWAL, J.]

It may be said that these benefits are generally provided by the employers     A
in order to retain the talented employees in the organization. There are
various instances of perquisite such as concessional rent accommodation
provided by the employer, any sum paid by an employer in respect of an
obligation which was actually payable by the employee etc. Section 17(2)
of the IT Act was enacted by the legislature to give the broad view of
                                                                               B
term perquisite. On the other hand, the word ‘Capital Gains’ means a
profit from the sale of property or an investment. It may be short term or
long term depending upon the facts and circumstances of each case.
This gain or profit is charged to tax in the year in which transfer of the
capital assets takes place. In the instant case, the fundamental question
which arises for consideration before this Court is with regard to the         C
taxability of the amount received by the Respondent on redemption of
Stock Appreciation Rights (SARs.)
       10. It is a matter of record that the Respondent was employed as
the Chairman-cum-Managing Director of the (P&G) India Ltd. at the
relevant time and the said company is the subsidiary of (P&G) USA              D
through Richardson Vicks Inc. USA and that (P&G) USA owned
controlling equity. It is an undisputed fact that the Respondent was working
as a salaried employee. The (P&G) USA was the company who had
issued the Stock Appreciation Rights (SARs.) to the Respondent without
any consideration from 1991 to 1996. The said SARs were redeemed
on 15.10.1997 and in lieu of that the Respondent received an amount of         E
Rs 6,80,40,724/- from (P&G) USA. However, when the Respondent
filed his return, he claimed this amount as an exemption from the ambit
of Income Tax. The issue involved in this appeal is in respect of
Rs. 6,80,40,724/- made on account of amount received on redemption of
Stock Appreciation Rights.                                                     F
       11. The Tribunal was of the view that the stock options are capital
assets and such assets in the instant case acquired for consideration,
hence, gain arising therefrom is liable to capital gain tax. However, the
stand of the Revenue before the Tribunal was that the amount in question
is taxable as perquisite under Section 17(2)(iii) of the IT Act or in          G
alternatively under Section 28(iv) of the IT Act instead of capital gains.
The High Court also upheld the view of the Tribunal but the High Court
disagreed that such capital gains arose to the Respondent on redemption
of Stock Appreciation Rights since there was no cost of acquisition

                                                                               H
1074             SUPREME COURT REPORTS                           [2018] 7 S.C.R.


 A     involved from the side of the Respondent. The meaning of the word
       perquisite for the instant case is given under Section 17(2) of the IT Act.
       The Revenue alternatively contended that the case of the Respondent
       should come under the ambit of Section 28(iv) of the IT Act.
              12. It is apposite to note here that, particularly, in order to bring
 B     the perquisite transferred by the employer to the employees within the
       ambit of tax, legislature brought an amendment under Section 17 of the
       IT Act by inserting Clause (iiia) in Section 17(2) of the IT Act through
       the Finance Act, 1999 (27 of 1999) with effect from 01.04.2000, which
       was later on omitted by the Finance Act, 2000. The said Clause (iiia) as
       it was then is reproduced herein below:
 C
             “(iiia) the value of any specified security allotted or transferred,
             directly or indirectly, by any person free of cost or at concessional
             rate, to an individual who is or has been in employment of that
             person:
 D           Provided that in a case where allotment or transfer of specified
             securities is made in pursuance of an option exercised by an
             individual, the value of the specified securities shall be taxable in
             the previous year in which such option is exercised by such
             individual.

 E           Explanation- For the purposes of this clause,-
             (a) “cost’ means the amount actually paid for acquiring specified
             securities and where no money has been paid, the cost shall be
             taken as nil;
             (b) “specified securities” means the securities as defined in
 F           clause(h) of section 2 of the Securities Contracts (Regulation)
             Act, 1956 (42 of 1956) and includes employees’ stock option and
             sweet equity shares;
             (c) “sweat equity shares” means equity shares issued by a
             company to its employees or directors at a discount or for
 G           consideration other than cash for providing know-how or making
             available rights in the nature of intellectual property rights or value
             additions, by whatever name called; and
             (d) “value” means the difference between the fair market value
             and the cost for acquiring specified securities;”
 H
           ADDL. COMMISSIONER OF INCOME TAX v.                                     1075
             BHARAT V. PATEL [R.K. AGRAWAL, J.]

       13. The intention behind the said amendment brought by the                  A
legislature was to bring the benefits transferred by the employer to the
employees as in the instant case, within the ambit of the Income Tax
Act, 1961. It was the first time when the legislature specified the meaning
of the cost for acquiring specific securities. Only by this amendment,
legislature determined what would constitute the specific securities. By
                                                                                   B
this amendment, legislature clearly covered the direct or indirect transfer
of specified securities from the employer to the employees during or
after the employment. On a perusal of the said clause, it is evident that
the case of the Respondent falls under such clause. However, since the
transaction in the instant case pertains to prior to 01.04.2000, hence,
such transaction cannot be covered under the said clause in the absence            C
of an express provision of retrospective effect. We also do not find any
force in the argument of the Revenue that the case of the Respondent
would fall under the ambit of Section 17(2) (iii) of the IT Act instead of
Section 17(2) (iiia) of the IT Act. It is a fundamental principle of law that
a receipt under the IT Act must be made taxable before it can be treated
                                                                                   D
as income. Courts cannot construe the law in such a way that brings an
individual within the ambit of Income Tax Act to pay tax who otherwise
is not liable to pay. In the absence of any such specific provision, if an
individual is subjected to pay tax, it would amount to the violation of his
Constitutional Right.
        14. It is pertinent to note that on the point of applicability of clause   E
(iiia) of Section 17(2) of the IT Act, this Court settled the position in
Infosys Technologies Ltd (supra), and has held as under:-
       “17. Be that as it may, proceeding on the basis that there was
       “benefit” the question is whether every benefit received by the
       person is taxable as income? In our view, it is not so. Unless the          F
       benefit is made taxable, it cannot be regarded as income. During
       the relevant assessment years, there was no provision in law which
       made such benefit taxable as income. Further, as stated, the benefit
       was prospective. Unless a benefit is in the nature of income or
       specifically included by the legislature as part of income, the same        G
       is not taxable. In this case, the shares could not be obtained by the
       employees till the lock-in period was over. On facts, we hold that
       in the absence of legislative mandate a potential benefit could not
       be considered as “income” of the employee(s) chargeable under
       the head “salaries”…..”
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1076            SUPREME COURT REPORTS                            [2018] 7 S.C.R.


 A            15. The Revenue also contended before the High Court that the
       amendment brought in by Section 17(2) of the IT Act was clarificatory,
       hence, retrospective in nature. However, the High Court rejected the
       stand of the Revenue. The High Court, in its impugned judgment, on the
       point of the applicability of clause has held as under:-
 B           “15. In the case of Commissioner of Income-Tax, Bangalore vs
             B.C. Srinivasa Setty [(1981) 128 ITR 294 (SC)] this Court held
             that the charging section and computation provision under the 1961
             Act constituted an integrated code. The mechanism introduced
             for the first time under the Finance Act, 1999 by which cost was
             explained in the manner stated above was not there prior to
 C           1.4.2000. The new mechanism stood introduced w.e.f. 1.4.2000
             only. With the above definition of the word cost introduced vide
             clause (iiia), the value of option became ascertainable. There is
             nothing in the Memorandum to the Finance Act, 1999 to say that
             this new mechanism would operate retrospectively. Further, a
 D           mechanism which explains cost in the manner indicated above
             cannot be read retrospectively unless the Legislature expressly
             says so. It was not capable of being implemented retrospectively.
             Till 1.4.2000, in the absence of the definition of the word cost
             value of the option was not ascertainable. In our view, clause
             (iiia) is not clarificatory. Moreover, the meaning of the words
 E           specified securities in section (iiia) was defined or explained for
             the first time vide Finance Act , 1999 w.e.f. 1.4.2000.Morevover,
             the words allotted or transferred in clause (iiia) made things clear
             only after 1.4.2000. Lastly, it may be pointed out that even clause
             (iiia) has been subsequently deleted w.e.f. 1.4.2001. For the afore
 F           stated reasons, we are of the view the clause (iiia) cannot be read
             as retrospective.”
              16. Circular No. 710 dated 24.07.1995 which was issued by the
       CBDT deals with the taxability of shares issued at less than the market
       price. For ready reference, Circular No. 710 issued by the CBDT is
 G     reproduced hereinbelow:-
             “202. Taxability of the perequisite on shares issued to
             employees at less than market price:
             1. Chief Commissioners and corporate assessees have been
             seeking clarification regarding taxability of the perquisite on shares
 H           issued to the employees at less than market price.
          ADDL. COMMISSIONER OF INCOME TAX v.                                 1077
            BHARAT V. PATEL [R.K. AGRAWAL, J.]

      2. The matter has been considered by the Board. The benefit             A
      does amount to a perquisite within the meaning of clause (iii) of
      sub-section (2) of Section 17 of the Income-Tax Act, 1961. The
      various situations in this regard have to be dealt with as under:
           (i) where the shares held by the Government have been
           transferred to the employee, there will be no perquisite because   B
           the employer-employee relationship does not exist between
           Government and the employee (transferor and the transferee);
           (ii) where the company offers shares to the employees at the
           same price as have been offered to the other shareholders
           or the general public, there will be no perquisite;                C
           (iii) where the employer has offered the shares to its
           employees at a price lower than the one at which the shares
           have been offered to the other shareholders/public, the
           difference between the two prices will be taxed as perquisite;
           (iv) where the shares have been offered only to the                D
           employees, the value of perqusite will be the difference
           between the market price of the shares on the date of
           acceptance of the offer by the employee and the price at
           which the shares have been offered.”
      On a perusal of the above, prima facie, it appears that such            E
Circular dealt with the cases where the employer issued shares to the
employees at less than the market price. In the instant case, the
Respondent was allotted Stock Appreciation Rights (SARs.) by the
(P&G) USA which is different from the allotment of shares. Hence, in
our opinion such Circular has no applicability on the instant case.           F
Moreover, a Circular cannot be used to introduce a new tax provision in
a Statute which was otherwise absent.
       17. Alternatively, the Revenue also contended that the case of the
Respondent shall come within the ambit of the Section 28(iv) of the IT
Act. At this juncture, we deem it appropriate, for the sake of convenience,
                                                                              G
to refer Section 28(iv) of the IT Act which is reproduced herein below:-
      “28. Profits and gains of business or profession.-The
      following income shall be chargeable to income-tax under the head
      “Profits and gains of business or profession”-
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1078             SUPREME COURT REPORTS                              [2018] 7 S.C.R.


 A            (iv) the value of any benefit or perquisite, whether convertible
              into money or not, arising from business or the exercise of a
              profession.”
                On a first look of the said provision, it is apparent that such benefit
       or perquisite shall have arisen from the business activities or profession
 B     whereas in the instant case there is nothing as such. The applicability of
       Section 28(iv) is confined only to the case where there is any business
       or profession related transaction involved. Hence, the instant case cannot
       be covered under Section 28(iv) of the IT Act for the purpose of tax
       liability.
 C            18. To sum up, the Respondent got the Stock Appreciation Rights
       (SARs) and, eventually received an amount on account of its redemption
       prior to 01.04.2000 on which the amendment of Finance Act, 1999 (27
       of 1999) came into force. In the absence of any express statutory provision
       regarding the applicability of such amendment from retrospective effect,
       we do not find any force in the argument of the Revenue that such
 D     amendment came into force retrospectively. It is well established rule of
       interpretation that taxing provisions shall be construed strictly so that no
       person who is otherwise not liable to pay tax, be made liable to pay tax.
              19. In view of above discussion, we are of the considered view
       that these instant appeals are devoid of merits and deserve to be
 E     dismissed. Accordingly, these are hereby dismissed leaving parties to
       bear their own cost.


       Divya Pandey                                                   Appeals dismissed.

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