Mid Assignment
Mid Assignment
Mid Assignment
Presented to:
Prof. Arif Hussain Ejaz
Presented by:
M. Imran 10102
Attiq-ur-Rehman 10133
M. Rizwn 10149
M. Asif Tufail 10138
Farhan Siddiqui 10135
Abid Idrees 10111
To get the main purpose out of this website, it was very essential for us to understand the depth
of the ordinance as well as how to get the exemption from tax of how to get benefits after giving
TAX.
Introduction:-
The Central Board of Revenue (CBR) was created on April 01, 1924 through enactment of the
Central Board of Revenue Act, 1924. In 1944, a full-fledged Revenue Division was created
under the Ministry of Finance.
After independence, this arrangement continued up to 31st August 1960 when on the
recommendations of the Administrative Re-organization Committee, FBR was made an attached
department of the Ministry of Finance.
In 1974, further changes were made to streamline the organization and its functions.
Consequently, the post of Chairman FBR was created with the status of ex-officio Additional
Secretary and Secretary Finance was relieved of his duties as ex-officio Chairman of the FBR.
By the enactment of FBR ACT 2007 in July 2007 the Central Board of Revenue has now
become Federal Board of Revenue.
Collectors:
Custom House karachi
Lahore
Sambrial
Exports Karachi
Port Qasim
Custom House Quetta
Preventive
Hyderabad
Peshawar
Chapter1 Preliminary
Chapter2 Appointment of officers of customs and their powers
Chapter3 Declaration of ports, airports, land custom-station
Chapter4 Prohibition and restriction of importation and exportation
Chapter5 Levy of exemption form and prepayment of customs duties
Chapter6 Drawback
Chapter7 Arrival and departure of conveyance
Chapter8 General provisions affecting conveyances at custom station
Chapter9 Discharge of cargo and entry inward of goods
Chapter10 Clearance of goods for home consumption
Chapter11 Warehousing
Chapter12 Transshipment
Chapter13 Transit trade
Chapter14 Exportation or shipment and relending
Chapter15 Special provisions regarding baggage and goods imported or exported by post
Chapter16 Provisions related to costal goods and vessels
Chapter17 Offences and penalties
Chapter18 Prevention of smuggling-powers of search, seizure and arrest
Chapter19 Appeals and revisions
Chapter20 Miscellaneous
Definitions
Baggage
Import by privileged personnel
Prior release of consignment
Auction and auctioneers
Temporary importation of motor vehicles
Licensing
Valuation procedures
Maintenance of accounts
Recovery of arrears
Customs Notifications:
Notifications import
Parent Active SRO
Last
SRO# Issue Date Amended Title
Date
Notifications export
Customs Active/Operative Notifications/SROs Export
Parent Active SRO
Last Amended
SRO# Issue Date Title
Date
Levy of regulatory duty at the rate of fifteen percent ad
323 (I)/2010 May 13 2010 Jun 4 2010 valorem on export of all types of yarn for sixty days with
immediate effect
Imposing of regulatory duty at the rate of twenty-five per
cent (25%) ad valorem on export of waste and scrap of
----(I)/2010 Mar 13 2010
copper and aluminium and on bars, rods, ingots, slabs, and
billets
Federal Board of Revenue is pleased to make the following
888(I)/2009 Oct 15 2009 Oct 20 2009 further amendment in the Export Oriented Units and Small
& Medium Enterprises Rules, 2008
Federal Government is pleased to rescind its Notification
805(I)/2009 Sep 16 2009 Sep 19 2009 No. S.R.O.1185 (I)/2007, dated the 5th December, 2007
with immediate effect.
Regulatory duty at the rate of twenty-five per cent ad
594(I)/2009 Jun 25 2009 Apr 2 2010 valorem levied on Export of goods classifiable under the
H.S. codes in the table on the above mentioned SRO.
The Federal Government is pleased to direct that a
321(I)/2009 Apr 10 2009 Apr 10 2009 regulatory duty at the rate of fifteen per cent ad valorem
shall be levied on export of molasses with immediate effect.
This notification allows duty drawback rates on export of
209(I)/2009 Mar 5 2009 Mar 5 2009
textile and allied products
This notification allows duty drawback rates on export of
210(I)/2009 Mar 5 2009 Mar 5 2009
leather and allied products and sports goods
This notification allows duty drawback rates on export of
211(I)/2009 Mar 5 2009 Mar 5 2009
engineering/metal and allied products
This notification allows duty drawback rates on export of
212(I)/2009 Mar 5 2009 Mar 5 2009 miscellaneous products like packing metarials, edible
products, plastic products, etc.
Regulatory duty equivalent to the Price Differential Claims
(PDC), in Rupees per litre, of High Speed Diesel (HSD) and
946(I)/2008 Sep 4 2008 Oct 18 2008
Superior Kerosene Oil (SKO) as notified by the Ministry of
Petroleum & Natural Re
The Federal Government is pleased to exempt from the
whole of customs duties, sales tax and federal excise duty
326(I)/2008 Mar 29 2008 Mar 29 2008
leviable on all the goods imported into and exported from
an Export Oriented Unit subjec
327(I)/2008 Mar 29 2008 Mar 29 2008 The Federal Board of Revenue is pleased to make the rules.
Regulatory duty at the rate of thirty-five percent ad-
1185(I)/2007 Dec 5 2007 Dec 13 2008
valorem on export of wheat products
Rescind the notification No .S.R.O 474(I)/2006, dated the
1186(I)/2007 Dec 5 2007 Dec 5 2007
22nd May,2006
______(I)/200
Jul 28 2007 Jul 28 2007 ATA Carnet Rules
7
Regulatory duty on ferrous and non ferrous waste and
482(I)/2007 Jun 9 2007 Jun 13 2009
scrap.
492(I)/2006 May 26 2006 Jun 20 2006 35% Regulatory duty on export of Pulses
Amendment in SRO.450(I)/2001 dated 18.6.2001 Customs
1211(I)/2005 Dec 9 2005 Dec 9 2005
Rules,2001
CBR is pleased to direct that blankets, tens and tarpaulins
shall be deemed to have been exported if supplied for the
1080(I)/2005 Oct 22 2005 Mar 28 2009
earthquake victims subject to the following conditions,
namely:
1065(I)/2005 Oct 20 2005 Aug 11 2007 This Notification issued in suppersesion of SRO 410/2001
dated 18th June [Link] to the new Notification,
the facility of temporary importation is available to
exporters also registered as manu
1011(I)/2005 Sep 27 2005 Sep 27 2005 20% Regulatory duty on export of raw & wet blue hides.
782(I)/2005 Aug 6 2005 Aug 6 2005 This notification rescinded 96 individual DDB notifications
783(I)/2005 Aug 6 2005 Aug 6 2005 This notification rescinded 7 standard DDB notifications
315(I)/2004 May 21 2004 Jan 1 2005 Duty Draw Back - Artificial leather (PVC binding material)
259(I)/2004 May 7 2004 Jan 1 2005 Duty Draw Back - Fiber Cement Pipes
Duty Draw Back - Central Excise on export of Lubricating
1028(I)/2003 Nov 6 2003 Jan 1 2005
Oil
416(I)/2002 Jun 26 2002 Dec 15 2004 Reward Rules (Customs)
Sales tax:-
Sales Tax was a provincial subject at the time of partition. It was being administered in the
provinces of Punjab & Sindh as provincial levy. Sales tax was declared a federal subject in 1948
through the enactment of General Sales Tax Act, 1948 and in 1952; this levy was transferred
permanently to the Central Government. Sales tax was levied at the standard rate of 6 pies per
rupee at every stage whenever a sale was affected. The trading community protested against this
system, and this resulted in the enactment of Sales Tax Act 1951.
A system of licensed manufacturers & wholesalers was instituted whereby they were allowed to
purchase goods free of sales tax from each other and pay tax on sales to unlicensed traders.
Imports were chargeable to Sales Tax but the licensed manufacturers & wholesalers were
allowed to import goods without the payment of Sales Tax. Later on Sales Tax became
chargeable on locally produced & imported goods at the time of their sales & import,
respectively. The sales tax was collected under the Finance Ordinance, 1956, on goods which
were chargeable to Central Excise Duty, as if it were a duty of Central Excise. In April 1981, by
virtue of an amendment in the Sales Tax act, 1951, the collection of Sales Tax on non-excisable
goods was also entrusted to the Central Excise Department.
In the late eighties the government decided to replace Sales Tax with the Value Added Tax in the
country as a part of its structural adjustment program which was undertaken to correct anomalies
& distortions both in our tax & non-tax regimes. Accordingly new enactment titled Sales Tax
Act 1990 replaced Sales Tax Act 1951 with effect from 1-11-1990.
Liability to Sales Tax:-
Following sectors are required to get registration for sales tax and charge sales tax on their
supplies/ services:
Manufacturing
Import
Services
Distribution and Wholesale
Previously it was being charged at the manufacturing & import stage, and its scope has been
extended now to remaining sectors. Sales Tax is chargeable on all locally produced and imported
goods except computer software, poultry feeds, medicines and unprocessed agricultural produce
of Pakistan and other goods specified in Sixth Schedule to The Sales Tax Act, 1990.
|MS Word version
S.R.O 11/15/201
Amendment in Sales Tax Rules 2006 (Refund)
1042(I)/2010 0
S.R.O 11/12/201
Authorization officers of D.G, [Link] (Inland Revenue)ST&FE
1038(I)/2010 0
S.R.O 11/12/201
Amendment in Sales Tax S.R.O 282(i)/2010 Internal Audit (Customs)
1040(I)/2010 0
S.R.O 810
8/19/2010 File Refund Claim Through FBR Web Portal
(1)/2010
S.R.O.
6/5/2010 Amendment in S.R.O 69(I)/2006, Dated 28/1/2006
397(I)/2010
Short history:-
Withholding is an act of deduction or collection of tax at source, which has generally been in the
nature of an advance tax payment. It is an effective mechanism and important/timely source of
revenue. Their contribution is about 41 percent of total direct tax revenues. Increase from Rs.5
(b) in 1991 to above Rs 169(b) in 2007 speaks of exponential growth and consequential heavy
reliance on withholding taxes in Pakistan.
Under the repealed Income Tax Act, 1922, tax was deducted from two main sources of income;
namely, salaries and interest on securities. Over the period of time, Withholding Tax net was
extended, by steadily introducing different Provisions in the Tax Laws. The repealed Income Tax
Ordinance, 1979, brought in all the provisions of the Income Tax Act, 1922. However, in the
1990s, withholding tax net was expanded extensively by providing for withholding tax on a
wider variety of transactions and making most of them presumptive. Provisions of the Income
Tax Ordinance, 2001, are more or less the same, except for a few changes and additions.
Important withholding provisions relate to salary, imports, exports, commission and brokerage,
dividend, contracts, profit on debt, utilities, vehicles tax, stock exchange-related provisions and
non-residents, etc., with varying rates.
Changes in withholding tax:
Government of Pakistan
Revenue Division
Federal Board of Revenue
Withholding agents:-
Major Withholding Tax Agent
Prescribed Persons / Withholding
Relevant Sections
Agent
Collector of Customs 148
Authorized dealer in foreign exchange 149, 154(1), 154(2)
Authorized dealer (motor cars) 231B
Association of persons 149, 152(1), 152(2), 156, 233
Association of persons constituted by, or 149, 152(1), 152(2), 153(1), 153(3), 156, 233
under, law
Banking Company 149, 151(1)(a), 151(1)(b), 151(1)(d), 152(1),
152(2), 153(1), 153(3), 154(1), 154(2), 154(3),
155, 156, 231A, 233
Body Corporate formed by or under law 149, 151(1)(d), 152(1), 152(2), 153(1), 153(3),
in force in Pakistan 155, 156, 233
Body incorporated by or under the law of 149, 152(1), 152(2), 153(1), 153(3), 155, 156,
a country outside Pakistan relating to 233
incorporation of companies
CNG Stations (Gas consumption bill 234A
preparer)
Company as defined under the 149, 151(1)(d), 152(1), 152(2), 153(1), 153(3),
Companies Ordinance, 1984 except a 155, 156, 233
Small Company
Consortium 149, 152(1), 152(2), 153(1), 153(3), 156
Co-operative Society 149, 152(1), 152(2), 153(1), 153(3), 155, 156,
233
Diplomatic Mission of a foreign state 155
Direct Exporter 154(3B)
Electricity Consumption Bill Preparing 235
Authority
Export House registered under DTRE 154(3B)
Rule, 2001
Export Processing Zone Authority 154(3A)
Federal Government 149, 151(1)(a), 151(1)(c), 152(1), 152(2),
153(1), 153(3), 155, 156, 233A
Finance Society 149, 151(1)(D), 152(1), 152(2), 153(1), 153(3),
155, 156, 233
Foreign association, whether 149, 152(1), 152(2), 153(1), 153(3), 155, 156,
incorporated or not, declared to be a 233
company by the Federal Board of
Revenue
Foreign consultant 149, 152(1), 152(2), 153(1), 153(3), 156, 233
Foreign contractor 149, 152(1), 152(2), 153(1), 153(3), 156, 233
Individual 149, 152(1), 152(2), 153(1), 153(3), 156
Local Authority 149, 151(1)©, 152(1), 152(2), 153(1), 153(3),
155, 156, 233
Manufacturer of motor cars 231B
Modaraba 149, 152(1), 152(2), 153(1), 153(3), 155, 156,
233
Motor Vehicle Tax Collection Authority 234
Non-profit organizations 149, 152(1), 152(2), 153(1), 153(3), 155, 156,
233
Persons selling petroleum products to 156A
petrol pump operators
Company 149, 152(1), 152(2), 155, 156, 233
Trusts/Non-profit Sector 149, 152(1), 152(2), 153(1), 153(3), 155, 156,
233
Telephone (bill preparer) & Cards (issuer 236
& Seller)
Provincial Government 149, 151(1)(c ), 152(1), 152(2), 153(1), 153(3),
155, 156, 233
Resident Company 150
Society established or constituted by or 149, 152(1), 152(2), 153(1), 153(3), 155, 156,
under any law for the time being in force 233
Stock Exchange Registered in Pakistan 233A
Manufacturer of motor cars 231B
Modaraba 149, 152(1), 152(2), 153(1), 153(3), 155, 156,
233
Motor Vehicle Tax Collection Authority 234
Non-profit organizations 149, 152(1), 152(2), 153(1), 153(3), 155, 156,
233
Persons selling petroleum products to 156A
petrol pump operators
Company 149, 152(1), 152(2), 155, 156, 233
Trusts/Non-profit Sector 149, 152(1), 152(2), 153(1), 153(3), 155, 156,
233
Telephone (bill preparer) & Cards (issuer 236
& Seller)
Provincial Government 149, 151(1)(c ), 152(1), 152(2), 153(1), 153(3),
155, 156, 233
Resident Company 150
Society established or constituted by or 149, 152(1), 152(2), 153(1), 153(3), 155, 156,
under any law for the time being in force 233
Stock Exchange Registered in Pakistan 233A
Wealth Statement
For Company
For Individual/AOP
Procedure:-
The applicant may seek advance ruling by making an application to the Central Board of
Revenue in the prescribed form and manner.
The application for advance ruling should be presented in the form prescribed for the
purpose by the applicant in person or by an authorized representative to the Secretary,
International Taxes Operations, Room No. 424, 5th Floor, FBR House, Constitution
Avenue, Islamabad.
The application and the accompanying annexures may be neatly typed on one side of
plain paper of A-4 size leaving a minimum margin of 30mm on all the four sides and may
be duly indexed. Legible photocopies of the relevant documents may be attached.
No information as required in the prescribed application form may be withheld.
Provision of complete and correct information would help the applicant in getting an
early decision.
The question(s) of law or fact on which advance ruling is sought may be stated clearly in
the application using a text box.
Signing of Application:-
The application, its verification and the annexures, statements and documents accompanying it,
are required to be signed by a person competent to do so. Where a person signing the application
and other documents claims to have been duly authorized to do so, the application must be
accompanied by a power of attorney authorizing him to sign.
Authorized Representative:-
The applicant is entitled to present his case before the Advance Ruling Committee either
personally or through an authorized representative. If the applicant desires to be represented by
an authorized representative, a duly authenticated document authorizing him to appear for the
applicant should be enclosed.
Payment of Fee:-
There is no fee for seeking an advance ruling from the Central Board of Revenue.
Withdrawal of application:-
The applicant may withdraw his application at any time before the ruling is issued.
Gives clarity to the local partners of non-residents vis-à-vis their liabilities under the tax
laws.
Presently, only a non-resident person as defined in the Income Tax Ordinance, 2001, can seek
advance ruling.
Who is a non-resident person?
Under the existing scheme of tax laws, the taxable entities are broadly divided into three
groups i.e. Individual, Association of Persons, and Company.
These taxable entities are divided into two categories depending upon their residential
status. These categories are :-
Resident, and
Non-Resident
An individual is a resident individual if he is present in Pakistan for a period of, or
periods amounting in aggregate to, 182 days or more during the tax year. A company is
a resident company for a tax year if it is incorporated or formed by or under any law in
force in Pakistan; or the control and management of the affairs of the company is situated
wholly in Pakistan at any time during the year. An association of persons is a resident
association of persons for a tax year if the control and management of the affairs of the
association is situated wholly or partly in Pakistan at any time during the year.
The advance ruling is required to be issued by the Central Board of Revenue within 3 months of
the receipt of a valid application.
1 Austria 2 Azerbaijan
3 Bahrain
4 Bangladesh 5 Belgium
8 Canada 9 China
10 Denmark 11 Egypt
12 Finland 13 France
14 Germany 15 Hungary
16 Indonesia 17 Iran
18 Ireland 19 Italy
20 Japan 21 Jordan
22 Kazakhstan 23 Korea
24 Kuwait 25 Libya
26 Lebanon 27 Malaysia
28 Malta 29 Mauritius
30 Moroco 31 Netherlands
32 Nigeria 33 Norway
34 Oman 35 Philippines
36 Poland 37 Portugal
38 Qatar 39 Romania
48 Tajikistan 49 Turkey
50 Tunisia 51 Turkmenistan
56 Vietnam 57 Yeman
The new income tax law will bring a complete change in the philosophy of income tax
proceedings and it will make life easier. The salient features are:
No assessing officer will determine your income and compute your tax liability. Now you
will yourself declare your income and determine your tax liability.
Your income tax return shall be accepted without any conditions. There will be no
compulsory enhancement of tax liability over previous year to qualify for acceptance.
Even your loss return shall also qualify for acceptance.
Filing of your income tax return itself will be an assessment order and your eligibility for
refund will flow from your tax return.
A certain percentage of returns filed shall be selected for tax audit on the basis of risk
assessment to verify the accuracy and correctness of your income tax return.
Tax audit will not necessarily mean an amendment of the assessment originally made
based by you in your return of income.
Your original assessment can only be amended on the basis of information acquired
during tax audit or any other source.
If selected for audit, there will be no pre-designated auditors to carry out audit. The
officials making selection for audit will be different from those who do actual audit. In
other words you have no designated Income Tax Officer holding jurisdiction on you.
Thus universal self-assessment in its true sense will be available to all taxpayers
irrespective of quantum, status, location or size. This is the first such experience in this
part of the world. The new law and the universal self-assessment system will take away
the discretionary powers of the tax collectors and place great responsibility and obligation
on you as a taxpayer and an honorable citizen. The new Income Tax Ordinance, 2001 and
its salient features, briefly explained above, are not workable without adequate records to
support the items reported by you on the income tax return and allied statements.
The Central Board of Revenue is fully aware of your (small taxpayers) problems and
difficulties in maintaining adequate records. Therefore only bare minimum books of
account; documents and records (that you generally maintain to run your business) have
been prescribed.
INDIVIDUAL, AOP
A is the tax assessed to the taxpayer for the latest tax year or latest assessment year under the
repealed Ordinance; andB is the tax paid in the quarter for which a tax credit is allowed under
section 168, other than tax deducted under section 149 or 155.
In the case of a company, the amount of advance tax due for a quarter shall be computed
according to the following formula, namely:-
(A/4) - B
Where –
A. is the tax assessed to the taxpayer for the latest tax year or latest assessment year under the
repealed Ordinance; and
B. is the tax paid in the quarter for which a tax credit is allowed under section 168, other than tax
Federal excise:-
The Federal Excise Act, 2005, was promulgated with effect from 1st July, 2005, repealing the
Central Excises Act, 1944. Following are some of the significant changes brought about by the
new Act:
The word “Federal” was used in place of “Central”. Therefore, now the term “Federal
Excise Duty” is more appropriate as compared to old “Central Excise Duty” for the duties
of excise levied under the 2005 Act.
The system of physical supervision has been entirely done away with and now all
clearances will be self-assessed and no prior permission for clearance will be required.
The payment of duty will be on monthly basis and the duty on all clearances during the
month will be payable by the 15th of next month. This is in contrast to previous
requirement of payment of duty prior to clearance.
No gate passes are required for clearances as in the old system.
Double taxation has been eliminated by allowing adjustment of the excise duty paid on
the input goods used directly in the manufacture of excisable goods.
On some services and goods FED is payable in VAT more i.e. in the same manner as
provided in the Sales Tax Act, 1990. For details see the link ‘Goods/Services Liable to
Excise Duty’ on this page.
Notifications:-
11/27/201
1084(I)/2010 Ammendment in SRO 57(I)/2010 Dated, 2/2/2010
0
S.R.O
6/5/2010 Resciding in S.R.O 650(I)/2005, dated 01/07/2005
399(I)/2010
No. 01/2010 2nd June, 2010 SANCTION OF REFUND CLAIMS OF IMPORT-RELATED FEDEAL EXCISE DUTY BY
THE COLLECTORATES OF CUSTOMS
No. 02/2008 6th October, 2008 FEDERAL EXCISE DUTY ON GOODS PRODUCED BY VENDORS (TOLL
MANUFACTURERS) FROM THE RAW MATERIALS SUPPLIED BY THE
PRINCIPALS.
No.01/2007 10th January, 2007 MITIGATING THE HARDSHIP OF ISLAMABAD BASED TAXPAYERS.
No. 08/2006 27th December, 2006 PROCEDURE REGARDING EXEMPT SUPPLY OF SOLVENT OIL TO
MANUFACTURERS OF SHOE ADHESIVES
No. 07/2006 10th October, 2006 BANKS FALLING IN THE JURISDICTION OF LARGE TAXPAYERS UNIT,
LAHORE.
No. 06/2006 10th October, 2006 BANKS FALLING IN THE JURISDICTION OF LARGE TAXPAYERS UNIT,
KARACHI
No. 05/2006 5th August, 2006 LEVY AND COLLECTION OF EXCISE DUTY ON FRANCHISE FEE/ TECHNICAL
FEE/ROYALTY AND PAYMENT THEREOF.
NO.01/2006 19th January, 2006 LEVY OF FEDERAL EXCISE DUTY AT IMPORT STAGE ON EDIBLE OIL AND
VEGETABLE GHEE INCLUDING COOKING OIL VIDE SRO. 24(I)/2006 Dated
07.01.2006 - CLARIFICATIONS REGARDING
Profile Member’s:-
[Link]
a. Overall increase in the revenue collection and contribute to the achievement of fiscal
targets;
Component of Reforms
Management and Institutional Development
Organizational Design
Human Resource Management
Training
Improving Professional Ethics
Internal Audit Function
Internal Affairs and Vigilance Function
Managing Organizational Change
Direct Taxes
Sales Tax
Customs
HQ Information Systems
Direct Tax Information System
Sales Tax Information System
Customs Information system
Outcomes of Reforms:-
a. Gaining Stakeholders' Respect
b. Substantial reduction of corruption - Transparency International Report
c. On Tax Facilitation 's Ranking improved to 32 in 133 countries (recent report)
d. Improved performance - Revenue targets not only achieved but surpassed
e. Increase in Tax to GDP ration by 0.3 % each year from 2004-05 as against agreed KPI's of 0.2 %
f. Creating business friendly environment
g. Introducing professionalism, integrity, teamwork, courtesy, responsiveness, transparency and
fairness
h. Facilitating and providing service to the taxpayers
i. Reducing the cost of doing business
j. Adversarial relations turned to mutual trust and confidence.
RTO Peshawar
RTO Rawalpindi
RTO Islamabad
RTO Gujranwala
RTO Sialkot
RTO Lahore
RTO Faisalabad
RTO Multan
RTO Sukkur
RTO Hyderabad
RTO Karachi
RTO Quetta
PTFC Wahga
Mansehra (N.W.F.P)
Kohat (N.W.F.P)
Mardan (N.W.F.P)
Nowsherah (N.W.F.P)
Sanghar (Sindh)
Sahiwal (Punjab)
Jehlum (Punjab)
Thatta (Sindh)
Baddin (Sindh)
Shikarpur (Sindh)
Larkana (Sindh)
Dadu (Sindh)
Nawab Shah(Sindh)
Article on reforms:-
[Link]
[Link]