Goods and Services Tax

Stock markets bounce back amid volatility, Sensex closes higher 410 pts
GST
Dated:- 3-9-2025
PTI
Mumbai, Sep 3 (PTI) Benchmark equity indices Sensex and Nifty closed higher in a volatile session on Wednesday, driven by a rally in metal stocks and optimism related to the GST Council meeting.
After oscillating between highs and lows, the 30-share BSE Sensex jumped 409.83 points or 0.51 per cent to settle at 80,567.71. During the day, the benchmark hit a high of 80,671.28 and a low of 80,004.60, gyrating 666.68 points.
The 50-share NSE Nifty climbed 135.45 points or 0.55 per cent to 24,715.05.
The GST Council is meeting in New Delhi for two days to discuss the proposed pruning of tax rates to 5 per cent and 18 per cent.
Among S

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GST Council meet on rate reform begins; TDP supports, opposition bloc seeks revenue protection
GST
Dated:- 3-9-2025
PTI
New Delhi, Sep 3 (PTI) The 56th meeting of the GST Council, chaired by Finance Minister Nirmala Sitharaman and comprising state ministers, on Wednesday started deliberations on 'next-gen GST' reforms, which will lower tax rates on items of mass consumption, remove duty inversion in sectors, like textiles, and ease compliance burden for MSMEs.
The Council, over the next two days, will discuss reducing the number of slabs in GST to just two 5 per cent and 18 per cent and removing the 12 per cent and 28 per cent slabs. Also, a special 40 per cent tax has been proposed on a select few items, including tobacco a

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proposals.
“As an alliance partner, we are supporting the Centre's proposal of GST rate rationalisation. It is in favour of the common man,” Keshav told reporters before the Council meeting. Andhra Pradesh's Telugu Desam Party (TDP) is an ally of the BJP-led NDA government at the Centre.
Prime Minister Narendra Modi, in his Independence Day speech on August 15, unveiled the plan for GST reforms. Shortly thereafter, the central government shared a blueprint of the planned reform with a Group of Ministers (GoM) from different states for initial vetting.
As many as eight sectors textiles, fertiliser, renewable energy, automotive, handicrafts, agriculture, health and insurance will benefit the most from the rate overhaul, as per the Cen

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it is the responsibility of the Centre to compensate states for revenue loss,” Kishore told reporters here after the meeting of the opposition bloc.
Under the present GST structure, the 18 per cent slab accounts for a lion's share or 65 per cent in GST collection. The 5 per cent slab contributes 7 per cent to the total GST kitty.
The top tax bracket of 28 per cent on luxury and sin goods contributes 11 per cent of the revenue, while the 12 per cent slab accounts for just 5 per cent of the revenue.
The Centre's GST reform proposal put forth before the Council rests on three pillars structural reforms, rate rationalisation and ease of living.
The structural reforms would ensure stability and predictability by providing “long-term cl

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Opposition-ruled states meet ahead of GST Council, seek compensation to nod reform agenda
GST
Dated:- 3-9-2025
PTI
New Delhi, Sep 3 (PTI) Finance ministers of opposition-ruled states on Wednesday met ahead of the crucial GST Council meeting, and decided to seek compensation for revenue loss incurred by all states following the implementation of GST rate rejig.
Eight opposition-ruled states Himachal Pradesh, Jharkhand, Karnataka, Kerala, Punjab, Tamil Nadu, Telangana and West Bengal had met last week to decide on how their revenues could be protected once the 12 and 28 per cent slabs are removed.
Jharkhand Finance Minister Radha Krishna Kishore said his state will suffer a Rs 2,000 crore revenue loss if the Centre's GST refo

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and comprising ministers from all states, will, over the next two days, discuss the Centre's 'next-gen' GST reform proposal of having just two tax rates of 5 and 18 per cent by moving products from the current 12 and 28 per cent slab to lower rates.
A special 40 per cent rate has been proposed to be levied on a select few items. A 4-tier GST structure of 5, 12, 18 and 28 per cent was implemented from July 1, 2017, when the Centre and states agreed to subsume most of their taxes, like excise duty and VAT, into one uniform tax.
A compensation cess in the range of 1 to 290 per cent is levied on luxury and demerit goods to create a revenue pool for compensating states for the loss of revenue occurring from the exercise. The compensation me

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a compensation cess, may see differential rates, with entry-level cars being charged 18 per cent rate, while SUVs and luxury ones being put in the special 40 per cent rate.
The special 40 per cent rate will also be for other demerit goods like tobacco, pan masala and cigarettes. There could also be an additional tax on top of this rate for this category.
Opposition states, like West Bengal, have demanded that any levy on top of the 40 per cent rate should exclusively be for sharing with states to make up for their revenue losses.
The compensation cess mechanism was initially put in place for a 5-year period till June 30, 2022, to make up for the revenue loss suffered by states on account of GST implementation.
The levy of compensati

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Stock markets decline in early trade amid weak global trends, relentless foreign fund outflows
GST
Dated:- 3-9-2025
PTI
Mumbai, Sep 3 (PTI) Benchmark equity indices Sensex and Nifty declined in early trade on Wednesday, tracking weak global market trends and relentless foreign fund outflows.
Caution also prevailed in the equity market ahead of the GST Council meeting beginning Wednesday.
The 30-share BSE Sensex declined 153.28 points to 80,004.60 in early trade. The 50-share NSE Nifty dipped 46.4 points to 24,533.20.
From the Sensex firms, Infosys, Bajaj Finance, Hindustan Unilever, Bharti Airtel, ICICI Bank and Trent were among the laggards.
However, Tata Steel, Bharat Electronics, Eternal, ITC and Mahindra & Mahindra w

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Orders under section 73 GST set aside for natural justice breach; matter remitted for fresh consideration
Case-Laws
GST
The HC allowed the petition and set aside the impugned orders issued under section 73 of the GST Act and the consequential equal-amount penalty, holding that the adjudicating and appellate authorities violated principles of natural justice by failing to consider the petitioner's evidentiary materials and submissions. The court found the record demonstrated outward supplies supported by tax invoices, e-way bills and bank statements and that tax had been discharged, whereas the authorities proceeded on the premise of alleged inward supplies from a non-existent firm without verifying the petitioner's documentation. In consequence, the HC quashed the orders and remitted the matter for fresh consideration in accordance with law and natural justice.
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Issuing show cause notice and determination against a deceased person is impermissible; Section 93 permits action against legal representative
Case-Laws
GST
The HC held that issuance of a show cause notice and consequential determination in the name of a deceased person is impermissible under the statutory scheme; Section 93 addresses liability of a legal representative but does not authorize determination against a deceased individual. Consequently, the impugned SCN and resultant determination issued to the deceased are quashed as unsustainable for want of notice to the legal representative. The petition is allowed; the matter is remitted to the revenue authority to initiate proceedings, if any, by issuing a fresh show cause notice and affording opportunity to the legal representative before making any determination or ordering recovery.
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Petition dismissed; GST registration cancellation and Section 122 show-cause notice sustained, petitioner must pursue statutory appellate remedies
Case-Laws
GST
The HC dismissed the petition challenging cancellation of the petitioner's GST registration. The court found no documentary evidence rebutting the competent authority's findings and noted the petitioner failed to disclose any challenge or appeal against the Proper Officer's cancellation order. Consequently, the cancellation stands and a show-cause notice issued under Section 122 of the CGST Act, 2017 for recovery of GST and penalty remains effective. The HC relied on the Apex Court principle that writ jurisdiction under Article 226 is inappropriate to supplant statutory remedies in assessment matters and that the petitioner should be relegated to available appellate remedies. Petition dismissed.
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Writ allowed; GST registration cancellation set aside after defective show-cause notice fixed hearing before expiry of reply period
Case-Laws
GST
The HC allowed the writ petition and set aside the impugned cancellation of the petitioner's GST registration. The court found the show-cause notice dated 12.03.2024 legally defective because it afforded a 30-day reply period but fixed an earlier personal hearing within that period, rendering the notice bad in law; the petitioner offered no explanation for non-submission of a written response. Consequently, the HC quashed the 12.03.2024 notice and the consequential order dated 02.05.2024, but expressly left open the respondent's liberty to issue a fresh valid show-cause notice and proceed in accordance with law.
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SJM urges Sitharaman to keep GST under 5 pc for plastic waste, beedi industries
GST
Dated:- 2-9-2025
PTI
New Delhi, Sep 2 (PTI) The Swadeshi Jagran Manch (SJM) requested the Centre on Tuesday to keep the GST on plastic waste and beedi production under the 5-per cent slab.
In a letter to Finance Minister Nirmala Sitharaman ahead of a meeting of the GST Council, the SJM, an affiliate of the Rashtriya Swayamsevak Sangh (RSS), said reducing the current rate of 18-per cent Goods and Services Tax (GST) on plastic waste and 28 per cent on beedi production will help protect and promote employment in the two sectors with better welfare of the workers.
A reduction in the GST rates in the two sectors will also help achieve the objective

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d “greater hardships” to the workers in the unregistered beedi production units as they are deprived of many social security or welfare benefits provided by both the Centre and states, he said.
“We humbly request you to keep beedis under the 5-per cent category to provide relief to this cottage industry which provides employment to a large number of beedi rollers, Tendu leave collectors and labourers engaged in distribution and retail,” Mahajan said.
In the past, a very small amount of central excise duty was levied on beedis by the Centre, he said, adding that even the sales tax was not levied by many states, keeping the interests of beedi workers in mind.
Seeking a reduction in the GST rates on plastic waste, Mahajan said the current 1

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CM Majhi hails launch of IndiaÂ’s first semiconductor chip, compliments OdishaÂ’s PMEC, NIT Rourkela
GST
Dated:- 2-9-2025
PTI
Bhubaneswar, Sep 2 (PTI) Odisha Chief Minister Mohan Charan Majhi on Tuesday hailed the launch of IndiaÂ’s first indigenous semiconductor chip at the SEMICON India 2025 Conclave in New Delhi, congratulating OdishaÂ’s Parala Maharaja Engineering College (PMEC), Berhampur, for developing the high-performance multiplier IC, a key component.
Majhi, who attended the conclave inaugurated by Prime Minister Narendra Modi, described the launch as a “historic milestone” in IndiaÂ’s journey towards technological leadership.
“I had the privilege of joining #SEMICONIndia2025, a landmark platform that brought together glo

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f the High Performance Multiplier IC – C2S0061 by PMEC Berhampur, along with the VG Amplifier and Sensor Circuit – C2S0018 and the Present Encryption Core – C2S0017 by NIT Rourkela, as part of IndiaÂ’s first Made in India chip initiative, is a matter of immense pride for Odisha.” He added that “these remarkable achievements showcase the talent and innovation nurtured within our state and highlight OdishaÂ’s growing role in IndiaÂ’s semiconductor journey. I warmly congratulate everyone associated with these historic milestones, which represent significant steps towards technological leadership and reflect the unwavering commitment of our institutions to research, innovation, and self-reliance”.
At the conclave, Majhi inaugurated the Odisha Pa

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GST Council meets Wednesday; tax cuts on daily use items in offing
GST
Dated:- 2-9-2025
PTI
New Delhi, Sep 2 (PTI) The Centre is likely to push for a 5 per cent tax on EVs when its ambitious overhaul of the Goods and Services Tax (GST) to lower tax rates on daily use items ranging from butter to electronics is considered by the all powerful GST Council in a two-day meeting starting Wednesday.
The Council, chaired by Union Finance Minister Nirmala Sitharaman and comprising ministers from all states, will discuss the Centre's 'next-gen' GST reform proposal of having just two tax rates of 5 and 18 per cent by moving products from the current 12 and 28 per cent slab to lower rates. A special 40 per cent rate has been proposed to b

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ad in his Independence Day speech on August 15 unveiled the plan for GST reforms. Shortly thereafter the central government shared a blue print of the planned reform with a Group of Ministers (GoM) from different states for initial vetting.
The GoM has consented to Centre's proposal of doing away with the 12 and 28 per cent slabs, and reducing tax rates to benefit common man. Its recommendations are to be considered by the Council on September 3 and 4.
While broadly agreeing with the slab changes, the GoM has favoured charging electric vehicles priced up to Rs 40 lakh with an 18 per cent GST, sources aware of the matter said. The Centre, however, is keen to push EV adoption and favours a 5 per cent rate and the same stance will be pushe

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per cent rate, while SUVs and luxury ones being put in the special 40 per cent rate.
The special 40 per cent rate will also be for other demerit goods like tobacco, pan masala and cigarretes. There could also be an additional tax on top of this rate for this category.
Opposition states, like West Bengal, have demanded that any levy on top of the 40 per cent rate should exclusively be for sharing with states to make up for their revenue losses.
Eight opposition-ruled states Himachal Pradesh, Jharkhand, Karnataka, Kerala, Punjab, Tamil Nadu, Telangana and West Bengal — have also demanded that all states be compensated for the revenue loss they incur post the implementation of the GST rejig.
These states have argued that rejig in rat

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Stock markets end lower amid profit-taking in banking, auto shares ahead of GST Council meeting
GST
Dated:- 2-9-2025
PTI
Mumbai, Sep 2 (PTI) Benchmark indices Sensex and Nifty reversed early gains to close lower on Tuesday dragged by last-hour profit-taking in banking and auto shares amid caution ahead of the GST Council meeting.
The 30-share BSE Sensex declined 206.61 points or 0.26 per cent to settle at 80,157.88. The barometer opened higher and traded with gains till late afternoon session. However, profit-taking at the fag-end dragged the index down by 752.64 points from the day's high of 80,761.14.
The 50-share NSE Nifty dipped 45.45 points or 0.18 per cent to 24,579.60. During the day, it hit a high of 24,756.10 and a

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CVC flags 23 cases of 'non-compliance' of its advice in corruption cases by govt departments
GST
Dated:- 2-9-2025
PTI
New Delhi, Sep 2 (PTI) The Central Vigilance Commission (CVC) has flagged 23 cases of “non-compliance” by government departments where its advice was substantially diluted in corruption cases, according to its latest annual report.
Of these cases, the highest, five, were by the Ministry of Railways and two each by National Highway Authority of India (NHAI), Mahanadi Coalfields Limited (MCL), and Energy Efficiency Service Limited (EESL), it said.
One case each was by Deendayal Port Authority (DPA), Bharat Sanchar Nigam Limited (BSNL), Airport Authority of India (AAI), IDBI Bank Ltd, and Indian Overseas Bank, a

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ilance matters.
The advice is tendered by the commission based on a reasoned appreciation of all facts, documents and records relating to a particular case, which are brought to its notice by the organisation concerned, the report said.
“Acceptance of the Commission's reasoned advice in an overwhelming majority of cases by the disciplinary authorities is an indication of the objectivity and fairness of the Commission's advice,” it said.
However, in some cases of officers covered under the commission's jurisdiction, either the prescribed consultation mechanism with the commission was not adhered to, or the authorities concerned did not accept the commission's advice, the report said.
Further, there have been instances where the advic

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attendant.
“However, the disciplinary authority in an order dated June 20, 2023, dropped the charges against the charged official without consulting the Commission for Second Stage Advice (SSA),” the report said, adding that dropping of charges against the charged official is a deviation from the commission's advice.
The CVC cited another matter pertaining to the “submission of fake Bank Guarantee (BG) by a firm and delay in taking action on forfeiture of BGs and banning of the firm by officials of BSNL.” The commission, FSA, had advised initiation of major penalty proceedings against the Joint General Manager of BSNL, among others.
The disciplinary authority in the matter of the then-Jt. GM had awarded a major penalty. However, th

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Next gen GST reforms will set economy open and transparent: Sitharaman
GST
Dated:- 2-9-2025
PTI
Chennai, Sep 2 (PTI) The next generation GST reforms would 'absolutely' set an economy open and transparent with further reduction in compliance burden and benefiting small businesses, Union Finance Minister Nirmala Sitharaman said on Tuesday .
She was speaking at the 120th Foundation Day celebrations of Tamil Nadu-based City Union Bank, where President Droupadi Murmu was the chief guest.
Sitharaman said Prime Minister Narendra Modi recently announced the creation of a Task Force for next generation reforms with a clearer mandate to simplify regulations, lower compliance costs and also build a more enabling ecosystems for startups,

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India grew 7.8 pc in Q1 despite challenges driven by economic self-interest: PM Modi
GST
Dated:- 2-9-2025
PTI
New Delhi, Sep 2 (PTI) In a veiled rebuttal to the 'dead economy' jibe, Prime Minister Narendra Modi on Tuesday said the Indian economy grew 7.8 per cent in the first quarter, surpassing all expectations despite global uncertainties and challenges driven by economic self-interest.
Speaking at the Semicon India 2025 conference here, he said GDP growth in April-June was better than 'every expectation, hope and estimate'.
Indian economic performance came amidst global uncertainties and “aarthik swarth se paida hue chunautiya hai” (challenges stemming from economic self-interest), he said.
“Once again, India has outper

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tional 25 per cent tariff on Indian goods over the country's purchases of Russian oil. This increased total tariffs to 50 per cent the highest in the world.
In the run up to the imposition of the tariff, Trump had dismissed India's economy as “dead”.
India in the first quarter as well as the 2024-25 (April 2024 to March 2025 fiscal) and years proceedings it, has remained the world's fastest growing major economy, outshining China by yards. The US economy grew at 3.3 per cent in April-June.
US officials have in recent days used unduly harsh words to criticise India over continued purchase of Russian oil.
Modi said his government will unleash a new phase of next generation reforms soon.
“In the coming times, we are going to begin a

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Odisha CM attends SEMICON conclave in Delhi
GST
Dated:- 2-9-2025
PTI
Bhubaneswar, Sep 2 (PTI) Odisha Chief Minister Mohan Charan Majhi on Tuesday attended the SEMICON India 2025 conclave in Delhi, officials said.
The conclave was inaugurated by Prime Minister Narendra Modi.
Majhi embarked on a five-day visit to the national capital on September 1. Besides the conclave, he is scheduled to participate in the GST council meeting and meet some Union ministers.
Majhi's attendance at th

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Petition allowed: consolidated show-cause notices across financial years permissible; no natural justice breach found but relief granted by operative order
Case-Laws
GST
The HC allowed the petition. The court concluded that issuance of consolidated show-cause notices and orders covering multiple financial years is permissible under the statutory scheme in proceedings alleging fraudulent availment of input tax credit, and that the legislative language does not preclude consolidation where transactions span years. The HC further held that, on the specific contentions raised by the petitioner concerning non-receipt of personal hearing notices and combined SCNs, there was no jurisdictional error and no breach of principles of natural justice warranting interference under writ jurisdiction. Notwithstanding these holdings, the petition was allowed and the relief directed as stated in the operative order.
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Authority must hear fresh representation within one week and decide on deposit, GST differential, and interest within six weeks
Case-Laws
GST
The HC disposed of the writ petition and directed that if the petitioner files a fresh representation within one week before the Chief Executive Officer of the respondent Authority, accompanied by all documents the Authority requires, the Authority shall adjudicate the representation in accordance with law within six weeks. The Authority must afford the petitioner an opportunity of hearing. The relief sought – release of the security deposit, payment of GST differential due to revision in rate, and claim for interest on delayed payment – will be considered in the statutory or contractual framework; the order leaves the substantive entitlement to any refund, GST differential and the claimed 18% interest to the Authority's lawful determination.
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Writ petition disposed; GST cancellation not reinstated due to non-filing of returns; petitioner may reapply after clearing dues
Case-Laws
GST
HC held that the writ petition is disposed; the petitioner's GST registration cancellation (originally effected on 18.12.2018) was not reinstated, the court noting the petitioner's failure to file returns which resulted in a show-cause notice dated 14.01.2023 and that the cited precedent was distinguishable. The petitioner is granted liberty to apply for fresh registration in the same name upon clearing outstanding dues and fulfilling other statutory compliances. If a fresh registration application is filed within ten days, the respondent authorities must consider the application in accordance with law. No order as to costs.
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Writ dismissed for maintainability; must pursue statutory appeals; notices valid under Section 73(10) despite misquotation of Section 74
Case-Laws
GST
The HC dismissed the writ petition for lack of maintainability, holding that petitioners cannot bypass the alternative statutory remedy of appeal against the adjudication orders. The Court declined to adjudicate on whether the show-cause notices disclosed fraud, willful misstatement or suppression, noting the notices were issued within the three-year period under Section 73(10) of the CGST Act and therefore remain competent even if an incorrect section (Section 74) was quoted. The Court held mere misquotation does not render a notice without jurisdiction if it can be sustained under the correct provision. Petition dismissed; petitioners left at liberty to prosecute the appeals already instituted against the impugned adjudication orders.
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Limitation period excludes 15.03.2020-28.02.2022; assessment order quashed and matter remitted for fresh adjudication, allowing petitioner relief
Case-Laws
GST
The HC allowed the writ petition and held that, pursuant to the Principal Bench ruling, the tax authorities are entitled to exclude the period 15.03.2020 to 28.02.2022 when computing limitation under the relevant provisions, thereby entitling the petitioner to relief. Consequently, the impugned assessment order dated 16.08.2024 issued by the first respondent for the assessment year 2019-2020 is quashed. The matter is remitted to the first respondent for fresh adjudication on merits and in accordance with law, taking into account the exclusion of the specified period; no order as to costs.
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Excess deposits under Section 71 not immediately refunded; may be adjusted or set off pending expeditious post-inspection adjudication
Case-Laws
GST
HC held that where a petitioner deposited amounts under section 71 of the State GST Act, 2017 and allegations of fraud and willful misstatement or suppression of facts arose, any deposit found to be in excess shall not be refunded immediately but may be adjusted at final adjudication or set off against any amounts found due in the petitioner's favour. The court directed that invoking authorities must proceed expeditiously with post-inspection adjudicatory steps under section 71 in accordance with the statutory scheme. The petition is disposed of with the above directions.
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Petition allowed; orders quashed where detention and seizure based on misclassification and speculative undervaluation cannot sustain penalty under Section 129
Case-Laws
GST
The HC allowed the petition and quashed the impugned orders dated 4.1.2025 and 22.5.2024, holding that detention and seizure based solely on alleged misclassification and speculative undervaluation cannot sustain a penalty under Section 129 of the UP GST Act where consignment documents were in order. The court found no discrepancy in quality or quantity and noted that the e-tax invoice, e-way bill and bill of lading/accompanying transport document accompanied the goods at detention. Relying on controlling HC authority precluding penalties premised on conjectural undervaluation, the tribunal's orders imposing penalty were set aside and the petition granted.
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Assessment orders set aside for missing DIN; respondent may restart assessment with fresh notice and assigned DIN; attachment vacated
Case-Laws
GST
The HC disposed of the writ petition and set aside the impugned assessment orders dated 26.04.2024 and 18.09.2024 issued by the 1st respondent for non-inclusion of a DIN, holding such omission vitiates the proceedings. The 1st respondent is granted liberty to recommence assessment proceedings, subject to issuing fresh notice to the petitioner and assigning a DIN to resultant orders. Concurrently, the order of bank attachment for recovery of dues stands vacated. No costs imposed.
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IDFC FIRST Bank Enables GST Payments for Customers and Non-Customers
GST
Dated:- 1-9-2025
PTI
Enables payment via UPI, Cards, Net Banking and Branches
Mumbai, 1st September 2025: IDFC FIRST Bank is pleased to announce the facility to pay GST for both its customers as well as non-customers. The integration provides the following features:
1. Open to both customers and non-customers.
2. Customers can pay GST through UPI, Credit Cards, and Debit cards and internet Banking.
3. Customers can also pay through nationwide branch network (via DD/Cheque/Cash).
4. Easy access to downloadable challans.
This enhances the convenience and accessibility for all taxpayers across the country through a wide range of digital channels.

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.idfcfirstbank.com/business-banking/tax-payment)
1. Log in to the GST portal: https://services.gst.gov.in/services/login
2. Create a Challan and select E-Payment -> Net Banking/ Credit/ Debit Card/ BHIM UPI
3. Choose IDFC FIRST Bank as the payment option and complete payment
4. Download/ print the GST paid challan
For more information, please visit www.idfcfirstbank.com
About the Bank
1. Vision: To build a world-class Bank in India, founded with principles of Ethical, Digital, and Social Good Banking.
2. Scale: IDFC FIRST Bank is one of IndiaÂ’s fast-growing private banks, building its UI, UX, and tech stack like a fintech. As of June 30, 2025, the Bank serves 35 million customers, with a customer business of ?5,10,032 cr

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nology stack delivers high-quality services across all channels like mobile, branch, internet banking, call centres and relationship managers. Built on cloud-native, API-led, microservices architecture, supported with data, analytics, AI, and fine aesthetics, we strive to deliver fintech-grade experiences on banking platform.
6. Social Good: We work for society. We have financed over 38 million loans including 15 million women entrepreneurs, 16 million loans (laptops, washing machines, refrigerators etc. that enhance the quality of life of middle class), 6.5 million vehicle loans, 1 million sanitation loans, 1 million livelihood loans, and 300,000 SMEs. On deposits, we provide access of premium investment research, which is usually reserv

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