TP Segment Split Rejected as Trading & After-Sales Services Are Inextricably Linked; TNMM at Entity Level Upheld: ITAT Delhi

Juniper Networks Solutions India Private Limited Vs ACIT (ITAT Delhi)

TP Segment Split Rejected as Trading & After-Sales Services Are Inextricably Linked; TNMM at Entity Level Upheld: ITAT Delhi

The appeal arises from the final assessment order dated 28.10.2024 for Assessment Year 2021–22, passed under Sections 143(3), 144C(13), and 144B of the Income-tax Act pursuant to the directions of the Dispute Resolution Panel (DRP). The assessee challenged multiple aspects of the assessment, including an upward revision of income, transfer pricing (TP) adjustments, segmentation of business activities, benchmarking methodology, allocation of expenses, selection of comparables, denial of risk adjustment, and initiation of penalty proceedings.

A key issue before the Tribunal was whether the tax authorities were justified in segregating the assessee’s operations into a trading segment and a service segment, and consequently rejecting the application of the Transactional Net Margin Method (TNMM) at the entity level. The assessee argued that its business model was integrated and that trading and service functions were inextricably linked.

The assessee relied on the Tribunal’s decision in its own case for the immediately preceding assessment year (A.Y. 2020–21), where identical issues had been considered. In that earlier decision, the Tribunal had accepted the assessee’s contention that its business model could not be artificially segmented and had upheld the application of TNMM at the entity level. The assessee submitted that the facts for the current year were identical and that the earlier ruling should be followed.

The Department contended that the facts were not necessarily identical due to absence of certain documents, but the assessee furnished the relevant transfer pricing order for the earlier year to demonstrate similarity. Upon examining the material, the Tribunal found that the issues, facts, and even the approach of the Transfer Pricing Officer (TPO) were substantially the same for both years.

The Tribunal analysed the nature of the assessee’s business and observed that it involved import, distribution, sales, and customer support services of networking equipment and software. It noted that customer services, including maintenance, technical support, and training, were closely connected with the sale of products. These services were often dependent on or bundled with the products supplied and formed part of a unified commercial offering.

It was observed that the tax authorities had split the business into two segments and allocated expenses based on revenue proportions, without adequately considering the functional interdependence between trading and service activities. The Tribunal held that such segmentation overlooked the integrated nature of the business. It further noted that customer services were largely driven by and dependent on the trading activity, and that without the trading function, the service segment would not independently exist.

The Tribunal also examined the revenue recognition policy and found that product and service obligations were often combined and fulfilled together. This reinforced the conclusion that the two segments were intertwined and could not be reliably evaluated separately.

Based on these findings, the Tribunal held that the action of carving out a separate trading segment was incorrect. It accepted the assessee’s contention that the business model was integrated and that TNMM at the entity level was the appropriate method for benchmarking.

Since this core issue was decided in favour of the assessee by following the precedent from the earlier year, the Tribunal allowed the relevant ground of appeal. Consequently, other grounds raised by the assessee were rendered unnecessary for adjudication and were left open.

In conclusion, the Tribunal partly allowed the appeal, holding that the segmentation of trading and service activities was unjustified and that the integrated business model warranted entity-level benchmarking under TNMM.

FULL TEXT OF THE ORDER OF ITAT DELHI

This appeal is filed by the assessee against the final assessment order dated 28.10.2024 passed u/s.143(3) r.w.s.144C(13) r.w.s. 144B of the Act pursuant to the directions of the DRP dated 20.09.2024 passed u/s. 144C(5) of the Act for the A.Y. 2021-22.

2. The assessee has raised following grounds of appeal :-

1. On the facts and circumstances of the case and in law, National Faceless Assessment Centre-Assessment Unit- Income Tax Department (the Ld. AO’) erred in assessing the income of the Appellant at Rs. 1,05,75,58,433 as against returned income of Rs. 1,01,25.26.119.

The Appellant prays that the Ld. AO be directed to accept the returned income

2. On the facts and circumstance of the case, the Ld. AO/ the Learned DC/ ACIT TP Delhi 2(2)(1) (‘Ld. TPO’) erred in making a Transfer Pricing (TP) adjustment of Rs. 4,50,32,314 on account of incorrect computation of working capital adjustment while passing the order to give effect to the Learned Dispute Resolution Panel’s (‘Ld. DRP’) directions.

The Appellant prays that the Ld. AO/Ld. TPO be directed to correctly compute the working capital adjustment as per Ld. DRP’s directions.

3. Without prejudice, on the facts and circumstances of the case and in law, the Ld. AO/Ld. TPO has erred in:

• • adopting different treatment of various items as operating/non-operating in nature for computing the operating margin for the tested party (Appellant) and for the comparables, and thereby not following a consistent approach.

4. The Appellant prays that the Ld. AO/ Ld. TPO be directed to accept the treatment of items as operating/non-operating as considered by the Appellant in the TP Study and also accepted by the Ld. TPO at the time of passing the TP order, and thereby follow the consistent approach.

On the facts and circumstances of the case and in law, for determination of arm’s length price (‘ALP’), the Ld. DRP erred in upholding action of Ld. AO/ Ld. TPO in carving out alleged trading segment by not accepting the inextricably linked i.e, model of the Appellant and rejecting the application of Transactional Net margin Method (TNMM) at entity level.

The Appellant prays that the Ld. AO/Ld. TPO be directed to accept the inextricably linked business model of the Appellant and also accept application of TNMM at entity level

5. Without prejudice, on the facts and circumstances of the case and in law, the Ld. DRP has erred in upholding action of the Ld. AO/Ld. Ld. TPO in:

allocating the indirect/common expenses in proportion of the revenue instead of allocating the same based on the gross profit of the alleged trading segment and alleged service segment

The Appellant prays that the Ld. AO/ Ld. TPO be directed to accept the allocation key based on the gross profit of the alleged trading segment and alleged service segment for allocating indirect/common expenses

6. Without prejudice, on the facts and circumstances of the case and in law, the Ld. DRP has erred in upholding action of the AO/Ld. TPO in:

• • not considering Resale Price Method (‘RPM) as the most appropriate method for benchmarking the international transaction related to purchase of traded goods under the alleged trading segment.

The Appellant prays that the Ld. AO/ Ld. TPO be directed to accept the RPM as the most appropriate method for benchmarking the international transaction related to purchase of traded goods under the alleged trading segment.

7. On the facts and circumstances of the case and in law, the Ld. DRP has erred in upholding action of the Ld. AO/Ld. TPO in including the comparables in the final benchmarking set in the TP order that:

• • fails TPO’s own sales trading income filter of 75%;
  • are not comparable to the alleged trading segment of the Assessee in terms of functions performed, assets employed and risks assumed.

The Appellant prays that Ld. AO/ Ld. TPO be directed to exclude the companies that fail TPO’s own sales trading income filter; and are not functionally comparable.

8. On the facts and in the circumstances of the case and in law, the Ld. DRP has erred in upholding the action of the Ld. AO/Ld. TPO in not granting risk adjustment to the profit Level Indicator (‘PLI’) of comparable companies as required by Rule 10B(3) read with Rule 10B(1)(e) of Income-tax Rules, 1962 (‘the Rules’).

9. On the facts and in the circumstances of the case and in law, the Ld. AO has erred in initiating penalty proceedings under section 270A of the Act.

The Appellant prays that the Ld. AO be directed to drop the penalty proceedings under section 270A of the Act.

3. The Ld. Counsel for the assessee at the outset submitted that identical issues came up for consideration before the Tribunal in assessee’s own case in the immediately preceding assessment year i.e. A.Y. 2020-21 in ITA No.4400/Del/2024 dated 24.10.2025 and the Tribunal considering the submissions evidences placed on record held that trading segment of the assessee cannot be carved out since trading segment is inextricably linked to integrated business model of the assessee and accepted the transactional net margin method (TNMM) adopted by Assessee at entity level.

4. The Ld. Counsel for the assessee submits that the facts being identical for the assessment year under consideration i.e. A.Y.2021-22 the decision of the Tribunal may be followed. The Ld. Counsel submits that the order of the Tribunal for the immediately preceding is placed at pages-62 to 75 of the paperbook. Referring to grounds of appeal before the Tribunal for the immediately preceding assessment year which was extracted by the Tribunal at page-7 of the order, Ld. Counsel submitted that ground No.3 of grounds of appeal for the A.Y. 2020-21 is identical to ground No. 4 of grounds of appeal of the assessee for the year under consideration. It is submitted that if ground No.4 is allowed of ITAT for following the order immediately preceding year, other grounds becomes infructuous.

5. On the other hand the Ld. DR submitted that since the copy of the order of the TPO for the immediately preceding year is not placed on record, the facts cannot be said to be identical for the A.Y. 2021-22.

6. In reply the Ld. Counsel for the assessee furnished a copy of the order of the TPO for the A.Y’s 2020-21 which is placed on record.

7. Heard rival submissions and perused the orders of the authorities below and the materials placed before us. We observed that the issues in the appeal for the assessment year under consideration is identical to the issues raised before the Tribunal for the A.Y. 2020-21, including the orders passed by the TPO for both the assessment years. In ground No.4 of grounds of appeal the assessee contended that the DRP erred in upholding the action of the AO/ TPO in carving out trading segment by not accepting the inextricably linked integrated business model of the assessee and not accepting the application of transactional net margin method (TNMM) at entity level. It was the prayer of the assessee that AO/ TPO be directed to accept the inextricably linked to business mobile of the assessee and also accept the application of TNMM at entity level. The very same identical ground which was raised by the assessee for the immediately preceding assessment year i.e.2020-21 came up for consideration before the Tribunal in appeal No.4400/Del/2024 and the Tribunal by order dated 24.10.2025 accepted the contentions of the assessee in ground and allowed the claims of the assessee, by observing as under :-

2. Brief facts of the case are, the assessee company, M/s Juniper Networks Solution India Private Limited is engaged in the business of distribution, sales, marketing and customer support services of internet protocol secure networking solutions, equipment and software. The assessee imports networking equipment from an overseas entity and further is engaged in distribution, sales, marketing, customer support services of internet protocol secured networking solutions, equipment and software embedded in such imported equipment. The Company is a Limited Risk Distributor for its Associated Enterprise viz. Juniper Networks International BV (JNIBV). It imports networking equipments and related spares/ consumables from JNIBV for onward selling either in the Indian Market or other countries through Merchant Trading Transactions.

3. The Company was incorporated on 11^th December 2017 as a Limited Risk Distributor for Juniper Networks International BV (JNI BV) for the purpose of sale of networking equipment in India. Consequently, the assessee purchases goods (both for the purpose of distribution and as spares) for onwards distribution to third party customers. Additionally, through Merchant Trading Transactions, the Company also undertook Merchant Trading Transactions (MTT) which involves physical shipment of goods from one foreign country to another foreign country without the goods entering into the Domestic Tariff Area (of India). This is only 2nd year of operations in India by the Company.

4. The assessee company has filed its return of income on 12.01.2021 vide acknowledgement no. 204286211120121 declaring total loss of Rs.49,78,97,850/-and deemed total income u/s 115JB at Rs.0/-. The case of the assessee was selected for scrutiny assessment under CASS, therefore notice u/s 143(2) of the Income-tax Act, 1961 was issued to the assessee company vide notice bearing DIN: ITBAIAST/S/143(2)/2021-22/1033793662(1) dated 29.06.2021. The return of the assessee was selected for scrutiny through CASS on the following issues :–

5. A reference u/s 92CA(1) of the Act, was made to the TPO on 29.12.2021 in respect of the international transactions/specific domestic transactions reported in Form No. 3CEB filed by the assessee company. Notice u/s. 142(1) of the Act alongwith questionnaire was also issued and duly served upon the assessee.

6. The case was referred to TPO on the basis of information that the assessee has reported international transactions reported in the form no 3CEB. The profile of the assessee was reproduced by the TPO in his order at page of 1 of the order and the same are also reproduced by the AO, which had already reproduced in brief facts above. We also observed that the TPO himself observed that the assessee is doing trading activity, in the second limb, it is providing maintenance /warranty services in India. He further observed that both the business functions are having different nature as well as expenses and profit. He rejected the claim of the assessee that they are inextricably linked. The assessee has benchmarked for margin on entity level for TNM Method, which included profit from trading and service businesses. The TPO rejected the claim and however accepted the TNMM. He proceeded to split the trading segment results from the combine results as under:

7. We observed that in the above chart, the TPO has split the income and expenses on the basis of trading segment and allocated the cost on the basis of revenue from operation (particularly employee cost and other expenses). He determined the OP/Sales at -8.18%. He observed that the assessee is incurring losses in its trading segment which is basically based on purchases and supply from its AEs. The assessee was issued notices to submit the details, the contents of the notices are reproduced at page 4 and 5 of TPO order. He analysed the weighted average OP/Sales declared by the assessee in FY 2017-18 to 2019-20, which are of 12 comparable, applied the filters and narrowed down to the 7 comparables, determined the median of 6.62%. The assessee was asked to submit their views to finalise the bench marking. After considering the various objections of the assessee on the segment carved out, ALP methodology, allocation key proposed, TNMM over RPM, application of quantitative filters and arithmetic error in margins, working capital adjustments and risk adjustments and comparable selection. After considering the submissions of the assessee and method adopted by the assessee for segment results and all other objections raised by the assessee, TPO rejected the same and finally he determined the OP/OR of comparable for trading segment at 2.27% and finally proposed ALP adjustment of Rs. 16,86,93,204/-.

8. Aggrieved with the above order, the assessee filed objections before the DRP and filed their grounds of objections, also filed detailed submissions. After considering the same, the DRP has sustained all the findings of the AO/TPO except allowed the working capital adjustment to be computed on the adjusted margins in accordance with the OECD guidelines. Accordingly, the TPO revised the weighted average adjusted mean of the comparable after allowing the working capital adjustments, which is reproduced at page 2 of the order giving effect to the DRP order, the median determined by him is 8.12% in comparison to the 35^th and 65^th TPO found that the operating margin of the assessee is within the ALP, accordingly, the adjustment was reduced to nil.

9. Against the order of Final assessment order and directions of DRP on the issue of rejecting the various objections raised before the DRP, which DRP had sustained the findings of TPO and given relief only on the issue of working capital adjustment, assessee filed the following grounds of appeal :-

“1.On the facts and circumstances of the case and in law, National Faceless Assessment Centre- Assessment Unit-Income Tax Department (‘the Ld. AO’) erred in assessing the income of the Appellant at Rs.66,65,91,054 as against returned income of Rs.49,78,97,850. The Appellant prays that the Ld. AO be directed to accept the returned income.

2. On the facts and circumstance of the case, the Ld. AO erred in making an adjustment of Rs.16,86,93,204 on account of TP adjustment without appreciating the fact that the aforesaid adjustment has been deleted by the Learned DC/ACIT TP Delhi 2(2)(1) (‘Ld. TPO’) in the order passed to give effect to the Dispute Resolution Panel (,DRP’) directions.

The Appellant prays that the Ld. AO be directed to delete the adjustment of Rs.16,86,93,204.

3. On the facts and circumstances of the case and in law, for determination of arm’s length price (‘ALP’), the Ld. DRP erred in upholding action of Ld. Assessing Officer/ Ld. TPO in carving out alleged trading segment by not accepting the inextricably linked i.e., integrated business model of the Appellant and rejecting the application of Transactional Net margin Method (TNMM’) at entity level.

The Appellant prays that the Ld. Assessing Officer/ Ld. TPO be directed to accept the inextricably linked business model of the Appellant and also accept application of TNMM at entity level.

4. Without prejudice, even if alleged trading segment is casted, on the facts and circumstances of the case and in law, the Ld. DRP has erred in upholding action of the Ld. AO/Ld. Ld. TPO in:

• • • allocating the indirect I common expenses in proportion of the revenue of alleged trading segment and alleged service segment
    • in disregarding and rejecting the allocation key based on the gross profit of the alleged trading segment and alleged service segment

The Appellant prays that the Ld. Assessing Officer/ Ld. TPO be directed to accept the allocation key based on the gross profit of the alleged trading segment and alleged service segment for allocating indirect/common expenses.

5. Without prejudice, even if alleged trading segment is casted, on the facts and circumstances of the case and in law, the Ld. DRP has erred in upholding action of the Assessing Officer/Ld. TPO in:

• • • not considering Resale Price Method (‘RPM’) as the most appropriate method for benchmarking the international transaction related to purchase of traded goods under the alleged trading segment.

The Appellant prays that the Ld. Assessing Officer/ Ld. TPO be directed to accept the RPM as the most appropriate method for benchmarking the international transaction related to purchase of traded goods under the alleged trading segment.

6. On the facts and in the circumstances of the case and in law, the Ld. DRP has erred in upholding the action of the Ld. AO / Ld. TPO in not granting risk adjustment to the profit Level Indicator (‘PLI’) of comparable companies as required by Rule 10B(3) read with Rule 10B(1)(e) of Income-tax Rules, 1962 (‘the Rules’).

7. On the facts and in the circumstances of the case and in law, the Ld. AO has erred in initiating penalty proceedings under section 270A of the Act.

The Appellant prays that the Ld. AO be directed to drop the penalty proceedings under section 270A of the Act.

Each Ground is without prejudice to and independent of each other.”

10. At the time of hearing, ld. AR submitted that the assessee is mainly involved in the import and distribution business, it is involved only in distribution and not a service provider. In this regard, he brought to our notice recording of nature and profile of the assessee at page 1 of TPO order and also para 5.8 of the DRP order where they have clearly recorded the FAR analysis. Further he brought to our notice the TP study submitted by the assessee, which is placed at pages 23 to 34 of the paper book. With reference to above material on record, he submitted that the lower authorities have recorded the nature of service segment, the assessee provides after sale services in the form of AMC through its own employees. After recording the same, they observed that these are two legs of transactions form separate class of transactions involve different levels of risk involved. He brought to our notice the observations of the DRP that under TP regulations, the bench marking should be done on transaction to transaction basis unless the transactions are so closely inter-linked and continuous that separate evaluation of the same is not possible. Whereas in the given case, the same are fundamentally different, it can be segregated. Therefore, he sustained the findings of TPO and ld. DRP also rejected all other objections raised by the assessee.

11. He further brought to our notice agreement placed at page 578 of the paper book. He submitted that as per the above agreement and recital, the assessee wishes to market and distribute software and customer services, avail services as defined in clause 1.4 of the agreement from the AE. He also brought to our notice nature of customer services mentioned in clause 1.4. He submitted that the functions of the assessee company are intertwined with the trading segment. Further he brought to our notice page 591 of the paper book, which is the letter written to TPO indicating that both products and services were procured by the assessee from its AE and no payment was made by the assessee towards procurement of services.

12. On the other hand, Ld DR heavily relied on the detailed findings of lower authorities.

13. Considered the rival submissions and material placed on record. We observed that the assessee is a wholly owned subsidiary of Juniper Network International B.V, Netherlands. It is part of a network of affiliated companies engaged in the business of designing, developing, manufacturing, marketing and distribution of the products and customer services as per clause 1.4 of the mutual agreement. For the sake of brevity, it is reproduced below:

“1.4 “Customer Services” means :

(a) Product maintenance services (including any of the following or any combination thereof: distribution of Software Releases and certain upgrades, remote technical services, repair services, and technical support for diagnosis and remediation of Hardware, Software or system defects) in the form of offerings and terms and conditions authorised under policies established by Juniper or its Affiliates from time to time;

(b) professional services (including pre-defined and custom services to address a broad range of engagements including, but not limited to. product installation and configuration, network-level design, implementation and monitoring);

(c) educational services (including a wide variety of training courses and technical certification programs) ;

(d) resident engineering services (including, but not limited to, analysing network configurations, assisting with network inventory tracking and management to support the network. testing product features and functionality, providing technical and product workshops, troubleshooting the network and supporting operations, developing network and equipment operating procedures, evaluating technical specifications tor interoperability, and assisting in the definition of key performance indicators for the network and services); and

(e) such other services provided by JNSIPL to the Customer.”

14. Further as per the software and service agreement, the assessee is mainly engaged in marketing and customer service as per the mutual agreements which include the warranty extended on the product.

15. We observed that considering the fact that the assessee is involved in the trading of the products supplied by the AEs and also having service facility, the tax authorities divided the business of the assessee in two segments and reworked the segmental results by allocation on the basis of revenue factor. In our view, they have completely overlooked the fact that the core business is trading and the customer services are interconnected to it. Most of customer services are provided with the assistance of AEs. In case the trading results has to be bench marked when the trading is complete as soon as the products are sold to the Indian customers whereas it is inter connected with the after sales customer services as defined in the clause of 1.4 of the mutual agreement. Merely because the assessee has facility to provide customer services, it cannot be segregated without analysing the key functions which are inter dependent on each other. In our view, the sole existence of the assessee company depends upon the trading activities without that there is no business for the service segment. It is like egg or chicken story.

16. Even for the argument, if we segregate the segments on the basis of activities, we observed that the TPO had simply divided on the basis of revenue without considering the fact that the majority of the service segment is established only for the purpose of dealing with the after sales services. If that be the case, at least he should have considered for allocating the manpower and other cost on the basis of 80:20. This would have given the result appropriate.

17. Coming to the issue of revenue recognition, we observed that the assessee recognises the revenue on the basis of below:

“f. Revenue from contracts with customers

Revenue is recognized when promised goods or services are transferred to customers In an amount that reflects (he consideration to which the Company expects to be entitled in exchange for those goods or services by following a five-step process. (1) identify the contract with a customer, (2) identify the performance obligations in the contract, (3) determine the transaction price. (4) allocate the transaction price, and (5) recognize revenue when or as the Company satisfies a performance obligation as further described below.

Identify the contract with a customer: The Company generally considers a sales contract or agreement with an approved purchase order as a customer contract provided that collection is considered probable, which is assessed based on the creditworthiness of the customer as determined by credit checks, payment histories, and/or other circumstances. The Company combines contracts with a customer if contracts are negotiated with a single commercial substance or contain price dependencies

Identify the performance obligations in the contract: Product performance obligations include hardware and software license and service performance obligations include maintenance. software post-contract sup pan, training, and professional services. Certain software licenses and related post-contract support are combined into a single performance obligation when the maintenance updates are crucial to the continued functionality of the software.

Determine the transaction price: The transaction price for the Company’s contracts with its customers consists of both fixed and variable consideration provided it is probable that a significant reversal of revenue will not occur when the uncertainty related to variable consideration is resolved. Fixed consideration includes amounts to be contractually billed to the customer while variable consideration includes estimates for rights of return, rebates, and price protection. which are based on historical sales returns and price protection credits, specific criteria outlined in rebate agreements, and other factors known at the time. The Company generally invoices customers for hardware, software licenses and related maintenance arrangements at time of delivery. and professional services either up front or upon meeting certain milestones. Customer invoices are generally due within 30 to 90 days after issuance. The Company’s contracts with customers typically do not include significant financing components as the period between the transfer of performance obligations and timing of payment are generally within one year.

Allocate the transaction price to the performance obligations in the contract: For contracts that contain multiple performance obligations, the Company allocates the transaction price to the performance obligations on a relative standalone selling price basis Standalone selling prices are based on multiple factors including, but not limited to historical discounting trends for products and services, pricing practices in different geographies and through different sales channels, gross margin objectives, internal costs, competitor pricing strategies, and industry technology lifecycles.

Recognize revenue when or as the Company satisfies a performance obligation: Revenue for hardware and certain software licenses, are recognized at a point in time, which is generally upon shipment or delivery. Certain software licenses combined with post-contract support are recognized over time on a ratable basis over the term of the license. Revenue for maintenance and software post-contract support is recognized over time on a ratable basis over the contract term, Revenue from training and professional services is recognized over time as services are completed or rate ably over the contractual period of generally one year or less.”

18. From the above, it is relevant to notice the identification of the performance obligations in the contract, it says “Product performance obligations include hardware and software licenses, and service performance obligations include maintenance, software post-contract, training and professional services. Certain software licenses and related post-contract support are combined into a single performance obligation when the maintenance updates are critical to the continued functionality of the software.” From the above revenue recognition of the assessee company indicate that the trading and services performances are intertwined and cannot be separated. The action of the revenue is wrong to divide the segments into two and allocate the cost on the basis of revenue of segment without properly analysing the nature of functions and intertwined services transaction with the products marketed by the assessee with the assistance of original manufacturer and actual services provider, in this case, JNI BV, Netherland. Therefore, we are in agreement with the submissions of the assessee in this case and you cannot divide the peculiar nature of the trading business of the assessee with the services provided by it to the Indian customers with the assistance of its AE. In the result, ground no 3 raised by the assessee is allowed in its favour.”

8. Facts being identical, respectfully following the said decision of the Coordinate Bench in assessee’s own case we allow ground No.4 of grounds of appeal of the assessee. All other grounds need not be adjudicated and they are left open.

9. In the result, the appeal of the assessee is partly allowed as indicated above.

Order pronounced in the open court on 22.04.2026.