GST on Healthcare Services — What Doctors and Clinics in Delhi Need to Know Before the Next Filing Deadline

NEW DELHI — India’s healthcare landscape is undergoing a fundamental shift. Post-COVID, thousands of doctors, surgeons, and specialists across Delhi NCR have set up independent practices, multi-specialty clinics, and telemedicine platforms — many for the first time. While their medical expertise is unquestionable, their familiarity with India’s complex tax framework often is not. GST on healthcare services, income tax under Section 44ADA, TDS on professional fees, and professional tax are a minefield of confusion that costs healthcare professionals in Delhi lakhs of rupees every year — in avoidable tax, missed deductions, and penalty notices they never anticipated. B M C & Associates, a full-service CA firm in Delhi NCR with 14+ years of experience and a dedicated healthcare sector practice, releases this comprehensive tax and compliance guide to help Delhi’s doctors, clinic owners, and hospital administrators navigate every key obligation with clarity and confidence.
Why Healthcare Tax Compliance Has Become More Complex Since 2022
The GST framework for healthcare was amended significantly via Notification No. 04/2022-CT(R) dated 13th July 2022, which introduced important modifications to the exemption structure. Combined with the 47th and 50th GST Council resolutions, the September 2025 GST rationalisation measures, and the new Budget 2025–26 tax regime changes, doctors in Delhi face a compliance environment that is meaningfully different from what it was even three years ago.
Additionally, the post-COVID boom in independent medical practice has created a new category of healthcare professional: the solo specialist who consults at multiple hospitals, earns from telemedicine platforms, sells wellness packages, and perhaps also runs a clinic — all with different tax treatments that apply simultaneously.
“Doctors are among the highest-earning professionals in India, and they are also among the most undertaxed in terms of legitimate deductions they are entitled to but never claim. We regularly help doctors recover ₹2–5 lakh per year in excess tax through correct Section 44ADA election, proper 80D claims, depreciation on clinic equipment, and NPS contributions. The money is there in the law. Most doctors simply don’t know about it.”
— CA Bipin Kumar Jha, Partner, B M C & Associates
PART 1: GST for Doctors and Clinics — What Is Exempt, What Is Taxable, and Why It Matters
The Core Rule: Healthcare Services Are Largely GST-Free
Under Notification No. 12/2017-Central Tax (Rate) as amended in July 2022, healthcare services provided by a clinical establishment, an authorised medical practitioner, or a paramedic are exempt from GST. The exemption covers the entire spectrum of core medical activity:
✅  GST-EXEMPT Healthcare Services (No GST, No Registration Required):
•        Doctor consultations — OPD, IPD, general practice, specialist consultations of all kinds
•        Diagnosis, pathological tests, X-rays, MRI, CT scans when conducted within the clinical establishment as part of patient care
•        Surgical procedures, therapeutic care, inpatient treatment of all kinds
•        Ambulance services for transport of patients to and from clinical establishments
•        IVF and Assisted Reproductive Technology (ART) procedures — clarified as exempt by the 47th GST Council
•        AYUSH treatments (Ayurveda, Yoga, Unani, Siddha, Homoeopathy) by recognised practitioners
•        Telemedicine consultations for patient care — same exemption as in-person consultation (Ministry of Health clarification, 2021)
•        Preventive healthcare services, vaccination, immunisation
•        Services under government health schemes (CGHS, PMJAY/Ayushman Bharat) — exempt
•        Blood bank services, organ preservation services
 
Where GST Does Apply: The Grey Zones That Trap Doctors
The exemption is not unlimited. Several services that doctors and clinic owners commonly provide fall outside the GST exemption and attract tax at 5% or 18%. Missing these obligations is one of the most common reasons healthcare professionals receive GST notices:
❌  TAXABLE Services Where GST Applies to Doctors:
•        Cosmetic and aesthetic surgery — 18% GST (UNLESS the procedure is medically necessary to restore anatomy or function affected by congenital defect, injury, or disease)
•        Hair transplant procedures — 18% GST with no medical necessity exemption
•        Hospital room charges above ₹5,000 per day (excluding ICU/CCU/NICU) — 5% GST; no ITC allowed
•        Sale of medicines to outpatients (not bundled with treatment) — 5% or 12% GST depending on medicine category
•        Medico-legal reports, expert witness opinions, fitness certificates for non-patient purposes — 18% GST
•        Health coaching, wellness packages, and yoga centres not attached to a clinical establishment — 18% GST
•        CME lectures, medical workshops, training programmes — 18% GST
•        Renting out clinic space, medical equipment, or consultation rooms to other doctors — 18% GST
•        Biomedical waste treatment services charged by external operators to clinical establishments — 12% GST
•        Health check-up packages marketed as wellness (not diagnosis) — 18% GST
 
“The line between exempt and taxable can be extraordinarily thin in healthcare. A knee replacement for a road accident patient: exempt. The same procedure for a patient who simply wants better mobility from arthritis: still exempt — it is medically indicated. A rhinoplasty to correct a deviated septum causing breathing difficulty: exempt. A rhinoplasty for cosmetic improvement: 18% GST. The distinction is medical necessity, and it must be documented.”
— CA Manish Mishra, Partner, B M C & Associates
GST Registration: When Does a Doctor Actually Need to Register?
This is the question BMC hears most frequently from newly independent practitioners in Delhi:
1.     Exempt services only + turnover any amount: If your clinic or practice provides ONLY GST-exempt healthcare services, you do NOT need to register for GST, regardless of your turnover. A cardiologist earning ₹1 crore per year from patient consultations has no GST obligation.
2.     Turnover below ₹20 lakh + ANY taxable service: If you provide some taxable services (e.g., selling medicines, cosmetic procedures) but total turnover from taxable services is below ₹20 lakh, GST registration is not mandatory (₹10 lakh for special category states).
3.     Turnover above ₹20 lakh + ANY taxable service: If your aggregate turnover (exempt + taxable) exceeds ₹20 lakh AND you provide any taxable service, GST registration becomes mandatory. This catches many doctors running pharmacies or offering wellness services.
4.     Multi-state practice: If you consult in more than one state (e.g., Delhi and Noida or Gurugram), GST registration is mandatory regardless of turnover.
5.     E-commerce platforms: If you receive consultation fees through any online platform or aggregator app, GST registration may be required from the first rupee.
 
The ITC Trap: Why Doctors Cannot Claim Input Tax Credit
One of the most misunderstood and financially significant aspects of GST for healthcare is the Input Tax Credit (ITC) restriction. Because core healthcare services are exempt from GST, healthcare providers cannot claim ITC on the GST they pay for goods and services used in providing those exempt services.
⚠️  What This Means in Practice — ITC You CANNOT Claim:
•        GST paid on purchasing a new MRI machine, ultrasound, ECG equipment — NOT claimable
•        GST paid on clinic renovation, furniture, air conditioning — NOT claimable
•        GST paid on medical consumables (gloves, syringes, dressings) used in exempt procedures — NOT claimable
•        GST paid on hospital room construction or fit-out — NOT claimable
•        GST on biomedical waste disposal fees (12%) paid to external operator — NOT claimable against exempt services
•        EXCEPTION: ITC CAN be claimed on inputs used exclusively for taxable services (cosmetic surgery equipment, pharmacy medicines for retail sale)
 
This restriction is not a loophole or a compliance failure — it is how the law is structured. The best response is to factor the irrecoverable GST cost into pricing decisions and to ensure that any mixed-use expenditure (used for both exempt and taxable services) is correctly apportioned and the eligible portion claimed.
Complete GST Rate Reference for Healthcare Professionals (Updated to September 2025)
The following comprehensive table covers every common service and supply encountered in medical practice in India, with current GST rates, SAC codes, and ITC eligibility:
 
Service / Supply
GST Rate
SAC/HSN
ITC Available?
Key Condition
Doctor consultations (OPD, IPD)
EXEMPT
9993
No
Must be by authorised medical practitioner
Diagnosis & pathology tests (in-house)
EXEMPT
9993
No
Must be within clinical establishment
X-Ray, MRI, CT Scan (in-house)
EXEMPT
9993
No
Bundled with healthcare service
Ambulance services
EXEMPT
9993
No
Transport of patient to/from clinical establishment
IVF / ART procedures
EXEMPT
9993
No
Clarified by 47th GST Council
AYUSH treatments (recognised)
EXEMPT
9993
No
Must be by registered AYUSH practitioner
Hospital room rent (up to ₹5,000/day)
EXEMPT
9993
No
Excludes ICU/CCU/NICU
Hospital room rent (above ₹5,000/day)
5%
9993
No
Excluding ICU; no ITC allowed
Cosmetic / aesthetic surgery
18%
9993
Yes
Exempt ONLY if medically necessary (reconstructive)
Hair transplant services
18%
9993
Yes
Not a healthcare service under GST law
Sale of medicines (outpatient)
5% / 12%
Various
Yes
Depends on medicine category
Sale of medicines (inpatient bundle)
EXEMPT
9993
No
Part of composite healthcare service
Medical implants & prosthetics
5%
9021
Yes
GST Council reduced from 12% to 5%
Biomedical waste treatment
12%
9994
Yes
Charged by treatment facility to clinic
Medico-legal reports / expert opinions
18%
9983
Yes
Non-clinical consultancy service
Health check-up packages (wellness)
18%
9993
Yes
If not bundled with treatment
Renting of clinic/equipment to others
18%
9972/9973
Yes
Commercial rental — not exempt
CME lectures / medical workshops
18%
9992
Yes
Non-medical professional service
Telemedicine (clinical, patient care)
EXEMPT
9993
No
Same exemption as in-person; 2021 clarification
Health insurance TPA services
18%
9985
Yes
Administrative service — not healthcare

 
PART 2: Income Tax for Doctors — The Deductions Most Healthcare Professionals Miss
Section 44ADA: The Presumptive Tax Scheme Built for Doctors
Section 44ADA of the Income Tax Act, 1961 is the single most important provision for solo medical practitioners in India — and one of the most underutilised. Introduced specifically for professionals including doctors, lawyers, engineers, and architects, it allows eligible practitioners to declare 50% of their gross professional receipts as net taxable income, without needing to maintain detailed books of accounts or undergo a tax audit.
💡  Section 44ADA Key Facts for Delhi Doctors:
•        Eligible if gross professional receipts (not net profit) are up to ₹75 lakh per year (increased from ₹50 lakh effective FY 2023-24)
•        Declare 50% of gross receipts as profit — regardless of actual expenses
•        No requirement to maintain books of accounts, P&L, or balance sheet
•        No tax audit required even if receipts approach ₹75 lakh
•        Advance tax payable as a single instalment by March 15 (not quarterly)
•        Available under both Old and New Tax Regimes
•        If actual expenses exceed 50% of receipts (e.g., high rent, large equipment EMIs), it may be better to opt OUT of 44ADA and claim actual expenses with a regular audit
•        Doctors earning above ₹75 lakh must maintain full books and undergo compulsory tax audit under Section 44AB
 
“We have seen doctors with gross receipts of ₹60 lakh paying tax on ₹40 lakh of ‘actual profit’ when their actual expenses were only ₹15 lakh — they chose 44ADA and paid tax on only ₹30 lakh, saving ₹3–45 lakh in tax. Equally, we have seen doctors with high clinic rents and equipment loans paying tax on 50% of receipts when their actual profit was only 20% — costing them lakhs extra. The right choice between 44ADA and regular accounting depends entirely on your individual expense structure.”
— CA Saroj Jha, Partner, B M C & Associates
TDS on Professional Fees: Reconciling What Hospitals Deduct
Doctors who consult at hospitals, nursing homes, or diagnostic centres — as visiting consultants rather than employees — have their professional fees subject to TDS at 10% under Section 194J when the annual payment exceeds ₹30,000. This is one of the most common compliance issues in the healthcare sector:
•        The hospital or clinic deducts TDS from every fee payment and deposits it with the government on the doctor's PAN
•        The doctor must reconcile total TDS deducted across all hospitals and clinics via Form 26AS and the Annual Information Statement (AIS) before filing ITR
•        TDS deducted by hospitals must be claimed as advance tax credit in the ITR; failure to do so results in paying double tax
•        If the doctor has submitted a lower deduction certificate (Form 13 from the Income Tax Department), hospitals must deduct at the reduced rate — but doctors rarely apply for this
•        Hospitals that fail to deduct TDS or deposit it late face penalties; doctors should verify their 26AS regularly to ensure credited TDS matches expectations
 
6 Critical Tax Deductions Delhi Doctors Are Missing Every Year
DEDUCTION 1:  NPS Contribution — An Additional ₹50,000 Deduction Most Doctors Ignore
Under Section 80CCD(1B), an additional deduction of ₹50,000 per year is available for contributions to the National Pension System (NPS) — over and above the standard ₹1.5 lakh Section 80C limit. This means a doctor in the 30% tax bracket saves ₹15,000 in tax annually, purely from opening an NPS account and contributing ₹50,000. Available under the Old Tax Regime only, but a high-impact, low-effort deduction.
DEDUCTION 2:  Depreciation on Clinic Equipment — Even Under 44ADA
A common misconception is that opting for Section 44ADA means no depreciation can be claimed. The Income Tax Act allows depreciation on personal assets (vehicle, equipment) even under the presumptive scheme. Doctors with high-value assets (diagnostic equipment, surgical instruments, clinic interiors) can claim depreciation that directly reduces taxable income — and this benefit is separate from the 44ADA deemed expense.
DEDUCTION 3:  Health Insurance for Family — Up to ₹75,000 Total Under Section 80D
Doctors are typically knowledgeable about health insurance — but they frequently under-claim under Section 80D. Premiums for self, spouse, and children (up to ₹25,000) plus premiums for parents (up to ₹25,000, or ₹50,000 if parents are senior citizens) can be deducted. Add ₹5,000 for preventive health check-ups. Total potential deduction: ₹75,000 for a doctor with senior citizen parents — saving ₹22,500 in tax at the 30% slab.
DEDUCTION 4:  Home Loan Interest on Clinic Property — Section 24(b)
Doctors who have taken home loans to purchase or construct clinic premises can claim interest paid as a deduction under Section 24(b) — up to ₹2 lakh per year for self-occupied property under the Old Regime, with no cap for let-out or commercial property. This is particularly relevant for Delhi NCR doctors who own their clinic space, given Delhi’s high property values and correspondingly large loan interest outflows.
DEDUCTION 5:  Professional Subscriptions, Journals, and Continuous Medical Education (CME)
For doctors who maintain full books of accounts (i.e., those opting out of 44ADA), professional expenses are fully deductible from taxable income. This includes medical journal subscriptions, conference registration fees, CME programme fees, professional body memberships (IMA, specialty associations), and medical textbooks. Many doctors miss these deductions by not maintaining adequate records. At 30% tax rate, ₹2 lakh in professional expenses saves ₹60,000 in tax annually.
DEDUCTION 6:  New Tax Regime Evaluation — Zero Tax Up to ₹12 Lakh
Budget 2025–26 has significantly enhanced the New Tax Regime. For a doctor with net taxable income up to ₹12 lakh (after applying 44ADA's 50% deduction), the tax liability under the New Regime is now ₹0 — thanks to the enhanced Section 87A rebate. For a doctor earning ₹24 lakh gross from practice under 44ADA: taxable income = ₹12 lakh → tax under New Regime = ₹0. Switching to the New Regime may be the single highest-value decision for doctors with gross receipts in the ₹18–28 lakh range.
 
PART 3: Professional Tax in Delhi — Simple but Commonly Missed
Professional Tax (PT) is a state-level levy on professionals and is administered by the Delhi Government for practitioners operating in Delhi NCR. Key points:
•        Professional Tax in Delhi is ₹2,500 per year for individuals earning above ₹12,000 per month
•        All doctors, surgeons, dentists, and healthcare professionals in independent practice in Delhi must register with the Delhi Profession Tax Officer and pay PT annually
•        Clinics and hospitals employing doctors as employees must deduct PT from salaries and deposit it on behalf of employees
•        The ₹2,500 paid as Professional Tax is
•        deductible from gross income under Section 16(iii) of the Income Tax Act — a small but guaranteed deduction.
•        Non-payment attracts a penalty of 2% per month on the outstanding amount
 
PART 4: Should Your Clinic Be a Sole Proprietorship, Partnership, LLP, or Private Limited Company?
One of the most consequential tax decisions a doctor makes is the legal structure of their practice. The choice affects income tax rates, compliance burden, and the ability to bring in co-founders or investors:
Sole Proprietorship / Partnership Firm
•        Simplest structure; income taxed at individual slab rates (up to 30% + surcharge)
•        No separate legal entity; unlimited personal liability for malpractice claims
•        44ADA available for sole proprietors up to ₹75 lakh receipts
•        Ideal for: solo practitioners, small single-specialty clinics
 
LLP (Limited Liability Partnership)
•        Flat 30% tax rate on LLP profits (not individual slabs)
•        Partners can draw remuneration and interest that is deductible from LLP profits
•        Lower personal liability than partnership; separate legal entity
•        Ideal for: multi-doctor practices, diagnostic centres with 2+ partners
 
Private Limited Company
•        Corporate tax rate of 22% (existing companies) or 15% (new manufacturing entities) under Section 115BAA/115BAB
•        Ability to raise investment, issue ESOPs to staff, and build institutional credibility
•        Highest compliance burden: mandatory audit, ROC filings, board meetings
•        Ideal for: multi-specialty hospital chains, telemedicine platforms, health-tech startups
 
“We have seen doctors spend decades as sole proprietors paying 30% tax on income that, if properly structured through an LLP with partner remuneration provisions, would have attracted an effective rate of 18–22%. The legal structure of your practice is a tax decision, not just an administrative one. And it should be revisited every 3–5 years as your income and practice scale.”
— CA Manish Mishra, Partner, B M C & Associates
Complete Compliance Calendar for Delhi Doctors — FY 2025–26
The following calendar covers every GST, income tax, professional tax, and other compliance deadline relevant to independent medical practitioners and clinic owners in Delhi NCR:
 
Month
Compliance Obligation
Form / Portal
Applicable To
April
TDS deducted on salaries/vendor payments for Mar — deposit
ITNS 281 Challan
Clinics with staff or vendor payments
April 15
Advance Tax — 1st instalment (15%)
Income Tax portal
Doctors with liability >₹10,000
May 10
Professional Tax return (Delhi)
Delhi Govt portal
All registered professionals
May 31
TDS Return Q4 (Jan–Mar)
Form 24Q/26Q
Clinics deducting TDS on salaries/fees
June 15
Advance Tax — 2nd instalment (45%)
Income Tax portal
All doctors with advance tax liability
July 15
FLA Return (if foreign investment received)
RBI FLAIR portal
Clinic companies with FDI
July 31
Income Tax Return — FY 2025–26
ITR-3 / ITR-4 (44ADA)
All doctors with Indian income
September 15
Advance Tax — 3rd instalment (75%)
Income Tax portal
All doctors
September 30
Tax Audit completion (if applicable)
CA Certificate
Doctors with receipts >₹75L under 44ADA
October 31
ITR with Tax Audit — extended deadline
Income Tax portal
Audit cases only
November 30
TDS Return Q2 (Jul–Sep)
Form 24Q/26Q
Clinics deducting TDS
December 15
Advance Tax — 4th instalment (100%)
Income Tax portal
All doctors
December 31
GSTR-9 Annual Return (if GST registered)
GST portal
Clinics with taxable turnover >₹2 crore
Monthly (20th)
GSTR-3B (if GST registered for taxable services)
GST portal
Doctors with taxable services
Monthly (11th)
GSTR-1 (if GST registered)
GST portal
Doctors with taxable services
Monthly (7th)
TDS / TCS deposit for previous month
ITNS 281 Challan
All clinics with staff/vendor payments

 
Quick Reference: Income Tax Deductions & Provisions for Doctors (FY 2025–26)
 
Income / Deduction
Section
Limit / Rate
Key Note for Doctors
Presumptive tax — solo practice income
44ADA
50% deemed profit of gross receipts up to ₹75L
No books of accounts required if opted; no audit needed
Regular business income (above ₹75L)
44AB
Actual profit; mandatory audit
Must maintain full books; TDS deducted from fees applies
Professional tax deduction (Delhi)
—
₹2,500/year
State-level; deductible from gross income
Section 80C (LIC, PPF, ELSS etc.)
80C
Up to ₹1.5 lakh/year
Available under Old Regime only
NPS Contribution — Employee
80CCD(1)
Up to 10% of income (within 80C limit)
Old Regime benefit
NPS Contribution — Additional
80CCD(1B)
Additional ₹50,000/year
Over and above 80C limit — high value for doctors
Health Insurance Premium (self+family)
80D
Up to ₹25,000 (₹50,000 for senior citizen)
Also covers preventive health check-up ₹5,000
Home Loan Interest
24(b)
Up to ₹2 lakh/year (self-occupied)
Old Regime; critical for clinic property owners
Depreciation on clinic equipment/assets
32
15%–40% per asset type
Available even under presumptive scheme on personal assets
Deduction for disabled dependant
80DD
₹75,000 (₹1.25L for severe disability)
Old Regime
Interest on education loan
80E
Full interest deduction, no cap
For own or spouse/children higher education loans
New Tax Regime — Zero tax slab
87A
Up to ₹12 lakh net income
Budget 2025–26; no deductions except NPS 80CCD(2)
TDS on professional fees received
194J
10% on fees above ₹30,000/year
Hospitals deduct TDS; doctors must reconcile with Form 26AS
Advance Tax obligation
234B/234C
If tax liability >₹10,000
Even under 44ADA, advance tax must be paid quarterly

 
How B M C & Associates Serves Delhi’s Healthcare Community
B M C & Associates has a dedicated healthcare sector practice that serves a wide range of medical professionals in Delhi NCR:
Services for Individual Doctors & Consultants
•        Section 44ADA vs regular taxation evaluation and election
•        Annual ITR filing (ITR-3 or ITR-4) with full deduction optimisation
•        TDS reconciliation from multiple hospitals and diagnostic centres via Form 26AS and AIS
•        Advance Tax computation and quarterly payment scheduling
•        New vs Old Tax Regime comparison and switching advisory
•        Professional Tax registration and annual payment for Delhi practitioners
 
Services for Clinics, Nursing Homes & Multi-Specialty Practices
•        GST registration (when required for taxable services) and monthly return filing
•        GST rate classification advisory for all services offered — exempt vs taxable determination
•        ITC apportionment for clinics offering both exempt and taxable services
•        Monthly TDS computation, deduction, deposit, and quarterly return filing for clinic staff
•        Payroll processing for medical and administrative staff — PF, ESI, professional tax
•        Statutory audit, ROC compliance for clinic companies
 
Services for Hospital Chains & Healthcare Enterprises
•        Transfer pricing advisory for multi-state hospital group transactions
•        FEMA compliance for clinics receiving foreign investment or with NRI promoters
•        Virtual CFO service for healthcare enterprises requiring ongoing financial leadership
•        GST health-check and notice management for large hospitals
•        ESOP structuring and tax planning for healthcare startups and telemedicine platforms
 
“Healthcare professionals are among our most valued clients, and they deserve advisors who understand the nuances of their field — from the GST treatment of a specific surgical procedure to the tax implications of a hospital room charge that crosses the ₹5,000 threshold by just ₹100. At BMC, we do not give doctors generic compliance advice. We give them the specific, sector-expert guidance that actually makes a difference to their financial health.”
— CA Bipin Kumar Jha, Partner, B M C & Associates
 
About B M C & Associates
B M C & Associates is a full-service Chartered Accountant firm headquartered in Gurugram, with offices serving Delhi, Noida, Dwarka, and Uttam Nagar. With 14+ years of experience and a 90%+ client retention rate, the firm serves medical professionals, clinic owners, hospital administrators, healthcare startups, and telemedicine platforms across Delhi NCR. Led by CA Bipin Kumar Jha, CA Manish Mishra, and CA Saroj Jha, the firm’s healthcare practice combines deep sector knowledge with full-service CA capability — GST advisory, income tax, TDS management, audit, ROC compliance, payroll, and virtual CFO services, all under one roof.
 
🏥  Free Tax Health-Check for Doctors — Book Your 30-Minute Consultation
Are you a doctor, surgeon, or clinic owner in Delhi NCR? Find out in 30 minutes how much tax you are overpaying, which deductions you are missing, and whether your practice structure is optimised for tax efficiency. BMC’s healthcare tax specialists offer a free initial consultation — no obligation, no jargon, just clear and practical advice from CAs who understand medical practice.
Call/WhatsApp: +91-991-084-9998  |  Email: info@bmcassociates.in  |  Visit: www.bmcassociates.in
 
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B M C & Associates
Email: info@bmcassociates.in
Phone: +91-991-084-9998  |  +91-974-887-3205
Website: www.bmcassociates.in
Office: 4th Floor, Blue 1 Square, Udyog Vihar, Sector 18, Gurugram, Haryana — 122015
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