In Ahmed v. Keisler, 504 F.3d 1183 (9th Cir. 2007), the Court reversed the BIAs denial of asylum and withholding of removal where the petitioner had been beaten three times by the Bengali police or army on account of his political opinion. The Court reasoned, physical harm has consistently been treated as persecution. Where an asylum applicant suffers such harm on more than one occasion, and, as in this case, is victimized at different times over a period of years, the cumulative effect of the harms is severe enough that no reasonable fact-finder could conclude that it did not rise to level of persecution. Id. at 1194. In Ahmed, the government did not rebut the presumption of withholding of removal eligibility generated by past persecution. Thus, the Court concluded that the BIAs decision that the petitioner was not entitled to withholding of removal was not supported by substantial evidence. Id. at 1200. In Ahmed, although we reversed the BIAs denial of withholding of removal, we found that substantial evidence did support the BIAs denial of CAT relief. 504 F.3d at 1200-01. The Court reasoned that while the four beatings Ahmed suffered were certainly forms of persecution, it is not clear that these actions would rise to the level of torture under substantial evidence review. Id. at 1201.