KGS

INTEGRITY FIRST

“If you change the way you look at things, the

things you look at will change” -Wayne Dyer

KGS

Cost

S. No. Topic

1.

Bank Audit

2.

Tax Planning in Krishi Kalyan Cess

3.

100% Foreign Direct Investment in E-Commerce

4.

Tax Deducted at source: Amendments FY 2016-17

5.

Tax Alerts Supreme Court rules tips received

INDEX

Bank Audit

This article highlights:

Non-compliances of the terms of

sanction

Key issues in respect of Drawing

Power Statement

Significance of audit accounts in

monitoring credit facility

Significance of consolidation of

accounts of subsidiaries,

associates and joint venture

Some issues observed in few large

borrowers’ accounts

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Bank Audit

Non Compliances of the terms of sanction

While sanctioning the credit facilities, the Bank stipulates many conditions, some of them are very common to all the cases, while few could be specific in a given cases. Some of these are -

Capital contribution of the Promoters

End use of the funds

Further Borrowings need prior approval

Major capital expenditure commitment

Major for Investment in Subsidiary, Associate, Related Parties, directly or indirectly

Share transfer or Pledge, by the Promoters

Update, furnishing of information relating to main Promoters and their direct/or indirect interest in other business

However, quite often it is observed by us, during the course of the audit that monitoring of these conditions is not adequate. Even wherever prior permissions are required, the same is not followed This leads to situation, that the Bank has to deal with the situation thereafter. In fact timely and appropriate corrective steps, in case of serious non-compliance, are essential to ensure that the Banks are not left to watch the situation helpless.

Key issues in respect of Drawing Power Statement

I) In Respect of Debtors

The details of sundry debtors, with full name of the debtors with location are not indicated

The Bill-wise break-up in respect of the debtors, is not available, in the absence of which, no scrutiny is

possible

The advances received from the debtors, have not been linked, separately. A confirmation from the

Company that there are no advances against these debtors is not obtained

The details of debtors, wherever large numbers are involved, must be available in soft copy of the proper

analysis, wherever necessary

The 10 largest parties may be identified and scrutinised with reference to the movement in these balances

The full details of related parties/subsidiary/debtors, with the period they are outstanding, are not

indicated separately and hence these are not excluded from the total debtors, in accordance with the

terms of sanction

II) In Respect of Inventories

The detailed list related to inventory has page-wise totals, nor have the totals been done for the total

inventory. The soft copy or full details, it is not possible to verify the same, easily

In most of the cases no item-wise details (like quantities, unit rate, stock in, stock out, etc.) of each category

of stocks have been submitted by the borrower. In cases only total value of stock category-wise has been

submitted, it is impossible to have any effective check and variation possible

Mode of valuation, i.e. at cost, is not adhered to

There is no confirmation by the company regarding holding any slow moving or non-moving or obsolete

stock in the Stock Statement, which will not to be considered in the calculation of DP

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The Bank has calculated D.P without considering the level of the creditors. In most of the cases, the level of

creditors is not reconciled. With the audited accounts, figures of the creditors, resulting into unpaid stock

hiring finance

(a)The full details of Work in progress (in inventory) including percentage of completion, cost formulas used for

valuation are not provided by the company

(b) Abnormal increase in quantum of Work-in-Progress

Significance of the Audited Accounts in monitoring the credit facility

Issues highlighted in the audit Report such as–

Ability to continue as a going concern

Delay and default in repayment of loan to banks and financial institutions

Delay in depositing statutory dues

Un-provided liabilities

Debt - Equity Ratio, based on the consolidated accounts

Debt-coverage Ratio, current ratio etc

Increase in the current liabilities such as Commercial papers, ECB & debenture etc

Effective capital of the organisation, often taking into A/c

Investment made in partnership, Joint Venture, associate and subsidiary company

Loan & Advances given, to partnership, Joint Venture, associate and subsidiary company, with or without interest

Net working Capital -After taking into account, advance from suppliers, sundry creditors, Bills discounted liabilities, etc

Reduction in Unsecured Loans from the Promoters, as well as other related parties

Bank accounts with the other Bank, without the consent of the Lender Bank

Liabilities - expenses un-provided for

Related party transactions, having impact on the Borrowing from the Bank

Large number of tax matters pending and not provided for, although issues highlighted have been paid

Delay/and default in repayments to Banks & Financial Institutions

The material uncertainty that may cost significant doubts about the company’s ability to continue as a going concern, which is dependent in generating the required funds

% of Interest payment as of Net Sales

Significance of Consolidation of accounts of subsidiaries, associates and Joint Ventures

Attention is invited to the provision of Section 212 of the Companies Act, 1956, which only provided for include certain particulars as its subsidiaries

Audited accounts, including Directors and Auditors Report

A statement of the holding company’s interest in the subsidiary companies as under :-

(i) Extent of holding company’s interest in subsidiary, at the end of the financial year

(ii) Net aggregate amount, so far its concerned members of the holding company, of subsidiary

profit, after deducting its losses or vice versa

(iii) The net aggregate amount of the profit of the subsidiary, after deducting its losses, for the years

as well as earlier years, which has been detailed in the accounts of the holding company

o However, the companies were able to avail exemption by making application to Central Govt

o The said Section 212 of the Companies Act, 1956, has been replaced by Section 129 of the

Companies Act, 2013

The new Section for the First time provided for the consolidation of financial statement of the Company

with all the subsidiaries, in the same form and manner as that of its own

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The ‘subsidiary’ shall also include associate company and joint venture for the purpose of consideration of

the accounts

Prior to this amendment, in case of quoted Company, under the Listing agreement, with the stock

exchanges, the listed companies were only required to prepare consolidated financial statement

The consolidated accounts reflect the true financial position, which enables the banker’s to effectively

monitor the credit facility enjoyed by the Group

Some issues observed in few large borrowers’ accounts

Case I

In respect of D.P. Statement

The D.P. Statement includes, large amount, as stock in trade, without giving any details

Debtors includes huge amount from few debtors, while the borrower, who is manufacturer of

equipment, do not supply capital goods, in question on credit, as a matter of policy

Huge amount of outstanding as debtors from its own foreign subsidiary companies, which are not

even reduced from the Adjusted Net worth of the Company

Huge provision of claims, made in the accounts, has been grouped in the Balance Sheet, under

creditors, not reducing it from the figures of the debtors, resulting into overstatement of debtors as

well as creditors

The Premium on Redemption F.C.C.B. are not being provided, for, as liability, as soon as the decision

is taken to reduce the same. This results into overstatement of the Net worth in this period

Net-worth of the Guarantors, obtained by the Bank is not in prescribed form, giving full details of

assets, its location, etc., in the absence of the details of the companies and entities

All foreign subsidiary companies, Balance Sheet are not in English, as at respective date in accordance

with the law of respective Company along with the audit reports are not available

Case II

Issues arising in the large project executed by EPC contractor being related party

The projects are executed by the E.P.C. Contractors, which are, holding or subsidiary company of the

Borrower Company

This leads to the situation of conflict of interest as well as no distinguishes being made between the

parent company and the EPC Contracting Company, resulting into issues such as project Cost, capital

contribution, effecting diversion of funds, delay in execution of the project leading to project cost-over

etc

In such situation, quite often Bank are ending up, in such high debt - equity ratio, as compared to

what was envisaged at the time of appraisal of the Project

In spite of clear provision in the Companies Act, 2013, where the subsidiary Companies are required

to be consolidated with the holding company, the accounts were not consolidated with the accounts of

holding company; by just give a note in this regard

Case III

Issues related to current Assets

Cash and Bank Balances include Fixed Deposit of a large amount. The same is however pledged with

the Bank for the availment of loan to subsidiary. This has not been appropriately disclosed in the A/c,

by Substantial portion of promoters share are pledge without prior approval and the end use is not

known to the bank

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The figure of the turnover includes the sale of raw material, which inflates the turnover

Raising of commercial paper is not been taking into account in the working capital assessment

High debtors level as compared to turnover

WIP substantially increases continuously for last 5 years

Heavy advances have been given to subsidiary

Case IV

Govt. Company and organisation responsible to procure Agriculture Product on behalf of the Govt.

The audited accounts are not furnished to the Bank, on various pretext, such as accounts have not

been placed, before the Parliament, etc

Since, the sanction of Loan limits, is covered by the Guarantees of the Central Govt. the normal

monitoring of the account is not strictly followed

The sanction of Limits has the condition of furnish the D.P. Statement, based on the stock position at

each month end, while these were received but the same could not/were not verified, since, the stocks

are at number of places and other procedure/volume difficulties

Substantial large variance was noticed in the stock as per balance sheet and DP statement. The

drawing Power, were restricted to DP available, rather than sanctioned limit.

Balance Sheet review, reveals that large amount of claims, stand debited in the A/c’s in the name of

the Central Govt. for many years. Number of these claims remains unconfirmed and unpaid, which

the organisation has not provided for

Once the Balance Sheet is recasted to ascertain effective capital after taking into A/c’s all the relevant

details, it was noticed that the Net Capital is not sufficient to support the working capital margin

required to avail the credit facilities

This article aims to

Understand the applicability and tax planning on KKC

Tax Planning in Krishi

Kalyan Cess

CA Jitin Girdhar & Ankita Jaiswal

Tax Planning In Krishi Kalyan Cess

Introduction:

The finance Minister has burdened the masses with a new cess (Tax) called Krishi Kalyan Cess levied at 0.5 per cent on all taxable services, proceeds of which would be exclusively used for financing initiatives relating to improvement of agriculture and welfare of farmers. The impact of KKC on various services and the economy, Make in India Program and initiative of ease of doing business.

Krishi Kalyan Cess- Imposition:

Levy of Cess seems to be contradictory to the overall vision of GST. With the applicability of GST, all indirect taxes shall be subsumed with an attempt to establish uniformity in structure and reducecascadingeffect of taxes.

The entire change of heart of Government can be seen from the Finance Minister’s Budget Speech 2016-17

“My direct tax proposals would result in revenue loss of ` 1,060 crore and my indirect proposals areexpected to yield `20,670 crores. Thus the net impact of all tax proposals would be revenue gain of`19,610 crores”

The increase in projected service tax collections can be seen as:

Budget 2015-16 (in Crores)

Revised Budget 2016-17 (in crores)

SERVICE TAX Collections 2,05,080 2,16,000Education Cess 786 –Secondary & Higher Education Cess 384 –

Swachh Bharat Cess 3,750 10,000Krishi Kalyan Cess – 5,000Total Service Tax 2,10,000 2,31,000

Applicability Of KKC- 01st June, 2016

S.No.

Time of issuance as well as amount of Invoice

Time of receipt as well as amount of payment received

Position of Taxablity

1 28.5.2016 for Rs 5,00,000 29.5.2016 for Rs 5,00,000 Non Taxable as issue of invoice and receipt of payment before 1 st June 2016

2. 28.5.2016 for Rs 5,00,000 29.5.2016 for Rs 4,00,000 Non Taxable to the extent of 4,00,000 because only part payment has been received for the same before the date of taxability ofservice or new levy. The Balance Rs1 Lac, if paid after 31.5.16 will be subject to KKC

3. 4.6.2016 for Rs 5,00,000 29.5.2016 for Rs 5,00,000 Non Taxable as receipt of payment before 1 st June 2016 while invoice issued within 14 days from taxability of service.

4. 20.6.2016 for Rs 2,50,000 24.5.2016 for Rs 2,50,000 Taxable as essential requirement of issue of invoice within 14 days from the date of service is not met.

KKC- Planning:

a) Incremental 0.5% can make significant difference to the financials of a company .Accordingly it should raise the Invoice and make attempt to receive the payments before 31st May 2016. Company should improve Debt collection period by expediting the entire machinery.

b) Company should also prefer to clear the current liability (creditor Balance) in order to reduce the burden of additional cess. Company should settle the liability before 1st June so that KKC doesn’t result in additional cash outflow.

Impact Of KKC:

a) Make in India-

KKC doesn’t augurs well for Make in India vision. The manufacturers paying Krishi Kalyan Cess on their input services would not be in a position to avail Cenvat credit of the same and thus would form part of their cost, leading to increase in prices to that extent.

b) Overall Economy-

Measures like KKC are inflationary in nature. It will lead to spike in the cost of services. Consumption of various services would be badly affected. Thereby resulting in downward spirals, whichin turn will affect the job market and GDP of the country.

Conclusion:

As a whole, rationale of KKC is very noble with an intent to improve overall agrarian economy, whichcontributes around 16% of our GDP. Government needs to play a balancing act.

Government needs to provide enough impetus to projects like Make in India, Startup India and ease ofdoing Business. Otherwise it shall appear to be marketing gimmick thereby exposing us before the world.

100% Foreign Direct

Investment in

E-Commerce

This article aims at:

Highlighting the key features in B2C e-

Commerce

Examining conditions permitting FDI

Tayyab Ali & Shweta Tripathi

KGS

100% Foreign Direct Investment in e-Commerce

On Tuesday, March 29, 2016, a major development took place

regarding the Foreign Direct Investment (FDI) policy and the e-commerce sector

in India. The Government has permitted 100% FDI in the market-place

format of e-commerce retailing through the automatic route in an

attempt to increase foreign investment in the e-commerce sector.

The clarification came in the form of a press note titled 'Guidelines for

Foreign Direct Investment (FDI) on E-Commerce' issued by the Department of Industrial Policy and

Promotion (DIPP) on FDI in online retail models to support the aforementioned move of the Government. This is a

much welcome move as it would encourage foreign investment and foreign exchange inflows and act as a catalyst in

the growth journey of the nation.

100% FDI under the automatic route is only permitted in the market-place model of e-commerce and

not yet in the inventory-based model of e-commerce

No FDI would be permitted for any company that is engaged in multi-branding retail in the e-

commerce sector. As per the Consolidated FDI Policy Circular 2015 (FDI Policy) released by the DIPP earlier, 100%

FDI was allowed only in the business-to-business (B2B) model and not the business-to-consumer (B2C) model or

retail trading through the automatic route.

FDI permitted in following circumstances :

The Government's latest move removed the barrier on 100% FDI in e-commerce retail trading/B2C model in

the following cases:

Where a manufacturer sells its products manufactured in

India through e-commerce retail.

Where a single brand retail trading entity, operating via brick

and mortar stores, undertakes retail trading through e-

commerce.

Where an Indian manufacturer sells its own single brand

products through e-commerce retail. Here, it was clarified that

an Indian manufacturer would be the investee company that is

the owner of the Indian brand and manufactures in India a

minimum of 70% of its products in-house and sources a maximum of 30% from Indian

manufacturers.

Definitions:

E-Commerce - The buying and selling of goods and services including digital products over

a digital and electronic network.

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Inventory-Based Model of E-Commerce - An e-commerce activity where the inventory

of goods and services is owned by an e-commerce entity and is sold to consumers directly.

Market-Place Model of E-Commerce - The providing of an IT platform by an ecommerce

entity on a digital and electronic network to act as a facilitator between buyers and sellers. A

market-place entity will be permitted to enter into transactions with sellers that are registered

on its platform on a business-to-business basis, the DIPP added.

Other conditions:

The DIPP came up with a few conditions as well which are as follows:

Digital and electronic networks will include all networks of computers, TV channels and internet

applications used in an automated manner like web pages, mobiles etc.

Market-place e-commerce entity will be permitted to enter into transactions only with sellers

registered on its platform on a B2B basis.

E-commerce market-place will cover areas like support services to sellers regarding warehousing,

logistics, order fulfillment, call center services, payment collections etc.

E-commerce entity providing a market-place will not exercise ownership over the inventory (goods

purported to be sold). An ownership of the inventory will convert the business into an inventory-

based model.

E-commerce entities will not be permitted to sell more than 25% of the sales made through its

market-place from one vendor or their group companies.

For goods and services being made available for sale electronically on websites in a market-place

model, the name, address and contact details of the seller will have to be provided. Delivery of goods

to customers, post-sales and customer satisfaction will be the responsibility of the seller itself.

The payments received for sales in the market-place model, payments for sale will be facilitated by the

e-commerce entity conforming with the guidelines of the Reserve Bank of India.

Any warrantee or guarantee of the goods and services sold in the market-place model will be the

responsibility of the seller.

E-commerce entities providing a market-place will not directly or indirectly influence the sale price of

goods or services and will have to maintain a level playing field.

Tax Deducted at

Source: Amendments

FY 2016-17

This article highlights

Increase in threshold limit of TDS

Revision of rates

Change in Due dates of filing quarterly returns

Procedure of e-filing of return

CA Puneet Mehra & Shraddha Sharda

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Tax Deducted at Source (TDS): Amendments FY 2016-17

IntroductionUnder the scheme of deduction of tax at source as provided in the Act, every person responsible for payment of any specified sum to any person is required to deduct tax at source at the prescribed rate and deposit it with the Central Government within specified time. However, no deduction is required to be made if the payments do not exceed prescribed threshold limit. In order to rationalise the rates and base for TDS provisions, the existing threshold limit for deduction of tax at source and the rates of deduction of tax at source are proposed to be revised w.e.f. 01.06.2016.

Increase in threshold limit of TDS on various payments mentioned in the relevant sections of the Act

Present Section

Heads Existing Threshold Limit (Rs.)

Proposed Threshold Limit (Rs.)

192A Payment of EPF due to an employee

30,000 50,000

194BB Winnings from Horse Race 5,000 10,000

194C Payments to Contractors Aggregate annual limit of 75,000

Aggregate annual limit of 1,00,000

194D Insurance commission 20,000 15,000

194G Commission on sale of lottery tickets

1,000 15,000

194H Commission or brokerage 5,000 15,000

194LA Payment of Compensation on acquisition of certain Immovable

2,00,000 2,50,000

Revision in rates of TDS on various payments mentioned in the relevant sections of the Act

Present Section

Heads Existing Rate of TDS (%)

Proposed Rate of TDS (%)

192DA Payment in respect of Life Insurance Policy

2% 1%

194EE Payments in respect of NSS Deposits

20% 10%

194D Insurance commission 10% 5%

194G Commission on sale of lottery tickets

10% 5%

194H Commission or brokerage 10% 5%

Other Amendments

∑ Section 194K (Income in respect of Units) and Section 194L (Payment of Compensation on acquisition of Capital Asset) - Proposed to be omitted w.e.f. 1st June 2016.

∑ New Section 194LBC has been inserted, where any income is payable to an investor, being a resident, in respect of an investment in a securitisation trust, TDS will be deducted

o If an individual or any Hindu undivided family pay any income applied rate will be 25%.

o TDS rate will applied 30% in case of any other person.

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Change in due date of Filling Quarterly TDS Returns

Sub Rule 2 of Rule 31A of Income Tax Rules specifies the due date for filing of

∑ Statement of deduction of tax under section 192 in Form No. 24Q;∑ Statement of deduction of tax under sections 193 to 196D in—

(i) Form No. 27Q in respect of the deductee who is a non-resident not being a company or a foreign company or resident but not ordinarily resident; and

(ii) Form No. 26Q in respect of all other deductees.

The Due date as per rule are different for Government deductors and non-Government deductors. To bring uniformity and to give deductors sufficient time in filing of TDS Statement CBDT has vide Notification No. 30/2016 dated: 29.04.2016 has revised due date for filing TDS statements for Government and non-government deductors w.e.f 01.06.2016 to as follows :-

Date of ending of quarter

Due date for Government Deductors

Due date for non-Government Deductors

Due date wef 01.06.2016 for Govt. and Non-Govt. Deductors

30th June 31st July of the financial year

15th July of the financial year

31st July of the financial year

30th September 31st October of the financial year

15th October of the financial year

31st October of the financial year

31st December 31st January of the financial year

15th January of the financial year

31st January of the financial year

31st March 15th May of the financial year immediately following the financial year in which the deduction is made

15th May of the financial year immediately following the financial year in which the deduction is made

31st May of the financial year immediately following the financial year in which the deduction is made

Procedure for e-filling of TDS Returns w.e.f 01.05.2016

With effect from 01.05.2016 e-TDS quarterly statements/returns shall not be e-filed or uploaded at TIN NSDL website. However they shall be uploaded at TRACES TDSCPC website.

Pre-Requisites for Uploading TDS StatementTo upload TDS, user should hold valid TAN and should be registered in e-Filing. Statement should be prepared using the Return Preparation Utility (RPU) and validated using the File Validation Utility (FVU). The utilities can be downloaded from tin-nsdl website (https://www.tin-nsdl.com/). Valid DSC should be registered in e-Filing.

Upload TDS/TCS StatementTo Upload TDS, the steps are as below:

Step 1: In e-Filing Homepage, Login using ID (TAN), Password, and Captcha.Step 2: Post login, go to TDS, Upload TDS.Step 3: In the form provided, select the appropriate statement details from the drop down boxes for:

- FVU Version - Assessment Year - Form Name - Quarter

Step 5: Click Validate to Validate Statement details.Step 6: “Upload TDS ZIP file”: Upload the TDS/TCS statement (Prepared using the utility downloaded from tin-NSDL Website) Step 7: “Attach the Signature file” Upload the signature file generated using DSC Management Utility for

the uploaded TDS ZIP file. Step 8: Click on “Upload” button.

Note: TDS can be uploaded from Assessment Year 2011-12. Only Regular Statements can be uploaded, the Correction statement can be uploaded only through tin-nsdl portal.

This article aims to

Tax Issue on tips received by waiter

from customers

Tax payer’s contentions on this

issue

Tax Authority contentions on this

issue

Supreme court rulings over this

issues

Tax Alerts Supreme

Court rules tips received

by waiters from

customers is not salary

income

Tax Alerts Supreme Court rules tips received by waiters from customers is not salary income

Background and facts

Section 15 of the Indian Tax Laws (ITL) includes the following incomes as chargeable to tax under the head “Income from Salary” (Salary head):

Salary that is “due” from an employer or a former employer, whether paid or not Salary that is “paid or allowed” to an employee by or on behalf of an employer or a former

employer, though not due or before it becomes due Any “arrears of salary” paid or allowed to an employee by or on behalf of an employer or a

former employer, if not earlier charged to income tax

The Taxpayer was engaged in the business of owning, operating and managing hotels. The Tax Authority discovered, in a survey action on the Taxpayer, that the Taxpayer was not withholding tax on distribution of tips received from customers through credit cards.

The Tax Authority took the position that such tips constituted salary income of the waiters and the Taxpayer had an obligation to withhold tax thereon. The Tax Authority treated the Taxpayer as assessee-in-default and sought to recover the shortfall of tax, with interest. Furthermore, it also levied a penalty on the Taxpayer for not withholding tax.

Issues before the Supreme Court

Whether tips received by waiters from customers constitute “Salary Income” or “Income fromOther Sources” in their hands

Whether the employer has withholding obligation on tips received from customers through credit cards and, subsequently, disbursed to waiters

Taxpayer’s contentions

Salary taxation is attracted only if payment is received from employer under a contract of employment, pursuant to which, the employee has a legal right to claim such amount from the employer

Tips are received by waiters directly from customers out of their own volition for the quality of service provided to them and for courteous behaviour. The waiters, as employees, have no legal right to claim the same from the employer

Tax Authority’s contentions

Tips received from customers constitute salary income of the waiters as “profits in lieu of salary”. The Taxpayer may not have a withholding obligation on tips received directly from customers by the waiters. However, the Taxpayer, as an employer, has a withholding obligation on tips collected from customers on credit cards and paid to the waiters.

SC’s Ruling

The SC ruled in favour of the Taxpayer and held that the Taxpayer was not liable to withhold tax, sincetips received by the employees do not constitute salary income. Consequently, the Taxpayer cannot be treated as assessee in-default and thereby no interest can be levied for non-withholding of tax. The SC adopted the following reasoning for its conclusion:

Salary withholding obligation is on “any person responsible” for paying salary to employees which, in the context of salary income, is the employer

In the present case, tips are received from customers and not the employer. There is no dispute that such tips constitute taxable income of the employees. The dispute is on the head of income, whether “Salary Income” or “Income from Other Sources”. If it is not taxable as salary, the employer has no withholding obligation

Based on an analysis of the provisions dealing with salary income taxation, it is clear that payment received from an employer (whether current or former), under a contract of employment, alone is taxable as salary. Furthermore, there should be vested right in the employee to claim such payment from the employer. Reliance was placed in this regard on an SC ruling in the case of CIT v. L.W. Russel, which held that although the term “allowed” has a wide meaning, it cannot be said that the employer has “allowed” a perquisite to an employee if the employee has no legal right to the same. In other words, it cannot apply to contingent payments to which an employee has no vested right till the contingency occurs. Tips, being purely voluntary in nature and paid by customers on their volition, theemployee does not have the right to claim the same from the employer.

KGS

Contact Name E-mail Mobile Mr. Anuj Somani anujsomani@kgsomani.com +91 9871098777 Mr. Bhuvnesh Maheshwari bhuvneshmaheshwari@kgsomani.com +91 9810031993

Head office: Branch Offices: Network Offices: DELHI MUMBAI BANGALORE

Delite Cinema Hall GHAZIABAD BHOPAL 3rd Floor, Gate No. 2, New Delhi, India GURGAON BUBNESHWAR

SILIGURI CHENNAI

CHENNAI KOLKATA

Disclaimer

• This material and the information contained herein prepared by the authors is of a general nature and does not exhaustively deal with the subject discussed. • Although the authors have put their earnest effort in providing accurate and appropriate information, the article is not intended to be relied upon as the sole basis for any decision which may affect you or your business. The authors recommend you take professional advice before acting on specific issues. • KGS is neither responsible for any views, opinions and statements made by the authors nor is liable for consequences, if any, arising from actions based on such views or opinion.

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