strategic indirect tax management
Post on 20-Oct-2014
2.011 views
DESCRIPTION
Indirect Tax for Decision Makers, at Strategic Level and Business LevelTRANSCRIPT
![Page 1: Strategic Indirect Tax Management](https://reader033.vdocument.in/reader033/viewer/2022061106/5444ffa3afaf9fe32b8b4634/html5/thumbnails/1.jpg)
INDIRECT TAXES FOR DECISION MAKING
Strategic Indirect Tax Management
By CA Abdur Rahman Musba
May 2011
![Page 2: Strategic Indirect Tax Management](https://reader033.vdocument.in/reader033/viewer/2022061106/5444ffa3afaf9fe32b8b4634/html5/thumbnails/2.jpg)
Disclaimer
� This Presentation is only to provide various conceptualclarity of Indirect Tax Planning and Decision Making
� All the facts, case studies and information presented shouldbe crossed checked with the provisions of law, includingany notifications, exemptions, circulars, judgement,
CA Abdur Rahman Musba
any notifications, exemptions, circulars, judgement,clarifications and amendments
� The position stated herein may vastly differ from actualinterpretation by experts and vary from establishedindustry practices
� The Presenter shall have no liability for the accuracy ofinformation or the correct interpretation of law
![Page 3: Strategic Indirect Tax Management](https://reader033.vdocument.in/reader033/viewer/2022061106/5444ffa3afaf9fe32b8b4634/html5/thumbnails/3.jpg)
Factors Affecting Decision Making
� Tax - whether Creditable or Not
� Nature of Business
� Input
� Output
CA Abdur Rahman Musba
� Output
� Seller
� Buyer
� Value Addition & Value Chain
� Location
� Concessions and Schemes
![Page 4: Strategic Indirect Tax Management](https://reader033.vdocument.in/reader033/viewer/2022061106/5444ffa3afaf9fe32b8b4634/html5/thumbnails/4.jpg)
Nature of Taxes
� Central Excise� Basic Excise Duty - Creditable
� Education Cess - Creditable
� Custom Duty� Basic Custom Duty – Not Creditable
Education Cess on Custom - Not Creditable
CA Abdur Rahman Musba
� Education Cess on Custom - Not Creditable
� Countervailing Duty (Excise Duty) - Creditable
� Education Cess on Countervailing Duty – Creditable
� Special Additional Duty – Creditable
� Service Tax� Service Tax – Creditable
� Education Cess – Creditable
![Page 5: Strategic Indirect Tax Management](https://reader033.vdocument.in/reader033/viewer/2022061106/5444ffa3afaf9fe32b8b4634/html5/thumbnails/5.jpg)
Nature of Taxes
� Central Sale Tax – Not Creditable
� Sale Tax – Not Creditable
� Value Added Tax –Creditable
� Electricity Duty – Not Creditable
CA Abdur Rahman Musba
� Electricity Duty – Not Creditable
� Entry Tax – Not Creditable
� State Excise – Not Creditable
� Royalty (on mined products) – Not Creditable
� Stamp Duty – Not Creditable
� Various Other Cess and Taxes
![Page 6: Strategic Indirect Tax Management](https://reader033.vdocument.in/reader033/viewer/2022061106/5444ffa3afaf9fe32b8b4634/html5/thumbnails/6.jpg)
Nature of Business
� A Service Provider cannot avail credit of VAT andSpecial Additional Duty of Customs
� A Non-Excise Registered Dealer cannot avail Creditof Service Tax and Central Excise.
In case of lease of Tangible Goods, VAT is attracted if
CA Abdur Rahman Musba
� In case of lease of Tangible Goods, VAT is attracted ifcontrol is given to the lessee and Service Tax isattracted if control is not given to lessee.Accordingly, credit can be availed.
![Page 7: Strategic Indirect Tax Management](https://reader033.vdocument.in/reader033/viewer/2022061106/5444ffa3afaf9fe32b8b4634/html5/thumbnails/7.jpg)
Input and Output
� Restriction on taking Credit on certain input
� No Input Credit under Central Excise for Petrol & Diesel
� Certain Input not taxable
� No Excise Duty on Vegetables
Certain Output is Exempted or Non Taxable
CA Abdur Rahman Musba
� Certain Output is Exempted or Non Taxable
![Page 8: Strategic Indirect Tax Management](https://reader033.vdocument.in/reader033/viewer/2022061106/5444ffa3afaf9fe32b8b4634/html5/thumbnails/8.jpg)
Seller & Buyer
� Seller Exemption from Tax
� SSI under Central Excise
� Buyer cannot avail credit
� Final Consumers cannot take credit, but can claim refund on wrong claims
CA Abdur Rahman Musba
wrong claims
![Page 9: Strategic Indirect Tax Management](https://reader033.vdocument.in/reader033/viewer/2022061106/5444ffa3afaf9fe32b8b4634/html5/thumbnails/9.jpg)
Value Addition & Value Chain
� If Value Additions is low, it is better to avail fullcredit, as compared to concessional scheme, if optionexists� For By-Cycle manufacturers, when excisable components areout-sourced, it is better to pay output Excise duty @ 5% afteravailing Cenvat Credit rather than pay 1% without availing
CA Abdur Rahman Musba
availing Cenvat Credit rather than pay 1% without availingCenvat Credit
� Ensure that the entire value chain takes the benefitsof the Credit System� In a value chain, if one of the supplier is Non-ExciseDealer/SSI unit claiming Excise Exemption; the input ExciseDuty for that supplier would be a cost in the system
![Page 10: Strategic Indirect Tax Management](https://reader033.vdocument.in/reader033/viewer/2022061106/5444ffa3afaf9fe32b8b4634/html5/thumbnails/10.jpg)
Location
� If the supplier is outside the State, CST is a cost
� If the supplier is Foreign Country or SEZ unit,custom duty is Cost
� If the manufacturer is in Excise Exempted Area,input Central Excise is a cost and there is no output
CA Abdur Rahman Musba
input Central Excise is a cost and there is no outputExcise Duty
![Page 11: Strategic Indirect Tax Management](https://reader033.vdocument.in/reader033/viewer/2022061106/5444ffa3afaf9fe32b8b4634/html5/thumbnails/11.jpg)
Concessions & Schemes
� Lesser Rate of CST for purchases against Form C
� Concessional Custom Duty under Project Imports
� Various Schemes under Foreign Trade Policy
� Advance licence, Export Promotion Capital Goods Scheme(EPCG)
CA Abdur Rahman Musba
(EPCG)
![Page 12: Strategic Indirect Tax Management](https://reader033.vdocument.in/reader033/viewer/2022061106/5444ffa3afaf9fe32b8b4634/html5/thumbnails/12.jpg)
Formalities
� Registration
� Under CST, exemption is available for goods mentioned in theregistration certificate
� Credit/Exemption available only based on properDocumentations
CA Abdur Rahman Musba
Documentations
![Page 13: Strategic Indirect Tax Management](https://reader033.vdocument.in/reader033/viewer/2022061106/5444ffa3afaf9fe32b8b4634/html5/thumbnails/13.jpg)
Detailed Discussions
CA Abdur Rahman Musba
![Page 14: Strategic Indirect Tax Management](https://reader033.vdocument.in/reader033/viewer/2022061106/5444ffa3afaf9fe32b8b4634/html5/thumbnails/14.jpg)
Structure of the Presentation
� Service Tax
� Exemption
� VAT/Sales Tax/CST
�High Seas Sales
� Works Contract Tax (Service Tax and VAT)
CA Abdur Rahman Musba
Works Contract Tax (Service Tax and VAT)
� Central Excise
� Exemption under Central Excise
� Inputs and Capital Goods
� Reversal of Cenvat Credit
� Outsourcing Decision
� Formalities
� Case Studies
![Page 15: Strategic Indirect Tax Management](https://reader033.vdocument.in/reader033/viewer/2022061106/5444ffa3afaf9fe32b8b4634/html5/thumbnails/15.jpg)
Structure of the Presentation (Contd)
� Contracts – Capital Expenditure – Tax Liability
� Custom Duty
� Concession of Custom Duty
� Benefits under Foreign Trade Policy
Fiscal benefits for Specific Projects
CA Abdur Rahman Musba
� Fiscal benefits for Specific Projects
� Tips for Better Compliance – Strategic Level
![Page 16: Strategic Indirect Tax Management](https://reader033.vdocument.in/reader033/viewer/2022061106/5444ffa3afaf9fe32b8b4634/html5/thumbnails/16.jpg)
Service Tax
CA Abdur Rahman Musba
![Page 17: Strategic Indirect Tax Management](https://reader033.vdocument.in/reader033/viewer/2022061106/5444ffa3afaf9fe32b8b4634/html5/thumbnails/17.jpg)
Service Tax
� Service Tax and Education Cess is creditable.
� However, when abatement is availed; Credit is notavailable
� Restriction of Credit on Composite Scheme
CA Abdur Rahman Musba
� Credit interchangeable with Central Excise to someextent.
� Restriction of Credit on certain industries likeBanking
![Page 18: Strategic Indirect Tax Management](https://reader033.vdocument.in/reader033/viewer/2022061106/5444ffa3afaf9fe32b8b4634/html5/thumbnails/18.jpg)
Some Exemption under Service Tax
� Statutory Activities
� For Taxable Service Up to Rs. 10 lakhs
� Services to SEZ Developers and Units (Cenvat Creditneeds not be reversed)
� Exports of Services
CA Abdur Rahman Musba
� Exports of Services
� Refund of Service Tax for Exporter of Goods andExemption on Reverse Charge Basis (for GTA andForeign Commission agent)
� Services to UN and International Agencies, foreigndiplomatic missions
![Page 19: Strategic Indirect Tax Management](https://reader033.vdocument.in/reader033/viewer/2022061106/5444ffa3afaf9fe32b8b4634/html5/thumbnails/19.jpg)
Some Exemption under Service Tax
� Service Provided in Jammu & Kashmir
� Service Provided to EOU not exempted. EOU canclaim rebate under Cenvat Credit Rules
� For Construction of Roads, Airports, Railways,Transport Terminals Bridges, Tunnels, Dams;
CA Abdur Rahman Musba
Transport Terminals Bridges, Tunnels, Dams;Service Tax is exempted
![Page 20: Strategic Indirect Tax Management](https://reader033.vdocument.in/reader033/viewer/2022061106/5444ffa3afaf9fe32b8b4634/html5/thumbnails/20.jpg)
Cenvat Credit
� Cenvat Credit available on
� Inputs
� Inputs Service
� Capital Goods
� More Discussions under Central Excise
CA Abdur Rahman Musba
� More Discussions under Central Excise
![Page 21: Strategic Indirect Tax Management](https://reader033.vdocument.in/reader033/viewer/2022061106/5444ffa3afaf9fe32b8b4634/html5/thumbnails/21.jpg)
Formalities
� Registration of each office and premise on whichInvoices are raised by the Service Provider
� Registration of each office and premises, on whichinvoices are raised on the Service Recipient to claiminput credit/Service Tax exemption
CA Abdur Rahman Musba
input credit/Service Tax exemption
� Central Registration possible
![Page 22: Strategic Indirect Tax Management](https://reader033.vdocument.in/reader033/viewer/2022061106/5444ffa3afaf9fe32b8b4634/html5/thumbnails/22.jpg)
Sales Tax/VAT
CA Abdur Rahman Musba
![Page 23: Strategic Indirect Tax Management](https://reader033.vdocument.in/reader033/viewer/2022061106/5444ffa3afaf9fe32b8b4634/html5/thumbnails/23.jpg)
Central Sales Tax/Value Added Tax/Sales Taxes
� Central Sales Tax is not Creditable
� State Sales Tax not Creditable. Covers items like Petrol, Diesel and ATF
� Value Added Tax is Creditable
CA Abdur Rahman Musba
� VAT under Composition Scheme – Not Creditable
![Page 24: Strategic Indirect Tax Management](https://reader033.vdocument.in/reader033/viewer/2022061106/5444ffa3afaf9fe32b8b4634/html5/thumbnails/24.jpg)
Concession under CST
� Sale to a Registered Dealer
� Stock Transfer
� Sale to Exporter
� Sale to SEZ Developer/Unit
CA Abdur Rahman Musba
� Sale to SEZ Developer/Unit
� Sale made in course of Inter-State Sales (E1/E2 sales)
![Page 25: Strategic Indirect Tax Management](https://reader033.vdocument.in/reader033/viewer/2022061106/5444ffa3afaf9fe32b8b4634/html5/thumbnails/25.jpg)
Formalities under Sales Tax
� Registration of Goods to be sold for Inter State Sales
� Registration of each place of Sales
� Registration of place for purchase under Inter StateSales
CA Abdur Rahman Musba
![Page 26: Strategic Indirect Tax Management](https://reader033.vdocument.in/reader033/viewer/2022061106/5444ffa3afaf9fe32b8b4634/html5/thumbnails/26.jpg)
Case Study
� A Works Contractor is also a manufacturer of goodswhich is used in works contract
� The manufacturing unit is one state and the workscontracts in another state.
The Manufacturing Unit should be registered under
CA Abdur Rahman Musba
� The Manufacturing Unit should be registered underCST for the sale of goods.
� The works contract site should be registered underCST for purchase of Construction Material
� Goods should be transferred under Form F (StockTransfer)
![Page 27: Strategic Indirect Tax Management](https://reader033.vdocument.in/reader033/viewer/2022061106/5444ffa3afaf9fe32b8b4634/html5/thumbnails/27.jpg)
High Seas Sales
� Sale outside the territory is High Sea Sales
� When Celebrities sell precious stones like Diamonds,they take a flight across the Atlantic to avoid Sale Tax
� These are “High Seas Sales”
� High Seas Sales are made to avoid CST/VAT, in case of
CA Abdur Rahman Musba
� High Seas Sales are made to avoid CST/VAT, in case ofimported Goods.
� Sales should be executed after goods are left the foreigndestination and before arriving in India
� Bill of Lading is a negotiable Document.
� Airway Bill in not negotiable document. Delivery Challanshould be endorsed.
![Page 28: Strategic Indirect Tax Management](https://reader033.vdocument.in/reader033/viewer/2022061106/5444ffa3afaf9fe32b8b4634/html5/thumbnails/28.jpg)
Sales in Course of Imports
� Sales is made after the goods are imported (afterCustoms Formalities is completed before delivery istaken)
� Sales in Course of Import does not attract CST/VAT.
� “High Seas Sales” and “Sales in Course of Imports”option should be decided on case to case to basis
CA Abdur Rahman Musba
“High Seas Sales” and “Sales in Course of Imports”option should be decided on case to case to basis
� Usually, when Custom Duty is wholly exempted, HighSeas Sales is better.
� In case of High Seas Sales, the assessable value forCustoms Duty is the price charged by importer to theassessee.
![Page 29: Strategic Indirect Tax Management](https://reader033.vdocument.in/reader033/viewer/2022061106/5444ffa3afaf9fe32b8b4634/html5/thumbnails/29.jpg)
WORKS CONTRACT ATTRACT BOTH VAT AND SERVICE TAX
Taxation of Works Contract
CA Abdur Rahman Musba
![Page 30: Strategic Indirect Tax Management](https://reader033.vdocument.in/reader033/viewer/2022061106/5444ffa3afaf9fe32b8b4634/html5/thumbnails/30.jpg)
VAT on Works Contract
� Taxation under Vat – Eg Civil Works
Particulars Regular Abatement Composition
Amount on which VAT is
On Material Portion
On 70% (For civil works)
On Full Value
CA Abdur Rahman Musba
which VAT is payable
Portion civil works)
Rate at Which the amount is Taxable
Full Rate Full Rate 4%
Effective Rate Computed 9.8% 4%
Input credit Available Available Not Available
![Page 31: Strategic Indirect Tax Management](https://reader033.vdocument.in/reader033/viewer/2022061106/5444ffa3afaf9fe32b8b4634/html5/thumbnails/31.jpg)
Service Tax on Works Contract
Particulars Full Rate Abatement Composition Scheme
Calculation (as per VAT law)
Amount on which Service Tax is payable
Full Value On 33% of the Value
On Full Value On ServicePortion
Rate at Which Full Rate Full Rate 4.12% Full Rate
CA Abdur Rahman Musba
Rate at Which the amount is Taxable
Full Rate Full Rate 4.12% Full Rate
Effective Rate 10.3% 3.399% 4.12% Computed
Credit on Input Goods
Available Not Available
Not Available Not Available
Credit on Input Service
Available Not Available
Available Available
Credit on Capital Goods
Available Not Available
Available Available
![Page 32: Strategic Indirect Tax Management](https://reader033.vdocument.in/reader033/viewer/2022061106/5444ffa3afaf9fe32b8b4634/html5/thumbnails/32.jpg)
Central Excise
CA Abdur Rahman Musba
![Page 33: Strategic Indirect Tax Management](https://reader033.vdocument.in/reader033/viewer/2022061106/5444ffa3afaf9fe32b8b4634/html5/thumbnails/33.jpg)
Central Excise
� Normally, Central Excise by nature is Creditable
� Credit available for Education Cess
� Credit of Service Tax interchangeable
� Compound Levy Scheme – Credit not available
CA Abdur Rahman Musba
� Compound Levy Scheme – Credit not available
� Restriction of Credit on certain industries like ShipBreaking
![Page 34: Strategic Indirect Tax Management](https://reader033.vdocument.in/reader033/viewer/2022061106/5444ffa3afaf9fe32b8b4634/html5/thumbnails/34.jpg)
Exemption under Central Excise
� Some Exemption of Central Excise
� Power Project
� Water Infrastructure Project
� UN/ADB funded projects
� Project Under International Competitive Bidding
CA Abdur Rahman Musba
� Project Under International Competitive Bidding
� Supply to Defence
� Supply to SEZ, EOU, Exports
� Supply against EPCG Authorisation
� Exemption for SSI units
� Exemption in Excise Free States
� Exemption of products under specific Notification
![Page 35: Strategic Indirect Tax Management](https://reader033.vdocument.in/reader033/viewer/2022061106/5444ffa3afaf9fe32b8b4634/html5/thumbnails/35.jpg)
Case Study – When Located in an Excise Free Zone
� Some states like Himachal Pradesh are exemptedfrom Central Excise?
� Is it beneficial to set up a unit in Himachal Pradesh?
CA Abdur Rahman Musba
![Page 36: Strategic Indirect Tax Management](https://reader033.vdocument.in/reader033/viewer/2022061106/5444ffa3afaf9fe32b8b4634/html5/thumbnails/36.jpg)
Analysis
� Check whether the input are excisable
� Check whether the buyer can claim Credit
� Check the value addition
� Check the place from which input should be procuredand the output shall be distributed
CA Abdur Rahman Musba
and the output shall be distributed
� Example: Food Processing Industry
� The vegetables and fruits does not attract Excise Dutyand the customers cannot avail credit of Excise Duty
� Hence, it is beneficial to set up a food processing unit inExcise Free states
![Page 37: Strategic Indirect Tax Management](https://reader033.vdocument.in/reader033/viewer/2022061106/5444ffa3afaf9fe32b8b4634/html5/thumbnails/37.jpg)
Analysis of Inputs
� Analysis of “Input” under Cenvat Credit Rules isimportant
� Some of the items excluded from Input are
� Inputs used outside the Factory (except certain cases)
Petrol, Diesel excluded from definition of inputs
CA Abdur Rahman Musba
� Petrol, Diesel excluded from definition of inputs
� Inputs used for Civil Works
� Consumption of Employees
![Page 38: Strategic Indirect Tax Management](https://reader033.vdocument.in/reader033/viewer/2022061106/5444ffa3afaf9fe32b8b4634/html5/thumbnails/38.jpg)
Analysis of Input Service
� Similarly, analysis of “Input Service” is critical
� The analysis of Input and Input Service should be seen from specific business point of view.
� Some of the Items exclude are
CA Abdur Rahman Musba
� Service on Civil Works
� Service Tax on Motor Vehicle (like Rent a cab, insurance on cars)
� For Consumption of Employees
![Page 39: Strategic Indirect Tax Management](https://reader033.vdocument.in/reader033/viewer/2022061106/5444ffa3afaf9fe32b8b4634/html5/thumbnails/39.jpg)
Analysis of Capital Goods
� Cenvat Credit on Capital Goods is available forspecified list of Goods
� Cenvat Credit/Exemption not available forconstruction of Civil Works (except for Civil Worksfor SEZ and Service Tax exemption for certain
CA Abdur Rahman Musba
for SEZ and Service Tax exemption for certainInfrastructures)
![Page 40: Strategic Indirect Tax Management](https://reader033.vdocument.in/reader033/viewer/2022061106/5444ffa3afaf9fe32b8b4634/html5/thumbnails/40.jpg)
Analysis of Capital Goods(Contd)
� While analysing use of Cenvat Credit of CapitalGoods, financial modelling should be used toascertained when the Cenvat Credit of Capital Goodscan be fully used.
� For captive intensive industries, interest cost should
CA Abdur Rahman Musba
� For captive intensive industries, interest cost shouldbe added for utilisation of Cenvat Credit of CapitalGoods, if the utilisation of credit is over a longer timevis-à-vis exemption scheme like EOU, SEZ etc (incase of direct comparison)
![Page 41: Strategic Indirect Tax Management](https://reader033.vdocument.in/reader033/viewer/2022061106/5444ffa3afaf9fe32b8b4634/html5/thumbnails/41.jpg)
Case Study on Cenvat Credit on Capital Goods
Thumb Rule for factors considering how fast Cenvat Crediton Capital Goods can be used
� Huge Capital Investment
� Less Value Addition (in terms of Percentage)
� Excisable Input (in case the input is mine products like
CA Abdur Rahman Musba
� Excisable Input (in case the input is mine products likeCrude Oil, Iron Ore, Cenvat credit cannot be availed)
� Rate of Excise Duty of output vis-à-vis the rate of ExciseDuty of input.
Detailed Computations can be done only using financialmodelling
![Page 42: Strategic Indirect Tax Management](https://reader033.vdocument.in/reader033/viewer/2022061106/5444ffa3afaf9fe32b8b4634/html5/thumbnails/42.jpg)
Analysis of Output
� Whether Output is chargeable to Excise
� In case of pure power plant, Electricity is notChargeable to Excise Duty. Therefore, tax on inputbecomes a cost. However, if the power plant is set upas part of existing industrial plant, tax on input can
CA Abdur Rahman Musba
as part of existing industrial plant, tax on input canbe taken as credit.
![Page 43: Strategic Indirect Tax Management](https://reader033.vdocument.in/reader033/viewer/2022061106/5444ffa3afaf9fe32b8b4634/html5/thumbnails/43.jpg)
Cenvat Credit Reversal
� When manufacturer/service provider ismanufacturing/ providing both taxable and nontaxable service/goods, Cenvat Credit have to bereversed.
� In case, the person opts to pay an specified
CA Abdur Rahman Musba
� In case, the person opts to pay an specified“amount”, Cenvat credit need not be reversed
� For supplies to SEZ, EOU, Exports, Projects underCompetitive Bidding, Some Power Projects, CenvatCredit need not be reversed.
![Page 44: Strategic Indirect Tax Management](https://reader033.vdocument.in/reader033/viewer/2022061106/5444ffa3afaf9fe32b8b4634/html5/thumbnails/44.jpg)
Case Study on Reversal
� Pipes are required for Water Project, partly withinSEZ and partly outside SEZ.
� There is Excise Duty exemption for within SEZ andcenvat credit needs not be reversed
For water projects (from Source), pipes are exempted
CA Abdur Rahman Musba
� For water projects (from Source), pipes are exemptedfrom Excise Duty. However, Cenvat Credit have to bereversed.
� How to analysis the impact of Central Excise?
![Page 45: Strategic Indirect Tax Management](https://reader033.vdocument.in/reader033/viewer/2022061106/5444ffa3afaf9fe32b8b4634/html5/thumbnails/45.jpg)
Case Study on Reversal
� Various types of pipes can be procured. Therefore,first check the raw material for the pipemanufacturer
� For Ductile Iron Pipes, the main inputs are Iron Oreand Coal. Both the items are not excisable. (Coal has
CA Abdur Rahman Musba
and Coal. Both the items are not excisable. (Coal hasnow Energy Cess)
� The Price should not vary much due to Cenvat Creditavailability
� However, for other pipes, where input are taxableproducts, the manufacturer would charge 5% more;if detailed calculation or reversal is not made.
![Page 46: Strategic Indirect Tax Management](https://reader033.vdocument.in/reader033/viewer/2022061106/5444ffa3afaf9fe32b8b4634/html5/thumbnails/46.jpg)
Case Study (when Final Product is exempted)
� For Ship Building (and Aircraft Building), Central Excise is exempted.
� Even Custom Duty is exempted for imports of ships
� Therefore, should any tax planning be made in this case?
CA Abdur Rahman Musba
case?
![Page 47: Strategic Indirect Tax Management](https://reader033.vdocument.in/reader033/viewer/2022061106/5444ffa3afaf9fe32b8b4634/html5/thumbnails/47.jpg)
Case Study (when Final Product is exempted) [Contd]
� Shipping Building unit purchase components afterpaying Central Excise/Custom Duty.
� If the Shipyard is located in an EOU (ExportOriented Unit), Central Excise is exempted onpurchase of components.
CA Abdur Rahman Musba
purchase of components.
� Similarly, Custom Duty is exempted for import ofcomponents.
� On Sale in domestic market, there would not beExcise Duty.
� Net Foreign Exchange earning should be satisfied.
![Page 48: Strategic Indirect Tax Management](https://reader033.vdocument.in/reader033/viewer/2022061106/5444ffa3afaf9fe32b8b4634/html5/thumbnails/48.jpg)
Outsourcing Decision and Taxes
CA Abdur Rahman Musba
![Page 49: Strategic Indirect Tax Management](https://reader033.vdocument.in/reader033/viewer/2022061106/5444ffa3afaf9fe32b8b4634/html5/thumbnails/49.jpg)
Outsourcing Decision and Taxes
� Analysis the Value Chain and the Taxability of eachpoint of value addition
� If the Value Chain does not have taxes, theoutsourced vendor should not have any input Tax ascost nor charge any Output Tax which credit cannot
CA Abdur Rahman Musba
cost nor charge any Output Tax which credit cannotbe taken
� If the Value Chain has Taxes, the outsourced vendorshould able to at least avail and pass on thecreditable tax and further not add Tax cost.
![Page 50: Strategic Indirect Tax Management](https://reader033.vdocument.in/reader033/viewer/2022061106/5444ffa3afaf9fe32b8b4634/html5/thumbnails/50.jpg)
Case Study on Outsourcing
� For Input used outside the Factory, Cenvat Creditcannot be availed
� For Example, Cenvat Credit cannot be taken onExcise Duty paid on Explosive used by CementFactory for blasting Limestone.
CA Abdur Rahman Musba
Factory for blasting Limestone.
� Cenvat Credit cannot be taken for the tipper anddumper used for carrying limestone from the site tofactory (for such vehicles owned by the Factory orGoods Transport Agency)
� How to avail Cenvat Credit on these inputs andCapital Goods?
![Page 51: Strategic Indirect Tax Management](https://reader033.vdocument.in/reader033/viewer/2022061106/5444ffa3afaf9fe32b8b4634/html5/thumbnails/51.jpg)
Case Study on Outsourcing (Contd)
� The activities of the Limestone Mining can beoutsourced to Service Provider of Mining of Mineral
� Excise Duty on explosive can be availed as input, andcredit can be availed
Tippers and Dumpers can be treated as Capital
CA Abdur Rahman Musba
� Tippers and Dumpers can be treated as CapitalGoods for Mining activities
![Page 52: Strategic Indirect Tax Management](https://reader033.vdocument.in/reader033/viewer/2022061106/5444ffa3afaf9fe32b8b4634/html5/thumbnails/52.jpg)
Other Points to Consider
� Level of Control on the Third Party Service Provider
� Maturity of the Service Provider and competitiveness in the Industry
� Quality of Service Level
Confidentiality
CA Abdur Rahman Musba
� Confidentiality
� Administrative Cost and Management time to set up own Service Provider
� Effect on future changes in law
![Page 53: Strategic Indirect Tax Management](https://reader033.vdocument.in/reader033/viewer/2022061106/5444ffa3afaf9fe32b8b4634/html5/thumbnails/53.jpg)
Formalities
CA Abdur Rahman Musba
![Page 54: Strategic Indirect Tax Management](https://reader033.vdocument.in/reader033/viewer/2022061106/5444ffa3afaf9fe32b8b4634/html5/thumbnails/54.jpg)
Formalities
� To avail Credit/Refund/Exemption proper formalitieshave to be complied
� Registration is one of the important Formalities. TheRegistration show the ground plan.
� Only area shown in Ground Plan, Cenvat Credit can beavailed. (Any Capital Goods installed outside the Ground
CA Abdur Rahman Musba
Only area shown in Ground Plan, Cenvat Credit can beavailed. (Any Capital Goods installed outside the GroundPlan, Cenvat Credit cannot be availed).
� Land owned by the unit or lease by the unit can be shownin Ground Plan.
� In case of Project, where Contractor has leased out land,the lessee right should be assigned to the Unit.
![Page 55: Strategic Indirect Tax Management](https://reader033.vdocument.in/reader033/viewer/2022061106/5444ffa3afaf9fe32b8b4634/html5/thumbnails/55.jpg)
Formalities (Contd)
� Any additional land taken for the purpose of unit, andany manufacturing activities or storage is done in suchland, the Ground Plan should be amended.
� Even if storage is made in additional area (not mentionedin Ground Plan) it may be construed as “removal”.
CA Abdur Rahman Musba
in Ground Plan) it may be construed as “removal”.
� Cenvat Credit can be taken for a particular Unit. If thefactory is at different location, Cenvat Credit for eachfactory should be taken.
� In case, there are two units at the same location, CenvatCredit should be taken for each unit separately.
![Page 56: Strategic Indirect Tax Management](https://reader033.vdocument.in/reader033/viewer/2022061106/5444ffa3afaf9fe32b8b4634/html5/thumbnails/56.jpg)
Case Study (Installation outside Ground Plan)
� An Factory has to set up a Transformer for its factory
� The Transformer is being set up outside the factoryon Government Land.
� How can Cenvat Credit be availed on installation ofthe Transformer?
CA Abdur Rahman Musba
the Transformer?
![Page 57: Strategic Indirect Tax Management](https://reader033.vdocument.in/reader033/viewer/2022061106/5444ffa3afaf9fe32b8b4634/html5/thumbnails/57.jpg)
Case Study (Installation outside Ground Plan)
� The Cenvat Credit of Central Excise cannot beavailed directly
� A contractor has to be appointed for Supply andInstallation of Transformer (Composite Contract)
� The Contractor has to Purchase the Transformer
CA Abdur Rahman Musba
� The Contractor has to Purchase the Transformerfrom the Manufacturer/Excise Dealer and takeCenvat Credit on Central Excise
� After Installation, the Contractor has to ChargeService Tax on the Whole Value of Works at FullRate.
� Cenvat Credit can be taken on Service Tax.
![Page 58: Strategic Indirect Tax Management](https://reader033.vdocument.in/reader033/viewer/2022061106/5444ffa3afaf9fe32b8b4634/html5/thumbnails/58.jpg)
Contracts – Capital Goods –Tax Liability
CA Abdur Rahman Musba
![Page 59: Strategic Indirect Tax Management](https://reader033.vdocument.in/reader033/viewer/2022061106/5444ffa3afaf9fe32b8b4634/html5/thumbnails/59.jpg)
Formalities - Contracts
� Capital Goods can be purchase through three ways
� Supply Contract
� Works Contract
� Supply & Erection Contract
CA Abdur Rahman Musba
![Page 60: Strategic Indirect Tax Management](https://reader033.vdocument.in/reader033/viewer/2022061106/5444ffa3afaf9fe32b8b4634/html5/thumbnails/60.jpg)
Supply Contracts
� Cenvat Credit Under Central Excise can be takeneasily as the Invoice is in the name of Buyer
� For Inter-State Sales, C Form can be issued tominimise Sale Tax.
For Regular Purchases, the option for seller to open a
CA Abdur Rahman Musba
� For Regular Purchases, the option for seller to open adepot in the State should be analysed, if input of VATcan be availed
![Page 61: Strategic Indirect Tax Management](https://reader033.vdocument.in/reader033/viewer/2022061106/5444ffa3afaf9fe32b8b4634/html5/thumbnails/61.jpg)
Supply and Erection Contracts
� For Supply and Erection Contracts, (DivisibleContracts), the Purchase Order and Work Ordershould be issued
� Where the supplier is supplying goods from ThirdParty Manufacturer/Excise Dealer, the Invoice of the
CA Abdur Rahman Musba
Party Manufacturer/Excise Dealer, the Invoice of thethird party manufacturer should mention that theGoods are on Account of the Ultimate Buyer.(Contractor should not take Cenvat Credit).
![Page 62: Strategic Indirect Tax Management](https://reader033.vdocument.in/reader033/viewer/2022061106/5444ffa3afaf9fe32b8b4634/html5/thumbnails/62.jpg)
Supply and Erection Contracts (Contd)
� The Consignee in the Lorry Receipt (LR) should be inthe name of the contractor. The LR should beendorse in favour of Buyer before delivery of goods.
� The Contractor should not receive the Goods atDestination (especially in case of Sale in the course
CA Abdur Rahman Musba
Destination (especially in case of Sale in the courseof Inter State sale).
� Invoice should be raise on the date of endorsementof LR.
� C Form and E1, E2 Forms should be exchanged.
![Page 63: Strategic Indirect Tax Management](https://reader033.vdocument.in/reader033/viewer/2022061106/5444ffa3afaf9fe32b8b4634/html5/thumbnails/63.jpg)
Case Study
� In such Contracts, the Supplier Contractor isresponsible till Erection is over and handed over.The Contractor has to take insurance till handingover.
� If the Buyer accepts the goods delivered, what is the
CA Abdur Rahman Musba
� If the Buyer accepts the goods delivered, what is theLiability of the Contractor after delivery? (Who isresponsible for Security and Insurance?)
![Page 64: Strategic Indirect Tax Management](https://reader033.vdocument.in/reader033/viewer/2022061106/5444ffa3afaf9fe32b8b4634/html5/thumbnails/64.jpg)
Case Study
� When the Goods are received at site, the goodsshould be handed over to the Contractor, under acontract of Bailment, in pursuant of the MainAgreement, through a Delivery Challan.
CA Abdur Rahman Musba
![Page 65: Strategic Indirect Tax Management](https://reader033.vdocument.in/reader033/viewer/2022061106/5444ffa3afaf9fe32b8b4634/html5/thumbnails/65.jpg)
Works Contracts
� For Works Contract, the Contractor can take CenvatCredit. The Contractor has to charge normal ServiceTax on Full Value.
� However, in case of civil works, Cenvat Credit cannotbe availed. In Case of SEZ, Exemption of Central
CA Abdur Rahman Musba
be availed. In Case of SEZ, Exemption of CentralExcise and Service Tax can be obtained even for CivilWorks.
� Whether Works Contract can be split in Supply &Erection Contract should be analysed.
� Example: In Electrical Works and Goods can bepurchased Inter-State and Form C can be issued
![Page 66: Strategic Indirect Tax Management](https://reader033.vdocument.in/reader033/viewer/2022061106/5444ffa3afaf9fe32b8b4634/html5/thumbnails/66.jpg)
Custom Duty
CA Abdur Rahman Musba
![Page 67: Strategic Indirect Tax Management](https://reader033.vdocument.in/reader033/viewer/2022061106/5444ffa3afaf9fe32b8b4634/html5/thumbnails/67.jpg)
Computation of Custom Duty
S No
Particulars Working Legend Amount
1 Assessable Value (CIF + 1% of CIF)
A 1000
2 Basic Custom Duty (BCD) 10% of A B 100
3 CVD 10% of A+B C 110
CA Abdur Rahman Musba
3 CVD 10% of A+B C 110
4 Education Cess on CVD 3% on C D 3.3
5 Education Cess on BCD 3% on A+B+C E 6.40
6 Special Additional Duty 4% on A+B+C+D
F 48.79
7 Total 1268.49
Effective Duty 26.85%
![Page 68: Strategic Indirect Tax Management](https://reader033.vdocument.in/reader033/viewer/2022061106/5444ffa3afaf9fe32b8b4634/html5/thumbnails/68.jpg)
Credit for Custom Duty
� A manufacturer can claim Cenvat Credit on CVD,Education Cess on CVD and SAD
� A Service Provider can claim Cenvat Credit on CVDand Education Cess on CVD, and not on SAD.
A Trader can claim Refund of SAD, if the trader sells
CA Abdur Rahman Musba
� A Trader can claim Refund of SAD, if the trader sellsthe Goods charging VAT/Sales Tax.
� In a supply and erection contract (Divisible), theContractor can claim refund of SAD, and the Unitcan claim input Credit of CVD, Education Cess onCVD and VAT.
![Page 69: Strategic Indirect Tax Management](https://reader033.vdocument.in/reader033/viewer/2022061106/5444ffa3afaf9fe32b8b4634/html5/thumbnails/69.jpg)
Concession under Custom Duty – Capital Goods
� Project Imports – Concessional Rate of Custom Duty at5% or 0% for new Industrial & Infrastructural projects orsubstantially expansion of old projects. No Conditionattached
� Export Promotion Capital Goods Scheme under theForeign Trade Policy: Concessional Rate of 3% or 0%
CA Abdur Rahman Musba
Foreign Trade Policy: Concessional Rate of 3% or 0%Custom Duty.
� Export Oriented Unit: Custom Duty Exemption (forCapital Goods and Input).
� Special Economic Zone: Custom Duty Exempted
� Road Project: Machinery for Construction Exempted
![Page 70: Strategic Indirect Tax Management](https://reader033.vdocument.in/reader033/viewer/2022061106/5444ffa3afaf9fe32b8b4634/html5/thumbnails/70.jpg)
Concession under Custom Duty – Input
� Advance License Scheme
� Duty Free Import Authorisation
� Preferential Rate of Duty
CA Abdur Rahman Musba
![Page 71: Strategic Indirect Tax Management](https://reader033.vdocument.in/reader033/viewer/2022061106/5444ffa3afaf9fe32b8b4634/html5/thumbnails/71.jpg)
Case Duty - Delay Payment of Custom Duty
� When Huge Amount of Raw Material is imported (tobe used over a period of time), to avail Economy ofScale during Purchase.
� The Manufacturer does not have the cash to pay theCustom Duty or wants to avoid interest of funds used
CA Abdur Rahman Musba
Custom Duty or wants to avoid interest of funds usedto pay Custom Duty.
� What can be done?
![Page 72: Strategic Indirect Tax Management](https://reader033.vdocument.in/reader033/viewer/2022061106/5444ffa3afaf9fe32b8b4634/html5/thumbnails/72.jpg)
Delay Payment (Contd)
� The Goods can be stored in a Custom BondedArea/Warehouse.
� At the time of removal from Warehouse, CustomDuty can be Paid
CA Abdur Rahman Musba
![Page 73: Strategic Indirect Tax Management](https://reader033.vdocument.in/reader033/viewer/2022061106/5444ffa3afaf9fe32b8b4634/html5/thumbnails/73.jpg)
Case Study – Avoid Demurrage
� A Capital Goods in imported which is eligible forconcessional duty under Project Imports or ExportPromotion Capital Goods Scheme.
� However, the necessary formalities are notcompleted
CA Abdur Rahman Musba
completed
� If the Capital Goods are kept at the Port, hugedemurrages to be paid.
� How to Avoid the Demurrages?
![Page 74: Strategic Indirect Tax Management](https://reader033.vdocument.in/reader033/viewer/2022061106/5444ffa3afaf9fe32b8b4634/html5/thumbnails/74.jpg)
Avoid Demurrage
� The Goods should be transfer to Custom BondedArea and Project Can be registered in the CustomBonded Area and clear the goods at a concessionalrate of Duty.
CA Abdur Rahman Musba
![Page 75: Strategic Indirect Tax Management](https://reader033.vdocument.in/reader033/viewer/2022061106/5444ffa3afaf9fe32b8b4634/html5/thumbnails/75.jpg)
Benefits under Foreign Trade Policy
� Pre-Shipment
� Advance License
� Duty Free Import Authorisation
� Post Shipment
Duty Drawback
CA Abdur Rahman Musba
� Duty Drawback
� Duty Entitlement Passbook Scheme
� Market Focus Scheme
� Product Focus Scheme
� Served from India Scheme
![Page 76: Strategic Indirect Tax Management](https://reader033.vdocument.in/reader033/viewer/2022061106/5444ffa3afaf9fe32b8b4634/html5/thumbnails/76.jpg)
Foreign Trade Policy
� Projects
� Export Promotion Capital Goods Scheme
�Manufacturers of Products
�Hotels, Retailers, Project Imports
� Export Oriented Unit Scheme
CA Abdur Rahman Musba
� Export Oriented Unit Scheme
� Special Economic Zones
� Deemed Exports
� Refinery
� Power Projects
� EOU, SEZ
![Page 77: Strategic Indirect Tax Management](https://reader033.vdocument.in/reader033/viewer/2022061106/5444ffa3afaf9fe32b8b4634/html5/thumbnails/77.jpg)
Barriers to Foreign Trade
� Tariff Barriers
� High Rate of Import Duty
� Export Duty
� Free Trade Agreement/Pacts
� Non Tariff Barriers
CA Abdur Rahman Musba
� Non Tariff Barriers
� Phytosanitary Conditions
� Intellectual Property Rights
� Transfer of Technology
![Page 78: Strategic Indirect Tax Management](https://reader033.vdocument.in/reader033/viewer/2022061106/5444ffa3afaf9fe32b8b4634/html5/thumbnails/78.jpg)
Fiscal Benefits for Specific Projects
CA Abdur Rahman Musba
![Page 79: Strategic Indirect Tax Management](https://reader033.vdocument.in/reader033/viewer/2022061106/5444ffa3afaf9fe32b8b4634/html5/thumbnails/79.jpg)
Benefits for New Projects
� Concessional Custom Duty under Project Imports
� Deferred Payment of VAT on Sales
� Exemption of Stamp Duty on Lease, Loan
� Exemption of Electricity Duty, Entry Tax
CA Abdur Rahman Musba
� Exemption of Electricity Duty, Entry Tax
� Subsidy, Grant from Government
� Concessional Interest from Financial Institution
![Page 80: Strategic Indirect Tax Management](https://reader033.vdocument.in/reader033/viewer/2022061106/5444ffa3afaf9fe32b8b4634/html5/thumbnails/80.jpg)
Income Tax Benefit for New Projects
� Exemption for Income Tax under 10AA, 35AD, 80 IA,IAB, IB for various Industrial, Infrastructure Projects.
� Power, Road, Water Infrastructure, SEZ, Cold Storage,Industrial Project in Backward area, are some of theexempted Project
MAT is applicable on all Projects, but Creditable in
CA Abdur Rahman Musba
� MAT is applicable on all Projects, but Creditable innature. (Cash flow Issue: IRR, NPV, DSCR)
� The exemption of Tax may not be available due to initialhigher depreciation, initial cash losses
� However, actual exemption available should bedetermined by Financial Modelling.
![Page 81: Strategic Indirect Tax Management](https://reader033.vdocument.in/reader033/viewer/2022061106/5444ffa3afaf9fe32b8b4634/html5/thumbnails/81.jpg)
Power Projects
� Exemption from Excise and Custom Duty for MegaPower Projects
� Export Benefits Available for supplies to Mega PowerProjects
� Cenvat Credit need not be reversed for suppliers to MegaPower Project
CA Abdur Rahman Musba
Cenvat Credit need not be reversed for suppliers to MegaPower Project
� Income Tax exemption is available
� For other Independent Power Project; Excise, Custom isa cost
� Cenvat Credit can be available for Captive Power Plants,even if set up outside the Factory.
![Page 82: Strategic Indirect Tax Management](https://reader033.vdocument.in/reader033/viewer/2022061106/5444ffa3afaf9fe32b8b4634/html5/thumbnails/82.jpg)
Export Promotion Capital Goods Scheme
� Capital Goods used for Earning Forex
� Can be used by Hotel, Retailer, Project Imports and otherService Providers
� Import of Goods under Concessional Custom Duty/NilCustom Duty
CA Abdur Rahman Musba
Custom Duty
� Can also avail Indigenous Goods without Payment ofExcise Duty
� Domestic Supplier can avail Export Benefit like DutyDrawback
� Supply for Deemed Exports is counted for ExportObligations Fulfilment
![Page 83: Strategic Indirect Tax Management](https://reader033.vdocument.in/reader033/viewer/2022061106/5444ffa3afaf9fe32b8b4634/html5/thumbnails/83.jpg)
100% Export Oriented Unit
� Exemption under Excise Under CT – 3, ARE 3Procedure.
� Supplier of Goods need not reverse Cenvat Credit
� Supply to EOUs eligible for Export Benefits asdeemed exports.
CA Abdur Rahman Musba
deemed exports.
� Exemption of Custom Duty
� Service Tax can be availed as Credit and refund canbe obtained.
� CST is eligible for Refund
� Rate of Excise Duty is equivalent to Custom Duty
![Page 84: Strategic Indirect Tax Management](https://reader033.vdocument.in/reader033/viewer/2022061106/5444ffa3afaf9fe32b8b4634/html5/thumbnails/84.jpg)
Computation of Duty for EOU Sale
S No
Particulars Working Legend Amount
1 Assessable Value A 1000
2 Basic Custom Duty (BCD) 10% of A B 100
3 CVD 10% of A+B C 110
4 Education Cess on CVD 3% on C D 3.3
CA Abdur Rahman Musba
4 Education Cess on CVD 3% on C D 3.3
5 Education Cess on BCD 3% on A+B+C E 6.40
6 Total Excise Duty B+C+D+E F 219.7
Education Cess on Excise Duty 3% on F G 6.59
7 Total 1226.29
+ VAT/CST
![Page 85: Strategic Indirect Tax Management](https://reader033.vdocument.in/reader033/viewer/2022061106/5444ffa3afaf9fe32b8b4634/html5/thumbnails/85.jpg)
Special Economic Zone
� Exemption of Excise Duty, CST, Custom Duty, ServiceTax, R&D Cess for Authorised Operations
� Cenvat Credit on Goods or Service need not be reversedby the supplier/Service Providers
� Export Benefits can be availed. However, for units some
CA Abdur Rahman Musba
� Export Benefits can be availed. However, for units someexport benefits is subject to payment made in Forex
� Exemption of taxes for Civil Works
� Exemption of taxes for Construction Equipment of theContractors
� Income Tax benefit under Section 80IAB, 10AA
![Page 86: Strategic Indirect Tax Management](https://reader033.vdocument.in/reader033/viewer/2022061106/5444ffa3afaf9fe32b8b4634/html5/thumbnails/86.jpg)
Special Economic Zone (Contd)
� VAT is exempted by way of refund
� Exemption of Entry Tax (except certain PetroleumGoods)
� Exemption of Stamp Duty (100% for Developer/Co-Developer and 50% for units)
CA Abdur Rahman Musba
Developer and 50% for units)
� Exemption of Electricity Duty
� Custom Duty is payable when Sale made to DTA. (If theproduct is generally not being imported and CustomDuty is not exempted, the Seller have to bear the impactof Custom Duty component)
� Net Foreign Exchange Earning should be positive
![Page 87: Strategic Indirect Tax Management](https://reader033.vdocument.in/reader033/viewer/2022061106/5444ffa3afaf9fe32b8b4634/html5/thumbnails/87.jpg)
Case Study on SEZ
� Analysis of Input and Output Taxes is very critical fordetermination whether unit should be located in SEZ
� For IT/Electronic hardware, the main products outputare exempted from Custom Duty. However, the ITcomponents (inputs) attract Custom Duty
CA Abdur Rahman Musba
components (inputs) attract Custom Duty
� Sale of IT related goods in DTA is covered under the NetForeign Exchange Earning
� Hence, it is beneficial to set up a unit in SEZ than DTA,as SEZ unit can procure inputs without Custom Duty andsell without paying Excise Duty or Custom Duty
![Page 88: Strategic Indirect Tax Management](https://reader033.vdocument.in/reader033/viewer/2022061106/5444ffa3afaf9fe32b8b4634/html5/thumbnails/88.jpg)
Devil Lies in the Details
CA Abdur Rahman Musba
![Page 89: Strategic Indirect Tax Management](https://reader033.vdocument.in/reader033/viewer/2022061106/5444ffa3afaf9fe32b8b4634/html5/thumbnails/89.jpg)
Tips to ensure Compliance
� Scrutinise the Registration Certificates from time totime
� Keep Proper Documents, even if there is no taxpayable.
How do you convince the Government Official that your
CA Abdur Rahman Musba
� How do you convince the Government Official that yourturnover has not exceed the taxable turnover?
� Maintain proper Registers
� Have effective internal control
� Follow Proper System
� Remember the Security tracks the movements of goods
![Page 90: Strategic Indirect Tax Management](https://reader033.vdocument.in/reader033/viewer/2022061106/5444ffa3afaf9fe32b8b4634/html5/thumbnails/90.jpg)
Tips to ensure Compliance (Contd)
� Check the official rules relating to documentations bothfor documents in which exemption/Credit is obtain aswell as documents which is issued by the organisation
� Maintain Proper Record of Suppliers and Purchasers
� Have adequate personnel for compliance or outsource
CA Abdur Rahman Musba
� Have adequate personnel for compliance or outsourcethe job
� Give regular training to the personnel
� Conduct regular audits to minimise contravention of law
� Structure the wording of the Contract, Invoice, Letters
![Page 91: Strategic Indirect Tax Management](https://reader033.vdocument.in/reader033/viewer/2022061106/5444ffa3afaf9fe32b8b4634/html5/thumbnails/91.jpg)
Any Questions
CA Abdur Rahman Musba