UNION BUDGET Santhappa & Co., Chartered Accountants

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1 UNION BUDGET 2018 Santhappa & Co., Chartered Accountants

2 BUDGET 2018 INTRODUCTION ECONOMIC SURVEY DIRECT TAXES SLAB RATES FOR INDIVIDUALS/HUF AND COMPANIES INCOME FROM SALARIES INCOME FROM BUSINESS OR PROFESSION CAPITAL GAINS INCOME FROM OTHER SOURCES CHARITABLE AND RELIGIOUS TRUSTS INCOME COMPUTATION AND DISCLOSURE STANDARDS DEDUCTIONS OTHER AMENDMENTS TDS CHART FOR FY INDIRECT TAXES CUSTOMS

3 INTRODUCTION Finance Minister Sri Arun Jaitley presented the Union Budget in Parliament on 1 st February With a focus on the rural economy and farmers, the government proposed a string of measures for the agriculture sector. He also announced a new national health insurance scheme, set to be the largest government-funded programme in the world, which will cover 10 crore poor and marginalised families, translating to 50 crore beneficiaries. The slippage, though bigger than markets expected, wasn't large enough to raise the hackles of rating firms - an analyst at Moody's Investors Service, ECONOMIC SURVEY The GDP growth rate for the fiscal year is pegged at 6.75% by the Economic Survey report. The government, in its advance GDP estimate, had estimated a growth of 6.5%. In the fiscal year 2019, the survey said that the Indian economy is expected to grow between 7% and 7.5%. The International Monetary Fund (IMF) has also said that India could grow at 7.4% in the current year 2018, as against China s 6.8%. The Agriculture growth in FY18 likely to be at 2.1%, while the Industry growth for FY18 likely to be 4.4%. On the implementation of the Goods and Service Tax (GST), the survey said that there has been a 50% increase in number of indirect taxpayers; Large increase in voluntary registrations; distribution of GST base closely linked to size of economies; strong correlation between export performance and state s standard of living and India s formal sector was found to be substantially greater than currently believed, the economic survey said. which announced a rating upgrade for India in November, said the Budget was in line with the country's fiscal consolidation plan and that the "spending announced seemed to be on productive investments". Sri Arun Jaitley also embraced an expert committee's suggestion to bring down the Centre's debt-to-gdp ratio to 40% (from around 49% now). Capital expenditure via the Budget has suffered in the current financial year and is budgeted to remain low in the next year as well, but support from public sector enterprises and other extra-budget public investments are what the Finance Minister seeks to employ to spur the economy. Services growth for FY18 likely to be at 8.3% and the country s economy should witness improvement in next fiscal year. The level of tax filers by November 2017 was 31% greater. The economic survey said that it translated roughly into about 1.8 million additional taxpayers due to demonetization-cum-gst, representing 3% of existing taxpayers. The apparel sector has immense potential to drive economic growth, increase employment, and empower women in India. This is especially true as China s share of global apparel exports has come down in recent years. However, India has not, or not yet, capitalized on this opening. In the last three fiscal years, India experienced a positive term of trade shock. But in the first three quarters of , oil prices have been about 16 percent greater in dollar terms than in the previous year. It is estimated that a $10 per barrel increase in the price of oil reduces growth by percentage points, increases WPI inflation by about 1.7 percentage points and worsens the CAD by about $9-10 billion dollars. Economic Survey calls

4 for policy vigilance in coming year if high oil prices persist or stock prices correct sharply. The IBC resolution process could prove a valuable technology for tackling this long-standing problem in the Indian corporate sector. The Headline inflation has been below 4 per cent for twelve straight months, from November, 2016 to October, 2017 and CPI food inflation averaged around one per cent during April-December in the current financial year. The Survey observes that the economy has witnessed a gradual transition from a period of high and variable inflation to more stable prices in the last four years. Current account deficit expected to average 1.5-2% of the GDP this fiscal, while export growth is pegged at 12.1%. The survey said that India will need $4.5 trillion investment in infrastructure by DIRECT TAXES SLAB RATES A. Individuals (< 60Years), HUF, AOP, BOI & Artificial Juridical Person Income Rate of Tax Up to ` 2,50,000 NIL ` 2,50,001 to ` 5,00,000 5% ` 5,00,001 to ` 10,00,000 20% Above ` 10,00,000 30% C. Partnership firms, LLP and local authorities Income Rate of Tax Tax on Total Income 30% B. Individuals (Senior and Super Senior Citizens) Income Above 60 and below Above 80 years 80 years Up to 3,00,000 Nil Nil 3,00,001 to 5% Nil 5,00,000 ` 5,00,001 to 20% 20% ` 10,00,000 Above ` 10,00,000 30% 30% D. Companies Turnover/Income Type of Company Rate of Tax Turnover up to 250 Crores Domestic Company 25% Turn over Exceeding 250 Domestic Company 30% Crores Tax on Total Income Foreign Company 40%

5 SURCHARGE AND CESS Surcharge Assessee Status Total Income Rate Not exceeding 50 Lakhs Nil Individual ` 50 lakhs to ` 1 Crore 10% Above ` 1 Crore 15% Firm / LLP Above ` 1 Crore 12% Domestic Company ` 1 Crore to ` 10 Crore 7% Above ` 10 Crore 12% Foreign Company ` 1 Crore to ` 10 Crore 2% Above ` 10 Crore 5% HEADS OF INCOME INCOME FROM SALARIES Standard Deduction on Salary Income It is proposed to allow a standard deduction up to 40,000/- or the amount of salary received, whichever is less. Further the exemption in respect of CESS Health and Education 4% is applicable to all assessees which replaces the earlier 3% Transport Allowance (except in case of differently abled persons) Rs. 19,200/- (Rs. 38,400/- for physically handicapped or blind or deaf and dumb employees) and reimbursement of medical expenses of Rs. 15,000 is proposed to be withdrawn. INCOME FROM BUSINESS OR PROFESSION Presumptive income under section 44AE in case of goods carriage Since the profit margins of large capacity goods carriages are higher than small capacity goods carriages, however the tax consequences are similar which is against the principle of tax equity. Thus, Section 44AE is proposed to be amended to tax heavy goods vehicle (more than 12MT gross vehicle weight) at (a) amount earned or (b) 1,000/- per ton of gross vehicle weight or unladen weight per month or part of a month for each goods vehicle, whichever is higher. Taxability of compensation in connection to business or employment Section 28 has been proposed to be amended to tax the following - any compensation received or receivable, whether revenue or capital, in connection with the termination or the modification of the terms and conditions of any contract relating to its business. Tax treatment of transactions in respect of trading in agricultural commodity derivative Section 43(5) is proposed to be amended to tax trading of agricultural commodity derivatives, which is not chargeable to CTT, in a registered stock exchange or registered association, as non-speculative transaction. Rationalization of provision relating to conversion of stock-in-trade into Capital Asset

6 -Proposed amendment to sec 28 provides that any profit or gains arising from conversion of inventory into capital asset or its treatment as capital asset shall be charged to tax as business income where the existing law does not provide for its taxability. - Fair Market Value[FMV] of the inventory on the date of conversion or treatment determined in the prescribed manner, shall be deemed to be the CAPITAL GAINS Rationalization of Section 43CA, Section 50C and Section 56 No adjustments shall be made in a case where the variation between stamp duty value and the sale consideration is not more than 5% of the sale consideration Rationalization of the provisions of section 54EC The holding period for bonds under Section 54EC has been increased from 3 years to 5 years. Benefit of Section 54EC The scope of exemption under section 54EC has been restricted to Long Term Capital Gains arising out of Land or Buildings only. Long Term Capital Gains on Shares And Equity Oriented Funds Under the existing Act, the long-term capital gains on sale of Listed equity shares and Equity Oriented Mutual Funds were exempt from whole of tax under section 10(38). The Finance Act 2018 has proposed to withdraw the exemption under section 10(38) and to introduce a new section 112A in the Act to provide that long-term capital gains arising from transfer of a long-term capital asset being an equity share in a company or a unit of an equity-oriented fund or a unit of a business trust shall be taxed at 10 per cent of such capital gains exceeding Rs. 1,00,000/- full value of the consideration received or accruing as a result of such conversion. - For the computation of capital gain the FMV on the date of conversion shall be the cost of acquisition. Further, the new provision of section 112A also proposes to provide the following : a. First and Second Proviso to Section will not be available i.e. Benefit of Indexation & Benefit of computation of capital in foreign currency in case of Non-Residents. The Exemption under section 10(38) has been withdrawn for Foreign Institutional Investors also. b. The cost of acquisitions in respect of the long-term capital asset acquired by the assessee before the 1st day of February, 2018, shall be deemed to be the higher of i. the actual cost of acquisition of such asset; and ii. the lower of - the fair market value of such asset; and - the sale consideration received or accruing as a result of sale. Fair market value has been defined to mean a. in a case where the capital asset is listed on any recognized stock exchange, the highest price of the capital asset quoted on such exchange on the 31st day of January, However, where there is no trading in

7 such asset on such exchange on the 31st day of January, 2018, the highest price of such asset on such exchange on a date immediately preceding the 31st day of January, 2018 when such asset was traded on such exchange shall be the fair market value; and b. in a case where the capital asset is a unit and is not listed on recognized stock exchange, the net asset value of such asset as on the the 31st day of January, ANALYSIS 1: Assuming Mr. X purchased 5,000 shares of ABC Ltd listed on NSE on for Rs. 100 per share. On he wants to sell the same when market value is Rs. 200/- and The FMV of ABC shares on is Rs. 175/- The Cost of Acquisition for the purpose of Section 112A is determined as under: a. Actual Cost of Acquisition is 5,000 x 100 = Rs. 5,00,000/- And, the cost of acquisition is higher of (a) and (b) i.e. Rs.8,75,000/- being higher of Rs.8,75,000/- or Rs.5,00,000/- Therefore, Long Term Capital Gain is Actual Sales Consideration Cost of Acquisition as calculated above = Rs.10,00,000 Rs.8,75,000 Hence Long Term Capital Gain = Rs. 1,25,000/- b. the lower ofi. the fair market value on 31st January 2018 i.e., Rs. 8,75,000/- or ii. Actual sale consideration i.e. Rs. 10,00,000/- So, the lower of (i) and (ii) is Rs. 8,75,000/- ANALYSIS 2: Assuming Mr. X purchased 5,000 shares of ABC Ltd listed on NSE on for Rs. 100 per share. On he wants to sell the same when market value is Rs.75/- and The FMV of ABC shares on is Rs. 175/-. The Cost of Acquisition for the purpose of Section 112A is determined as under: a. Actual Cost of Acquisition is 5,000 x 100 = Rs. 5,00,000/- b. the lower ofi. the fair market value on 31st January 2018 i.e. Rs. 8,75,000/- or ii. Actual sale consideration i.e. Rs. 3,75,000/- So, the lower of (i) and (ii) is Rs. 3,75,000/- And, the cost of acquisition is higher of (a) and (b) i.e. Rs.5,00,000/- being higher of Rs.5,00,000/- or Rs.3,75,000/- Therefore, Long Term Capital Loss is Actual Sales Consideration Cost of Acquisition as calculated above = Rs.3,75,000 Rs.5,00,000 Hence Long Term Capital Loss = Rs. 1,25,000/

8 ANALYSIS 3: Assuming Mr. X purchased 5,000 shares of ABC Ltd listed on NSE on for Rs. 100 per share. On he wants to sell the same when market value is Rs.150/- and The FMV of ABC shares on is Rs. 175/-. The Cost of Acquisition for the purpose of Section 112A is determined as under: a. Actual Cost of Acquisition is 5,000 x 100 = Rs. 5,00,000/- b. the lower ofi. the fair market value on 31st January 2018 i.e. Rs. 8,75,000/- or ii. Actual sale consideration i.e. Rs. 7,50,000/- So, the lower of (i) and (ii) is Rs. 7,50,000/- And, the cost of acquisition is higher of (a) and (b) i.e. Rs.7,50,000/- being higher of Rs.8,75,000/- or Rs.7,50,000/- Therefore, Long Term Capital Gain is Actual Sales Consideration Cost of Acquisition as calculated above = Rs.7,50,000 Rs.7,50,000 Hence Long Term Capital Gain is NIL INCOME FROM OTHER SOURCES Tax deduction at source on 7.75% GOI Savings (Taxable) Bonds, 2018 The 8% savings bonds are known being replaced with 7.75% GOI savings bond. The interest received are taxable as in the case of earlier once. The Tax u/s 193 for deduction of TDS on such bonds are likely to be deducted at the time of making payment. No TDS is charged if the interest amount does not exceed the threshold limit. Application of Dividend Distribution Tax to Deemed Dividend Now, deemed dividend u/s 2(22) (e) is now subject to DDT under section 115O at the rate of 30% without gross up. Widening of scope of Accumulated profits for the purposes of Dividend To prevent companies escaping from paying tax on distribution of profits through amalgamation route. It is proposed to insert a new Explanation 2A to section 2(22) to widen the scope of term Accumulated profits so as to provide that in the case of an amalgamated company, accumulated profits, whether capitalised or not, or losses as the case may be, shall be increased by the accumulated profits of the amalgamating company, whether capitalized or not, on the date of amalgamation. CHARITABLE AND RELEGIOUS TRUSTS For the purposes of determining the application of income under section 11(1) expenditure incurred by cash exceeding 10,000 per person per day shall be ignored. Further where TDS has not been deducted as specified under section 40(a)(ia), 30% of such expenditure shall not be considered for the purpose of section 11(1). The above stated amendments shall also apply to entities claiming exemption under Section 10(23)(iv),(v),(vi) or (via)

9 INCOME COMPUTATION AND DISCLOSURE STANDARDS Amendments in relation to notified Income Computation and Disclosure Standards Recognition of Income or Expenses in certain cases which are to be computed in the manner provided in income computation and disclosure standards notified under section 145(2): 1. Marked to market loss or other expected loss shall be allowed deduction u/s 36(1)(xviii) and shall not be allowed as deduction in any other section as per Section 40A 2. Gain or loss arising on account of effects of changes in foreign exchange rates in respect of specified foreign currency transactions shall be treated as income or loss u/s 43AA 3. Income from Construction Contracts shall be determined u/s 43CB on the basis of percentage of completion method except for certain service contracts and that the contract revenue shall include retention money, and contract cost shall not be reduced by incidental interest, dividend and capital gains. 4. Section 145A has been amended with the following for determining the Income under the head Income from Business or Profession: i. The Valuation of inventory shall be lower of cost or Net Realizable Value paid or incurred by the assessee to bring the goods or services to the place of its location and condition as on the date of valuation. iii. Inventory being securities not listed, or listed but not quoted, on a recognized stock exchange, shall be valued at actual cost iv. Inventory being listed securities, shall be valued at lower of actual cost or net realizable value shall be done category-wise. 5. Further Section 145B has been inserted with the following: i. Interest received by an assessee on compensation or on enhanced compensation, shall be deemed to be the income of the year in which it is received. ii. The claim for escalation of price in a contract or export incentives shall be deemed to be the income of the previous year in which reasonable certainty of its realization is achieved. iii. Income u/s 2(24) (xviii) shall be deemed to be the income of the previous year in which it is received, if not charged to income tax for any earlier previous year. ii. The valuation of purchase and sale of goods or services and of inventory shall be adjusted to include the amount of any tax, duty, cess or fee actually

10 DEDUCTIONS Section Description Maximum Eligible deduction 80C Payments made to LIC, Contribution to PPF, Payment of Tuition Fee (first and second Child), Repayment of Housing Loan, Specified Investments, Stamp Duty on Purchase of House Property 80CCB Investment made under Equity Linked Savings Schemes (Up to Rs.10,000) Rs.1,50,000 80CCD Contribution to Pension Scheme of Central Government (Amount invested or 10% of Salary/Gross Total Income) 80CCD(1B) Contribution to NPS Rs.50,000 Health Insurance Premium Rs.25,000 80D Payment for preventive Health Check up Rs.5,000 Medical Expenditure of whole Family Rs.30,000 Senior Citizens Rs.50,000 80DD Maintenance including medical of a dependent person with disability Rs.75,000 Maintenance including medical of a dependent person with severe disability Rs.1,25,000 80DDB Medical treatment of Specified Diseases [senior citizens & very senior citizens] Rs.1,00,000 80E Interest on loan taken for higher education Amount of Interest Paid 80EE Interest on loan taken for residential house property (Value should not exceed Rs.50,00,000 and loan sanction should not exceed Rs.35,00,000) Rs.50,000 80G Specified Donations 100% of Amount Donated Other Donations 50% of Amount Donated 80GG Rents Paid Rs.60,000 80GGA Donation for Scientific research or rural development Amount Donated 80GGB Contributions given by companies to political parties (not allowed by way of cash) Amount Donated 80GGC Contributions given by any person to political parties (not allowed by way of cash) Amount Donated 80JJA Profits from business of bio-degradable waste Amount Donated 80JJAA Employment of new employees 30% of additional employee cost 80QQB Royalty income etc for authors (other than text books) Rs.3,00,000 80RRB Royalty on patents Rs.3,00,000 80TTA Interest on deposits in savings account Rs.10,000 80TTB Interest on deposits for Senior Citizens Rs.50,000 Person with disability Rs.75,000 80U Person with Severe disability Rs.1,25,000

11 OTHER AMENDMENTS Section 80AC has been amended to provide that all provisions of Chapter VI-A Part C - Deductions in respect of certain incomes shall be allowed only if return id filed within due date u/s 139(1). Every person, not being individual, which enters into a financial transaction of an amount aggregating to two lakh and fifty thousand rupees or more in a financial year shall be required to apply to the Assessing Officer for allotment of PAN. The managing director, director, partner, trustee, author, founder, Karta, chief executive officer, principal officer or office bearer or any person competent to act on behalf of such entities shall also apply to the Assessing Officer for allotment of PAN. This amendment will take effect from 1st April, Similarly relief from shareholding specified under section 79 for carry forward of losses in case of private limited companies has been exempted for companies who have filed for corporate insolvency resolution process under the Insolvency and Bankruptcy Code, 2016 with the Adjudicating Authority. Income arising to a non-resident (other than a company or foreign company) by way of royalty from, or fees for technical services rendered in or outside India to, the National Technical Research Organisation will be exempt u/s 10 from income tax and hence TDS on such payments is not required u/s 195. (W.e.f 1 st April 2018) Section 115R has been amended to introduce dividend distribution tax on equity-oriented fund at the rate of 10% Section 271FA states that any person fails to failure to furnish statement of financial transaction or reportable account is liable to pay a penalty of Rs 100 per day as default. The assesse failing to furnish the same even after a specified notice u/s 285BA (5) is liable to a penalty of Rs 500 per day in default. This may further extend to Rs.1,000 on continuing default. 115JB is amended to provide deduction of the aggregate amount of unabsorbed depreciation and loss brought forward (excluding unabsorbed depreciation) from book profits, irrespective of which is lower, when a company has filed for corporate insolvency resolution process under the Insolvency and Bankruptcy Code, 2016 with the Adjudicating Authority. [Applicable from AY 18-19] It is proposed to amend the section 47 of the Act so as to provide that transactions in the following assets, by a non-resident on a recognized stock exchange located in any International Financial Services Centre shall not be regarded as transfer, if the consideration is paid or payable in foreign currency- 1. Bond or Global Depository Receipt, as referred to in sub-section (1) of section 115AC or 2. rupee denominated bond of an Indian company or 3. derivative Any income arising any income accruing or arising to a foreign company on account of sale of leftover stock of crude oil, if any, from the facility in India after the expiry of the agreement or the arrangement referred to in clause (48A) subject to such conditions as may be notified by the

12 Central Government in this behalf is shall not be considered in computing the total income. (W.e.f 1 st April 2019) No adjustment under section 143(1)(vi) shall be made in respect of any return furnished on or after the assessment year commencing on the first day of April, i.e. no addition shall be made relating to income appearing in 26AS, Form 16 and 16A which has not been considered in the return. Section 271J - Penalty on professionals for furnishing incorrect information in statutory report or certificate should be removed. If an accountant or a merchant banker or a registered valuer, furnishes incorrect information in a report or certificate under any provisions of the Act or the rules made thereunder, the Assessing Officer or the Commissioner (Appeals) may direct him to pay a sum of ten thousand rupees for each such report or certificate by way of penalty Section Any assessee may appeal to the Appellate Tribunal against such order. Section 245-O provides for the constitution of an Authority for Advance Rulings. In view of the proposed constitution of new Customs Authority for Advance Ruling under section 28EA of the Customs Act, section 245O so as to provide that such Authority shall cease to act as an Authority for Advance Rulings, and shall act as an Appellate Authority for the purpose of Chapter V of the Customs Act, 1962 from the date of appointment of Customs Authority for Advance Rulings under section 28EA of the Customs Act, It is further proposed that such Authority shall not admit any appeal against any ruling or order passed earlier by it in the capacity of Authority for Advance ruling after the date of appointment of Customs Authority for Advance Rulings under section 28EA of the Customs Act, In order to avoid overlapping, it is also proposed that where the Authority is dealing with an application seeking advance ruling in the matters of the Act, the Revenue Member shall be the Member referred to in sub-clause (i) of clause (c) of sub-section (3). Taxation of long-term capital gains in the case of Foreign Institutional Investor[Section 115AD] - Consequent to the proposal for withdrawal of exemption under section 10(38) of the Act, the FIIs will be liable to tax on long term capital gains arising from transfer of long term capital asset being equity shares of a company or a unit of equity oriented fund or a unit of business trusts only in respect of amount of such gains exceeding one lakh rupees. Rationalisation of provisions relating to Country-by-Country Report [Section 286] - The time allowed for furnishing the Country-by-Country Report (CbCR), in the case of parent entity or Alternative Reporting Entity (ARE), resident in India, is proposed to be extended to twelve months from the end of reporting accounting year (For FY the time limit shall be March 31, 2019) - In case its parent entity outside India has no obligation to file the report in its country or territory then constituent entity resident in India, shall also furnish CbCR within the aforesaid due date i.e. twelve months from the end of reporting accounting year It is proposed to prescribe a new scheme for the purpose of making assessments so as to impart greater transparency and accountability, by eliminating the interface between the Assessing Officer and the assessee, optimal utilization of the resources, and introduction of teambased assessment.

13 TDS CHART FOR FY Section Nature of Payment Threshold Limit Rate 192 Salary As per the Slab rates applicable to Individual & Senior Citizens 194A Interest Other than Securities 10,000/- for Banks** and 5,000/- for Others 10% 194B Winning from Lottery & Puzzles 10,000/- p.a. 30% 194C Contractors, Sub-Contractors and Advertising 30,000/- per contract or 1,00,000/- p.a. 1% (Indl/HUF) & 2% (Company /Firm) 194D Insurance Commission 15,000/- p.a. 5% 194H Commission & Brokerage 15,000/- p.a. 5% 194I(a) Rent - Plant & Machinery 1,80,000/- p.a. 2% 194I(b) Rent - Land & Building 1,80,000/- p.a. 10% 194IA Transfer of Immovable Property other than Agricultural Land 50,00,000/- 1% (Indl/HUF) & 2% (Company /Firm) 194IB Rent paid by Individual/HUF 50,000/- p.m. 5% 194IC Payment under specified agreement 50,00,000/- 1% 194J Professional Fees & Technical Services 30,000/- p.a. 10% ** For Senior citizens and Super Senior citizens the Threshold limit has been increased from 10,000/- p.a to 50,000/-

14 INDIRECT TAXES CUSTOMS DUTY 1. A social welfare surcharge at 10% of the aggregate customs duties has been levied on imported goods in place of existing 3% education cesses. However, this surcharge will not be leviable on integrated tax and GST compensation cess on imported goods 2. In order to provide impetus to domestic industry and giving boost to make in India campaign, Customs duty rate has been increased in certain sectors, like food processing, electronics, auto components, footwear and furniture. It would also encourage starting of some high tech products to be manufactured in India. AMENDMENTS IN THE FIRST SCHEDULE TO THE CUSTOMS TARIFF ACT, 1975 Commodity Old Rate New Rate Food Processing 30% 50% Perfumes and toiletry preparations 10% 20% Automobile parts 7.5%/10% 15% Footwear 10% 20% Imitation Jewellery 15% 20% Cellular mobile phones 15% 20% Smart watches / wearable devices 7.5%/10% 15% Specified Parts of cellular mobile phones and other parts of LCD/LED/OLED TVs 7.5%/10% 15% Furniture 10% 20% Watches and Clocks 10% 20% Toys and Games 10% 20% Miscellaneous items 10% 20% 3. The name of Central Board of Excise and Customs [CBEC] to Central Board of Indirect Taxes and Customs (CBIC)

15 Credits Team Santhappa & Co., This summary of the Budget 2018 is compiled by Santhappa & Co., Chartered Accountants for restricted circulation only. It should not be relied upon as a substitute for detailed advice or as a basis for formulating business decision. Although, we endeavor to provide accurate and timely information, since its generality in nature there can be no guarantee that such information is accurate as of the date it is received or that it will continue to be accurate in future. Santhappa & Co., Chartered Accountants 201, 2 nd Floor, House of Lords, St. Mark s Road, Bangalore

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