UNION BUDGET CENTRAL EXCISE & CENVAT PROPOSALS
UNION BUDGET CONTENTS Preface... 2 Effective Date for Various Changes... 3 Central Excise... Legislative Changes 4-13 Cenvat Credit Rules, 2004. 14-22 1 S.K.KANODIA & ASSOCIATES
UNION BUDGET PREFACE Dear Readers, Budget has been a agriculture as well as farmer oriented budget. The Hon ble Finance Minister has provided many things for the farmers. On the indirect tax front, especially service tax and cenvat credit, a lot of procedural changes have been done. A new levy in the name of Krishi Kalyan Cess has been introduced. A dispute resolution system in indirect tax has been formulated. Many new exemptions has been introduced in the exemption notification. MAKE In INDIA concept has been favoured with many excise and customs rates being rationalized along with excise procedures. The intent of legislature has been clarified by amending Rule 6 of the Cenvat Credit Rules, 2004. All these are welcome step in the reforms of taxation. However, no update as to GST has been provided and it seems that the GST road is still far away. One needs to wait and watch till further updates are provided. As with every Budget, there are numerous questions which can be answered only on the fine reading of the budget papers. Please revert with your comments and questions. We would try our best to help you with any Budget related issues as per our interpretation of the same. Thank you for your support and faith in our firm. Best Regards, Ankit Kanodia Partner- Indirect Tax & Regulatory 2 S.K.KANODIA & ASSOCIATES
UNION BUDGET EFFECTIVE DATE FOR VARIOUS CHANGES Particulars Effective date of change Legislative changes in Customs and Excise Date of enactment of Finance Bill,, unless otherwise specified Changes to declared list and negative list Date of enactment of Finance Bill,, unless otherwise specified Amendments to CENVAT Credit Rules, March 1,, unless otherwise specified 2004 (Other than those specified in the relevant Notifications) New rates of Customs Duty March 1, New rates of Excise Duty March 1, [Retrospective amendments shall have the force of law only upon enactment of the Finance Bill, but with effect from the specific date indicated] Krishi Kalyan Cess Wef 01/06/ 3 S.K.KANODIA & ASSOCIATES
UNION BUDGET CENTRAL EXCISE A. LEGISLATIVE CHANGES 1. Amendments to Central Excise Rules, 2002 The following amendments have been made in the CE Rules, 2002: SL. SECTIO NO. N/RULE 1 rule 7, for sub-rule (4) of central excise rules 2 rule 8, in the DETAIL BEFORE AMENDMENT The assessee shall be liable to pay interest on any amount payable to Central Government, consequent to order for final assessment under sub-rule (3), at the rate specified by the Central Government by notification issued under section 11AA [ * * * * ] of the Act from the first day of the month succeeding the month for which such amount is determined, till the date of payment thereof. For the purposes of this proviso, it is hereby AFTER AMENDMENT W.E.F REMAR KS The assessee shall be liable to 1 st March The pay interest on any amount paid process or payable on the goods under for provisional assessment, but not calculati paid on the due date specified on of under sub-rule (1) of rule 8 and interest the first proviso thereto, as the in case of case may be, at the rate provision specified by the Central al Government, vide, notification assessme under section 11AA of the Act, nt has for the period starting with the been first day after the due date till overhaul the date of actual payment, ed and it whether such amount is paid will be before or after the issue of calculate order for final assessment. d form (Substituted) the due date of payment of duty till the date of actual For the removal of doubts, it is hereby clarified that,- 1 st April payment. New SSI limits for 4 S.K.KANODIA & ASSOCIATES
UNION BUDGET second proviso, for Explanati on -1 3 rule 11, in subrule (8), in the proviso clarified that an assessee shall be eligible, if his aggregate value of clearances of all excisable goods for home consumption in the preceding financial year, computed in the manner specified in the said notification, did not exceed rupees four hundred lakhs. An invoice issued under this rule by a manufacturer may be authenticated by means of a digital signature. Provided that where the duplicate copy of the invoice meant for transporter is digitally signed, a hard copy of the duplicate copy of the (a) an assessee, engaged in the manufacture or production of articles of jewellery, other than articles of silver jewellery but inclusive of articles of silver jewellery studded with diamond, ruby, emerald or sapphire, falling under chapter heading 7113 of the First Schedule of the Tariff Act shall be eligible, if his aggregate value of clearances of all excisable goods for home consumption in the preceding financial year, computed in the manner specified in the said notification, did not exceed rupees twelve crore; (b) an assessee, other than (a) above, shall be eligible, if his aggregate value of clearances of all excisable goods for home consumption in the preceding financial year, computed in the manner specified in the said notification, did not exceed rupees four hundred lakhs. (Substituted) An invoice issued under this rule by a manufacturer may be authenticated by means of a digital signature. Provided that where the duplicate copy of the invoice meant for transporter is digitally signed, a hard copy of the duplicate copy of the invoice meant for transporter shall be used for transport of 1 st April, certain classes of jewellery manufact urers have been prescribe d. The self assesstati on the duplicate copy of invoice has been done away with of it is 5 S.K.KANODIA & ASSOCIATES
UNION BUDGET 4 rule 12, sub rule (2) invoice meant for transporter and selfattested by the manufacturer shall be used for transport of goods (a) Notwithstanding anything containing in subrule (1), every assessee shall submit to the Superintendent of Central Excise, an Annual Financial Information Statement for the preceding financial year to which the statement relates in the form specified by notification by the Board by 30th day of November of the succeeding year. (b) The Central Government may, by notification, and subject to such conditions or limitations as may be specified in such notification, specify assessee or class of assessees who may not require to submit such an Annual Financial Information Statement.] goods (a) Notwithstanding anything containing in sub-rule (1), every assessee shall submit to the Superintendent of Central Excise, an Annual Return for the preceding financial year to which the return relates in the form specified by notification by the Board by 30th day of November of the succeeding year. (b) The Central Government may, by notification, and subject to such conditions or limitations as may be specified in such notification, specify assessee or class of assessees who may not require to submit such an Annual Return.] (c) The provision of this sub-rule and clause (b) of subrule (8) shall mutatis mutandis apply to a hundred per cent. Export- Oriented Unit. 1 st April, digitally signed. Returns for CE assessee has been overhaule d and only one extra return i.e. Annual Return other than monthly return for manufact ure and removal of goods has been prescribe d. 5 rule 12, sub rule (a) Every assessee shall submit to the OMITTED 1 st April, Annual Installed 6 S.K.KANODIA & ASSOCIATES
UNION BUDGET (2A) 6 Rule 12, in subrule (6) Superintendent of Central Excise, an Annual Installed Capacity Statement declaring the annual production capacity of the factory for the financial year to which the statement relates in the form specified by notification by the Board by 30th day of April of the succeeding financial year : Provided that for the year 2007-08, the said statement shall be furnished by 31st day of October, 2008. (b) The Central Government may, by notification, and subject to such conditions or limitations as may be specified in such notification, specify assessee or class of assessees who may not require to submit such an Annual Installed Capacity Statement.] Where any return or Annual Financial Information Statement or Annual Installed Capacity Statement referred to in this rule is submitted by the assessee after due date as specified for every return or statements, the Where any return referred to in this rule is submitted by the assessee after due date as specified for every return or statements, the assessee shall pay to the credit of the Central Government, an amount calculated at the rate of one hundred rupees per day 1 st April, Capacity Statement done away with. 7 S.K.KANODIA & ASSOCIATES
UNION BUDGET assessee shall pay to the credit of the Central Government, an amount calculated at the rate of one hundred rupees per day subject to a maximum of twenty thousand rupees for the period of delay in submission of each such return or statement.] subject to a maximum of twenty thousand rupees for the period of delay in submission of each such return or statement.] 7 Rule 12, in subrule (8) INSERTED An assessee, who has filed a return in the form referred to in sub-rule(1) within the date specified under that sub-rule or the second proviso thereto, may submit a revised return by the end of the calendar month in which the original return is filed. Explanation.- Where an assessee submits a revised return under clause (a), the relevant date for the purpose of recovery of Central Excise duty, if any, under section 11A of the Act shall be the date of submission of such revised return. (b) An assessee who has filed Annual Return referred to in clause (a) of sub-rule (2) by the due date mentioned in clause (a) of that sub-rule, may submit a revised return within a period of one month from the date of submission of the said Annual Return 1 st April, Provision of revised return for central excise assessees brought in. 8 S.K.KANODIA & ASSOCIATES
UNION BUDGET 8 Rule 17, in sub rule (7) 9 Rule 26, in sub rule (1), in the proviso INSERTED An assessee, who has filed a return in the form referred to in sub-rule (3) within the date specified under that sub-rule, may submit a revised return by the end of the calendar month in which the original return is filed. Explanation.- Where an assessee submits a revised return under this sub-rule, the relevant date for the purpose of recovery of Central Excise duty, if any, under section 11A of the Act shall be the date of submission of such revised return INSERTED Provided that where any proceeding for the person liable to pay duty have been concluded under clause (a) or clause (d) of sub-section (1) of section 11AC of the Act in respect of duty, interest and penalty, all proceedings in respect of penalty against other persons, if any, in the said proceedings shall also be deemed to be concluded. 1 st April, 1 st April, 9 S.K.KANODIA & ASSOCIATES
UNION BUDGET 2. Amendments to Central Excise Act, 1944 Section 11A is being amended so as to increase the period of limitation from one year to two years in cases not involving fraud, suppression of facts, willful mis-statement, etc. SKKA Comments The increase in normal period of limitation will have good impact as the department would have the powers to reopen the case without proving fraud or misstatement. On the hand of assessee, chance of lower penalty being levied in case of guilt will be helpful. Section 5A is being amended so as to omit the requirement of publishing and offering for sale any notification issued, by the Directorate of Publicity and Public Relations of CBEC. The Third Schedule is being amended so as to: a) make some editorial changes, consequent to 2017 Harmonized System of Nomenclature. b) include therein: 1) All goods falling under heading 3401 and 3402; 2) Aluminium foils of a thickness not exceeding 0.2 mm; 3) Wrist wearable devices (commonly known as smart watches ); and 4) Accessories of motor vehicle. The amendment at b) will come into effect immediately owing to a declaration under the Provisional Collection of Taxes Act, 1931. The Clean Energy Cess is being renamed as Clean Environment Cess. Also, the Tenth Schedule to the Finance Act, 2010 dealing with Clean Energy Cess is being amended so as to increase the Scheduled rate of Clean Energy Cess from Rs.300 per tonne to Rs.400 per tonne. The effective rate of Clean Energy Cess is being increased from Rs.200 per tonne to Rs.400 per tonne. SKKA Comments The power sector and chemical sector would be burdened by cost escalation by such increase. 10 S.K.KANODIA & ASSOCIATES
UNION BUDGET Infrastructure Cess is being levied on motor vehicles, of heading 8703, w.e.f. 01/03/2106, as under: b) Petrol/LPG/CNG driven motor vehicles of length not exceeding 4m and engine capacity not exceeding 1200cc 1% c) Diesel driven motor vehicles of length not exceeding 4m and engine capacity not exceeding 1500cc 2.5% d) Other higher engine capacity motor vehicles and SUVs and bigger sedans 4%. Three wheeled vehicles, Electrically operated vehicles, Hybrid vehicles, Hydrogen vehicles based on fuel cell technology, Motor vehicles which after clearance have been registered for use solely as taxi, Cars for physically handicapped persons and Motor vehicles cleared as ambulances or registered for use solely as ambulance will be exempt from this Cess. No credit of this Cess will be available, and credit of no other duty can be utilized for payment of this Infrastructure Cess. Registration of two or more premises as one registrant in Central Excise reg- Circular No. 1016/4/-CX Notification No. 36/2001-Central Excise (NT), dated 26.06.2001 has been amended vide Notification No. 19/-Central Excise(NT), dated 01.03. to provide that o if two or more premises of the same factory are located in a close area, o these premises are within the jurisdiction of a Central Excise Range and o the process undertaken there are interlinked and o the units are not operating under any of the area based exemption notifications, the Commissioner of Central Excise, may, subject to proper accountal of the movement of goods from one premise to other and such other conditions and limitations, as may be prescribed, allow single registration. Certificate evidencing payment of Central Excise duty-circular No. 1017/5/-CX The benefit of Boards circular 620/11/2002-CX, dated 20.02.2002 wherein facility of issuing of Certificate as proof of payment of Central Excise duty was extended to Small Scale Industry has been extended to all industries w.e.f. 01/03/. 11 S.K.KANODIA & ASSOCIATES
UNION BUDGET 3. Amendments to Central Excise Tariff S. Amendment No. A. Amendments not affecting rates of duty 1. Editorial changes in the Harmonized System of Nomenclature (HSN) in certain chapters are being incorporated in the First and Second Schedules, to be effective from 01.01.2017. 2. To: a) Amend supplementary notes (e) and (f) Chapter 27 so as to change the reference: i. from IS:1460:2000 to IS:1460:2005 for high speed diesel (HSD) and ii. from IS:1460 to IS: 15770:2008 for light diesel oil (LDO) b) Substitute Tariff line 5901 39 10 with description Warp pile fabrics, uncut in place of tariff line 5801 37 11 [with description Warp pile fabrics epingle uncut velvet] and 5801 37 19 [with description Warp pile fabrics epingle uncut other]; c) Prescribe separate tariff lines for laboratory created or laboratory grown or manmade or cultured or synthetic diamonds; d) Delete Tariff line 8525 50 50, relating to Wireless microphone. B. Amendments involving change in the rate of duty w.e.f. 01/03/ From To Aerated Beverages 1 Waters, including mineral waters and 18% 21% aerated waters, containing added sugar or other sweetening matter or flavoured Tobacco and Tobacco Products 2 Cigar and cheroots 12.5% or Rs.3375 12.5% or Rs.3755 per thousand, per thousand, whichever is higher whichever is higher 3 Cigarillos 12.5% or Rs.3375 12.5% or Rs.3755 per thousand, per thousand, whichever is higher whichever is higher 12 S.K.KANODIA & ASSOCIATES
UNION BUDGET 4 Cigarettes of tobacco substitutes Rs.3375 per Rs.3755 per thousand thousand 5 Cigarillos of tobacco substitutes 12.5% or Rs.3375 12.5% or Rs.3755 per thousand, per thousand, whichever is higher whichever is higher 6 Others of tobacco substitutes 12.5% or Rs.3375 12.5% or Rs.3755 per thousand, per thousand, whichever is higher whichever is higher 7 Gutkha, chewing tobacco (including filter 70% 81% khaini) and jarda scented tobacco 8 Unmanufactured tobacco 55% 64% 9 Paper rolled biris [whether handmade or Rs.30 per thousand Rs.80 per thousand machine made] and other biris [other than handmade biris] However, the effective rate of basic excise duty of Rs.21 per thousand shall remain unchanged. 10 Articles of Jewellery [excluding articles of silver jewellery, other than those studded with diamonds, ruby, emerald or sapphire]. NIL 1% (without Cenvat Credit) and 12.5% (with Cenvat Credit) 13 S.K.KANODIA & ASSOCIATES
UNION BUDGET CENVAT CREDIT RULES, 2004 The following changes have been introduced in the CCR, 2004: SECTIO N/RULE Rule 2, in sub clause (a) DETAIL BEFORE AMENDMENT capital goods means :- (A) the following goods, namely :- (i) all goods falling under Chapter 82, Chapter 84, Chapter 85, Chapter 90, [heading 6805, grinding wheels and the like, and parts thereof falling under heading 6804] of the First Schedule to the Excise Tariff Act;.. used (1) in the factory of the manufacturer of the final products, but does not include any equipment or appliance used in an office; or [(1A) outside the factory of the manufacturer of the final products for generation of electricity for captive use within the factory; or] AFTER AMENDMENT W.E.F REMARKS capital goods means :- (A) the following goods, namely :- (i) all goods falling under Chapter 82, Chapter 84, Chapter 85, Chapter 90, [heading 6805, grinding wheels and the like, and parts thereof falling under heading 6804 and wagons of sub-heading 860692] of the First Schedule to the Excise Tariff Act;.. ]used - (1) in the factory of the manufacturer of the final products; or [(1A) outside the factory of the manufacturer of the final products for generation of electricity or for pumping of water for captive use within the factory; or] w.e.f. 1 st April, Welcome change as appliance used in an office located within a factory has been included in definition of capital goods Rule 2, in sub clause (e) exempted service means a -.but shall not include a service which is exported in terms of rule 6A of the Service Tax Rules, exempted service means a -. but shall not include a service (a) which is exported in terms of rule 6A of the Service Tax Rules, w.e.f. 1 st April, Definition amended to bring in transport by vessel services. 14 S.K.KANODIA & ASSOCIATES
UNION BUDGET Rule 2, in sub clause (k) 1994.] 1994; or (b) by way of transportation of goods by a vessel from customs station of clearance in India to a place outside India; input means..- (iii) all goods used for generation of electricity or steam for captive use; or (i) all goods used for providing any output service; but excludes. (C) capital goods except when used as parts or components in the manufacture of a final product; input means.. - (iii) all goods used for generation of electricity or steam or pumping of water for captive use; or (iv) all goods used for providing any output service, or; (v) all capital goods which have a value upto ten thousand rupees per piece but excludes - (C) capital goods, except when,- (i) used as parts or components in the manufacture of a final product; or (ii) the value of such capital goods is upto ten thousand rupees per piece; w.e.f. 1 st April, This would allow shipping lines to take credit on inputs and Page 31 of 38 input services used in providing the said service Rule 2, in sub clause (m) input service distributor means an office of the manufacturer or producer of final products or provider of output service, which receives invoices issued under rule input service distributor means an office of the manufacturer or producer of final products or provider of output service, which receives invoices issued under w.e.f. 1 st April, 15 S.K.KANODIA & ASSOCIATES
UNION BUDGET Rule 3, in sub-rule (4), in the fifth proviso Rule 3, in sub-rule (4), in the ninth proviso Rule 4, sub-rule (2), in clause (a), for the Explanati on 4A of the Service Tax Rules, 1994 towards pur-chases of input services and issues invoice, bill or, as the case may be, challan for the purposes of distributing the credit of service tax paid on the said services to such manufacturer or producer or provider, as the case may be Provided also that the CENVAT credit of any duty specified in subrule (1), except the National Calamity Contingent duty in item (v) thereof, shall not be utilized for payment of the said National Calamity Contingent duty on goods falling under tariff items 8517 12 10 and 8517 12 90 respectively of the First Schedule of the Central Excise Tariff INSERTED For the removal of doubts, it is hereby clarified that an assessee shall be eligible if his aggregate value of clearances of all excisable goods for home consumption in the preceding financial year computed in the manner specified in the said notification did not exceed rupees four hundred lakhs.] rule 4A of the Service Tax Rules, 1994 towards pur-chases of input services and issues invoice, bill or, as the case may be, challan for the purposes of distributing the credit of service tax paid on the said services to such manufacturer or producer or provider or an oursourced manufacturing unit, as the case may be Provided also that the CENVAT credit of any duty specified in sub-rule (1), except the National Calamity Contingent duty in item (v) thereof, shall not be utilized for payment of the National Calamity Contingent duty leviable under section 136 of the Finance Act, 2001 (14 of 2001) Provided also that CENVAT credit shall not be utilised for payment of Infrastructure Cess leviable under sub-clause (1) of clause 159 of the Finance Bill, For the removal of doubts, it is hereby clarified that- (i) an assessee engaged in the manufacture of articles of jewellery, other than articles of silver jewellery but inclusive of articles of silver jewellery studded with diamond, ruby, emerald or sapphire, falling under chapter heading 7113 of the First Schedule of the Excise 1 st March 1 st March 1 st March 16 S.K.KANODIA & ASSOCIATES
UNION BUDGET Rule 4, sub-rule (5), in clause (b) The CENVAT credit shall also be allowed in respect of jigs, fixtures, moulds and dies sent by a manufacturer of final products to, - (i) another manufacturer for the production of goods; or (ii) a job worker for the production of goods on his behalf, according to his specifications. Tariff Act, shall be eligible, if his aggregate value of clearances of all excisable goods for home consumption in the preceding financial year, computed in the manner specified in the said notification, did not exceed rupees twelve crore; (ii) an assessee, other than (a) above, shall be eligible, if his aggregate value of clearances of all excisable goods for home consumption in the preceding financial year, computed in the manner specified in the said notification, did not exceed rupees four hundred lakhs (substituted) The CENVAT credit shall also be allowed to a manufacturer of final products in respect of jigs, fixtures, moulds and dies or tools falling under Chapter 82 of the First Schedule to the Excise Tariff Act, sent by such manufacturer to, - (i) another manufacturer for the production of goods; or (ii) a job worker for the production of goods on his behalf, according to his specifications: Provided that such credit shall also be allowed where jigs, fixtures, moulds and dies or tools falling under Chapter 82 of the First Schedule to the Excise Tariff Act, are sent by the w.e.f. 1 st April, It is also being provided that a manufacture r can send these goods directly to such other manufacture r or jobworker without bringing the same to his premises 17 S.K.KANODIA & ASSOCIATES
UNION BUDGET Rule 4, sub-rule (6) The [Deputy Commissioner of Central Excise or the Assistant Commissioner of Central Excise, as the case may be,] having jurisdiction over the factory of the manufacturer of the final products who has sent the input or partially processed inputs outside his factory to a job-worker may, by an order, which shall be valid for a financial year, in respect of removal of such input or partially processed input, and subject to such conditions as he may impose in the interest of revenue including the manner in which duty, if leviable, is to be paid, allow final products to be cleared from the premises of the job-worker. manufacturer of final products to the premises of another manufacturer or job worker without bringing these to his own premises. (substituted) The [Deputy Commissioner of Central Excise or the Assistant Commissioner of Central Excise, as the case may be,] having jurisdiction over the factory of the manufacturer of the final products who has sent the input or partially processed inputs outside his factory to a jobworker may, by an order, which shall be valid for three financial years, in respect of removal of such input or partially processed input, and subject to such conditions as he may impose in the interest of revenue including the manner in which duty, if leviable, is to be paid, allow final products to be cleared from the premises of the job-worker. w.e.f. 1 st April, Presently, the permission given by an Assistant Commission er or Deputy Commission er to a manufacture r of the final products for sending inputs or partially processed inputs outside his factory to a job-worker and clearance there from on payment of duty is valid for a financial year. It is being provided that the same would be valid for three 18 S.K.KANODIA & ASSOCIATES
UNION BUDGET Rule 4, sub-rule (7), sixth proviso Rule 9, in sub rule (1), clause (a) INSERTED an invoice issued by - (i) a manufacturer for clearance of - Provided also that CENVAT Credit of Service Tax paid on the charges paid or payable for the service provided by way of assignment, by the Government or any other person, of the right to use any natural resource, shall be spread over such period of time as the period for which the right to use has been assigned. an invoice issued by - (i) a manufacturer or a service provider for clearance of w.e.f. 1 st April, w.e.f. 1 st April, financial years Rule 14, Sub rule (2) For the purposes of sub-rule (1), all credits taken during a month shall be deemed to have been taken on the last day of the month and the utilisation thereof shall be deemed to have occurred in the following manner, namely: - (i) the opening balance of the month has been utilised first; (ii) credit admissible in terms of these rules taken during the month has been utilised next; (iii) credit inadmissible in terms of these rules taken during the month has been utilised thereafter.] OMITTED w.e.f. 1 st April, The existing sub- rule (2) of rule 14 prescribes a procedure based on FIFO method for determining whether a particular credit has been utilized. The said sub-rule is being omitted. Other Changes in Cenvat Credit rules, 2004 19 S.K.KANODIA & ASSOCIATES
UNION BUDGET SKKA Comments o Rule 6 of Cenvat Credit Rules, which provides for reversal of credit in respect of inputs and input services used in manufacture of exempted goods or for provision of exempted services, is being redrafted with the objective of simplifying and rationalizing the same without altering the established principles of reversal of such credit w.e.f. 01/04/ A very welcome amendment to limit the reversal to the extent of cenvat credit availed. Recently, the MUMBAI CESTAT in case of Mercedes Benz had given a ruling on the same ground. A very important change in cenvat credit rules. o Rule 7 relating to input service distributor has been amended to provide facility to transfer input services credit to outsourced manufacturers, under certain circumstances w.e.f. 01/04/ o Notification No. 27/2012 C.E. (N.T.) is being amended so as to provide that time limit for filing application for refund of Cenvat Credit under Rule 5 of the Cenvat Credit Rules, 2004, in case of export of services, shall be 1 year from the date of (a) receipt of payment in convertible foreign exchange, where provision of service has been completed prior to receipt of such payment; or (b) the date of issue of invoice, where payment for the service has been received in advance prior to the date of issue of the invoice DISCLAMER: UNION BUDGET - HIGHLIGHTS IS MEANT FOR INFORMATIONAL PURPOSE ONLY AND DOES NOT PURPORT TO BE ADVCIE OR OPINION, LEGAL OR OTHERWISE WHATSOEVER. THE INFORMATION PROVIDED IS NOT INTENDED TO CREATE A CONSULTANT- CLIENT RELATIONSHIP AND NOT FOR ADVERTISING OR SOLICITING. SKKA DOES NOT INTEND TO ADVERTISE ITS SERVICES OR SOLICIT WORK THROUGH THIS NEWSLETTER. SKKA IS NOT RESPONSIBLE FOR ANY ERROR OR OMMISSIONIN THIS NEWSLETTER. THE VIEWS EXPRESSED IN THE ARTICLES IN THIS NEWSLETTER ARE PERSONAL VEIWS OF THE AUTHORS. 20 S.K.KANODIA & ASSOCIATES
UNION BUDGET 21 S.K.KANODIA & ASSOCIATES