Feedback   New User   Login      
Tax Management India. Com TMI - Tax Management India. Com
Acts / Rules Notifications Circulars Tariff/ ITC HSN Forms Case Laws Manuals Short Notes Articles SMS News Highlights
        Home        
Extracts
Home List
← Previous Next →

M/s. Marks Shipping Pvt. Ltd. Mumbai Versus ACIT –Circle-4 (2) Mumbai

2015 (7) TMI 801 - ITAT MUMBAI

Validity of reopening of assessment - assessee set off unabsorbed depreciation for the AY.1994-95 amounting to ₹ 25.81 crores in the AY.2004-05 - Held that:- There is no doubt the reassessment notice was issued after four years for AY under appeal, that the provisions of proviso to section 147 were applicable to the case,that the AO had not mentioned that the failure of the assessee to disclose the relevant and material facts led to under assessment or escapement of income for the assessme .....

X X X X X X X

Extract - Part text only
Click here to Access Full Contents

X X X X X X X

im were applicable to the facts of the case under appeal.In these circumstances,in our opinion,the order of the FAA is not a speaking order.He had not dealt with the objections raised by the assessee.As the basis for endorsing the reopening after four years is missing,so,we are reversing his order.We hold that the order passed by the AO and upheld by the FAA was not a valid order,as the twin conditions of reopening of the matter,after a period of four years,were missing.Effective ground of appea .....

X X X X X X X

Extract - Part text only
Click here to Access Full Contents

X X X X X X X

uted item.It is not the case of the AO or the FAA that material was not available at the time of the original assessment.The AO has reviewed his original order and in our opinion in the reassessment proceedings it is not permissible. See M/s. OHM Stock Brokers Pvt. Ltd. Versus Commissioner of Income Tax-4, Mumbai and another [2013 (3) TMI 200 - BOMBAY HIGH COURT] - Decided in favour of assessee. - ITA No.6363, 6364, 6365 and 6366/Mum/2013,ITA No.17, 18, 19 and 20/Mum/2014 - Dated:- 22-7-2015 - S .....

X X X X X X X

Extract - Part text only
Click here to Access Full Contents

X X X X X X X

u/s. 148 on a change of opinion - Re-assessment Order may be quashed i) The ld. CIT(A) erred in treating the issue of notice u/s. 148 as proper without appreciating that during original scrutiny assessment, entire materials pertaining to the issue as per reasons were furnished before the Assessing Officer who had duly applied his mind and infact considered the same claim while making disallowance u/s. 14A; therefore, in the absence of' any allegation that there was no true and full disclosu .....

X X X X X X X

Extract - Part text only
Click here to Access Full Contents

X X X X X X X

ppellant; therefore, the notice issued u/s. 148 does not have the mandate of law and may, therefore, be treated as voidabinitio. iii) Without prejudice to above, the notice u/s. 148 cannot be issued to make roving and fishing enquiries or to complete an unfinished task as possibly been left out during original scrutiny assessment proceedings. 2. Disallownce u/s.36(1)(ii)Rs. 26,47,146/on account of alleged nonallowable commission payment (Rs.16,87,146/) to the Directors: i) The ld. Commissioner o .....

X X X X X X X

Extract - Part text only
Click here to Access Full Contents

X X X X X X X

olding purely in terms of appointment against the services rendered is outside the scope of Sec. 36(1 )(ii); thus the same cannot be attributed as distribution of dividend or profits in the guise of commission. As the payments have direct nexus to the services rendered, Sec. 36(1)(ii) has no role to play under the circumstances and the disallowance may be deleted. iii) The ld.. CIT(A) erred in confirming even the payment of remuneration of ₹ 9,60,000/paid to Directors as includible while m .....

X X X X X X X

Extract - Part text only
Click here to Access Full Contents

X X X X X X X

Notice u/s. 148 on a change of opinion Reassessment Order may be quashed i) The ld.CIT(A) erred in treating the issue of notice u/s. 148 as proper without appreciating that during original scrutiny assessment, entire materials pertaining to the issue as per reasons were furnished before the Assessing Officer who had duly applied his mind and infact considered the same claim while making disallowance u/s. 14A; therefore, in the absence of any allegation that there was no true and full disclosure .....

X X X X X X X

Extract - Part text only
Click here to Access Full Contents

X X X X X X X

; therefore, the notice issued u/s. 148 does not have the mandate of law and may, therefore, be treated as voidabinitio. iii) Without prejudice to above, the notice u/s. 148 cannot be issued to make roving and fishing enquiries or to complete an unfinished task as possibly been left out during original scrutiny assessment proceedings. 2. Disallowance u/s. 36(1)(ii) ₹ 29,44.544/on account. of alleged nonallowable Commission payment (Rs. 18,64,544/) to the Directors i) The ld. CIT(A) erred i .....

X X X X X X X

Extract - Part text only
Click here to Access Full Contents

X X X X X X X

ointment against the services rendered is outside the scope of Sec. 36(1) (ii); thus the same cannot be attributed as distribution of dividend or profits in the guise of commission. As the payments have direct nexus to the services rendered, Sec. 36(1)(ii) has no role to play under the circumstances and the disallowance may be deleted. iii) The ld. CIT(A) erred in confirming even the payment of remuneration of ₹ 10,80,000/paid to Directors as includible while making disallowance u/s.36(1 ) .....

X X X X X X X

Extract - Part text only
Click here to Access Full Contents

X X X X X X X

ment, entire materials pertaining to the issue as per reasons were furnished before the Assessing Officer who had duly applied his mind and infact considered the same claim while making disallowance u/s. 14A; therefore, in the absence of' any allegation that there was no true and full disclosure of material facts by the Appellant, the jurisdiction acquired through the issue of notice u/s. 148 becomes defective and untenable for being tainted with a change of opinion and the Order may, conseq .....

X X X X X X X

Extract - Part text only
Click here to Access Full Contents

X X X X X X X

the notice u/s. 148 cannot be issued to make roving and fishing enquiries or to complete an unfinished task as possibly been left out during original scrutiny assessment proceedings. 2. Disallowance u/s.36(1)(ii)Rs. 35,65,588/on account of alleged nonallowable Commission payment (Rs.22,45,588/) to the Directors: i) The ld. Commissioner of Income tax(Appeals) erred in confirming the disallowance without appreciating that the appellant had, after complying to the enabling conditions, paid commiss .....

X X X X X X X

Extract - Part text only
Click here to Access Full Contents

X X X X X X X

of dividend or profits in the guise of commission. As the payments have direct nexus to the services rendered, Sec.36(1 )(ii) has no role to play under the circumstances and the disallowance may be deleted. iii) The Id. CIT(A) erred in confirming even the payment of remuneration of ₹ 13,20,000/paid to Directors as includible while making disallowance u/s.36(1 )(ii). 3. Levy of Penal Interest u/s. 234A, 2348, 234C and 234D The Appellant, on merits, denies its liability to penal interest. 4. .....

X X X X X X X

Extract - Part text only
Click here to Access Full Contents

X X X X X X X

d infact considered the same claim while making disallowance u/s. 14A; therefore, in the absence of any allegation that there was no true and full disclosure of material facts by the Appellant, the jurisdiction acquired through the issue of notice u/s. 148 becomes defective and untenable for being tainted with a change of opinion and the Order may, consequently, be quashed. ii) The ld. CIT(A) ought to have appreciated that the notice u/s. 148 issued even within four years time has to have the su .....

X X X X X X X

Extract - Part text only
Click here to Access Full Contents

X X X X X X X

sessment proceedings. 2. Disallowance u/s. 36(1)(ii) ₹ 65,23,182/on account. of alleged nonallowable Commission payment (Rs.23,23,182/) to the Directors i) The ld. CIT(A) erred in confirming the disallowance without appreciating that the Appellant had, after complying to the enabling conditions, paid commission to two of its directors in particular against their full time rendering of services; thus the disallowance is uncalled for as the said payment is no an appropriation of profits or a .....

X X X X X X X

Extract - Part text only
Click here to Access Full Contents

X X X X X X X

owance may be deleted. iii) The ld. CIT(A) erred in confirming even the payment of remuneration of ₹ 42,00,000/paid to Directors as includible while making disallowance u/s.36(1 )(ii). 3. Levy of Penal Interest u/s. 234A, 2348, 234C and 234D The Appellant, on merits, denies its liability to penal interest. 4. The Appellant craves leave to add, amend or alter all or any of the above Grounds of Appeal. ITA/17/MUM/2014-AY.2005-06: 1. On the facts and in the circumstances of the case and in la .....

X X X X X X X

Extract - Part text only
Click here to Access Full Contents

X X X X X X X

cessary. ITA/18/MUM/2014-AY.2006-07: 1. On the facts and in the circumstances of the case and in law,the Ld.CIT(A) was not justified in directing the A.O. to verify and allow the remuneration to the directors which was not segregated from commission in the Tax Audit report and Director's report. 2.On the facts and in the circumstances of the case and in law,the impugned order of the Ld.CIT(A)is contrary to law and consequently merits to be set aside and that of the Assessing Officer be resto .....

X X X X X X X

Extract - Part text only
Click here to Access Full Contents

X X X X X X X

contrary to law and consequently merits to be set aside and that of the Assessing Officer be restored. 3. The appellant craves leave to amend or alter any ground or add a new ground which may be necessary. ITA/20/MUM/2014-AY.2008-09: 1. On the facts and in the circumstances of the case and in law,the Ld.CIT(A) was not justified in directing the A.O. to verify and allow the remuneration to the directors which was not segregated from commission in the Tax Audit report and Director's report. 2 .....

X X X X X X X

Extract - Part text only
Click here to Access Full Contents

X X X X X X X

47 order date Assessed income 2005-06 Rs.94,68,428/- Rs.1,01,65,220/- 30.3.2012 Rs.1,28,22,366/- 2006-07 Rs.2,21,56,072/- Rs.2,84,00,300/- 30.3.2012 Rs.3,13,19,513/- 2007-08 Rs.1,96,23,610/- Rs.2,14,16,810/- 30.3.2012 Rs.2,49,82,398/- 2008-09 Rs.2,56,73,217/- Rs.2,80,41,580/- 30.3.2012 Rs.3,45,64,762/- ITA/6363/MUM/2013: 2.First we will take the appeal for the AY.2005-06.Assessee-company engaged in the business of custom clearing agency filed its return of income on 31.10.2005,declaring income o .....

X X X X X X X

Extract - Part text only
Click here to Access Full Contents

X X X X X X X

at the assessee has paid Directors Remuneration of ₹ 26,57,146/to Directors. In the AY 200910, the assessing officer found that this payment made to Directors includes commission payment. Therefore, this commission was added u/s. 36(1)(iii). As per section(1)(ii), only such commission payments are allowed as expenditure as any sum paid to an employee as bonus or commission for services rendered, where such sum would not have been payable to him as profits or dividend, if it had not been pa .....

X X X X X X X

Extract - Part text only
Click here to Access Full Contents

X X X X X X X

e to tax has escaped the assessment. Issue notice u/s.148 of the IT Act after seeking prior approval of CIT4, Mumbai vide letter No. ……….. as required u/s. 151 of the Income tax Act, 1961. He passed an order u/s.143(3)r.w.s.147 of the Act on 22.03.2013 computing the income of the assessee at ₹ 1.28 Crores. 3.Aggrieved by the order of the AO,the assessee preferred an appeal before the First Appellate Authority(FAA).Before him it was argued that reopening was result of c .....

X X X X X X X

Extract - Part text only
Click here to Access Full Contents

X X X X X X X

basis of the assessment passed for the AY.2009-10 by invoking the provisions of section 36(1)(vii)of the Act and by relying upon the decision of the special bench delivered in the case of Dalal Broacha Stock Brokers Pvt.Ltd.(140TTJ129),that details of salary and commission payment was furnished to the AO in all the AY.s.from AY.1995-96,that notice for reopening was issued after four years,that income had not escaped taxation because of the failure of the assessee.The assessee relied upon the ca .....

X X X X X X X

Extract - Part text only
Click here to Access Full Contents

X X X X X X X

holders of the company,that remuneration included commission payment, that commission payment was in violation to section 36(1)(ii),that the AO had issue notice after four years,that the assessee had raised objections about issue of notice u/s.148,that the AO had dismissed the objections raised by the assessee following the decision of Kalyanji Mavji & Co. (102ITR287).He referred to the cases of Praful Chunilal Patel(148CTR62),Citibank N A (179 CTR124),Indo Adan Salt Mfg. & Trading Co.( .....

X X X X X X X

Extract - Part text only
Click here to Access Full Contents

X X X X X X X

s was not linked to any extra services rendered by them in due course of their duties,that the payment was apparently in lieu of the dividend and is a device to avoid payment of full tax,that the commission paid to the directors is not allowable u/s. 36(1)(ii) or 37 of the Act.As regards to the merit of the addition of commission u/s. 36(1)(ii),he observed that the AO had treated the entire payment made to the directors as commission,that the payment has been made in respect of both the salary a .....

X X X X X X X

Extract - Part text only
Click here to Access Full Contents

X X X X X X X

the remuneration was allowable to the directors and secondly whether these remuneration were within the limit prescribed by the Companies Act.He held that if the directors were allowed remuneration as per the Company's Resolution and was within the limit prescribed by the Companies Act,the remuneration could be allowed as eligible deduction. 4.Before us,the Authorised Representative argued that the fact that in AY 2009-10 similar claim had been disallowed was not adequate for re-opening the .....

X X X X X X X

Extract - Part text only
Click here to Access Full Contents

X X X X X X X

nt details regarding payment to the directors was made by the AO, that the payment made to the director was the subject matter of discussion when the disallowance u/s. 14A was made by the AO, relying upon later year s decisions amounted to change of opinion.He referred to directors report. He further argued that the payment of commission was against the services rendered by directors, that similar payment of commission and remuneration had been allowed since 1995-96 on a continuous basis under s .....

X X X X X X X

Extract - Part text only
Click here to Access Full Contents

X X X X X X X

d the true facts about the commission paid to the directors, that there was no change of opinion, that the reopening was valid. 5.a.We have heard the rival submissions and perused the material before us.Before proceeding further,we would like to mention certain principles that govern the re-opening of assessment u/s. 147 of the Act and same can be summarised as under: i.The twin conditions required for reopening an assessment beyond the period of four years are that there must be reason to belie .....

X X X X X X X

Extract - Part text only
Click here to Access Full Contents

X X X X X X X

sessee to disclose fully and truly all material facts necessary for its assessment for the assessment year under consideration, the assumption of jurisdiction under section 147 of the Act would be invalid. ii.For the AO to invoke the provisions of section 147 of the Act,there must be material facts based on some reasonable belief which would have a material bearing on the question of under - assessment. iii.As long as it can be demonstrated that both the conditions were satisfied and that there .....

X X X X X X X

Extract - Part text only
Click here to Access Full Contents

X X X X X X X

tisfied on the reasons recorded by the AO.Circular No. 1 of 2009, dated 27.03.2009 stipulates that the Joint Commissioner is only required to be satisfied on the reasons recorded by the AO and no notice is required to be issued by him.Courts have held that to avoid allegations of non-application of mind all that is desirable is that the Joint Commissioner should briefly state his reasons. vi.Just because he has approved the proposal of the AO by writing yes to the reasons recorded,the notice of .....

X X X X X X X

Extract - Part text only
Click here to Access Full Contents

X X X X X X X

be an outcome of a change of opinion. Consequently, before taking any action,he is required to substantiate his satisfaction in the reasons recorded by him. If such reasons recorded disclose a mere change of opinion the assessment proceedings cannot be initiated. viii.Once the AO has made an assessment on the primary facts and documents placed before him, he cannot at another point of time form another opinion on the same primary facts and arrive at a conclusion that he had committed an error or .....

X X X X X X X

Extract - Part text only
Click here to Access Full Contents

X X X X X X X

.b.1.We would also like to refer to three judgments dealing with the issue.First of them is matter of Ohm Stock Brokers Pvt.Ltd.(351 ITR 443) of the Hon ble Mumbai High Court.Facts of the case were that the assessee,for the AY.s.2005-06 and 2006-07,had by letters dated 12.03.2007, and 31.08.2007 placed on the record before the AO the nature of payments, the agreements with the two directors in pursuance of which they were paid a fixed monthly remuneration and a commission/performance bonus repre .....

X X X X X X X

Extract - Part text only
Click here to Access Full Contents

X X X X X X X

ommission.Deciding the writ petitions,the Hon ble Court held as under: Under the proviso to section 147 of the Incometax Act, 1961, where an assessment has been completed under section 143(3) ,the validity of reopening it beyond four years of the end of the relevant assessment year is preconditioned by the requirement that there is a failure on the part of the assessee to fully and truly disclose material facts necessary for the assessment for that assessment year. There must be a failure on the .....

X X X X X X X

Extract - Part text only
Click here to Access Full Contents

X X X X X X X

essing Officer must have reason to believe that income has escaped the assessment. At the same time, the Assessing Officer is not conferred with the power to review an assessment and he cannot reopen an assessment only because of a mere change in the opinion. The Assessing Officer must, in other words, have tangible material to come to the conclusion that there is escapement of income... that the Assessing Officer had stated that a payment made to a shareholder would not be covered by section 36 .....

X X X X X X X

Extract - Part text only
Click here to Access Full Contents

X X X X X X X

ent years 200506 and 200607 did not fulfil the requirement set out in the proviso to section 147 and the notices of reopening would accordingly have to be quashed and set aside..... ......the mere fact that the order of assessment did not specifically deal with the issue as to whether the payment fell within the purview of section36(1)(ii)was not dispositive. The test is as to whether the assessee had furnished to the Assessing Officer all the primary facts on the basis of which a deduction was .....

X X X X X X X

Extract - Part text only
Click here to Access Full Contents

X X X X X X X

f the fixed monthly remuneration and in addition to the payment of commission which was computed at a stipulated proportion of the net profits. The assessee explained the basis on which a decision was taken to make the payment of commission at a fixed monthly remuneration and the rest at a proportion of the net profits. According to the assessee, this decision was based on the volatility of the stock market and having regard to the fact that the income of the assessee from share business had red .....

X X X X X X X

Extract - Part text only
Click here to Access Full Contents

X X X X X X X

36(1)(ii)were placed before the Assessing Officer. The order of assessment under section 143(3)accepted the claim on this issue. There was no dispute that the two directors had been assessed under section 143(3)on the amounts paid by the assessee to them. The Revenue had admittedly treated the amounts paid to the directors as salary income in their hands and their assessments had been completed accordingly. Therefore, the reopening of the assessments for the assessment year 200708 must be held t .....

X X X X X X X

Extract - Part text only
Click here to Access Full Contents

X X X X X X X

sessment may legitimately give rise to an inference of an escapement of income, before the Assessing Officer proceeds to reopen an assessment after the expiry of four years of the end of the relevant assessment year, he must none the less apply his mind to the fundamental question as to whether there has been a failure to disclose on the part of the assessee........ there was no allegation that the assessee had failed to disclose material facts necessary for assessment. Moreover, the return of i .....

X X X X X X X

Extract - Part text only
Click here to Access Full Contents

X X X X X X X

l held that unabsorbed depreciation for the period up to 1996-97 could be carried forward and set off against the income from any head for a maximum period of eight AY.s.Hence,according to the AO, the set off of unabsorbed depreciation for the AY. 1994-95 against the income of the AY.2004-05 was not in accordance with law and, consequently, income had escaped assessment. The second issue in relation to which the assessment was reopened was that while giving effect to the order of the Tribunal,in .....

X X X X X X X

Extract - Part text only
Click here to Access Full Contents

X X X X X X X

since the relevant income by way of diminution in the value of assets/investments which was required to be added back had not been brought to tax.The Hon ble Court held that the fundamental condition for reopening the assessment beyond a period of four years had not been fulfilled and that the notice was not valid and was liable to be quashed. 5.b.3.Lastly we would like to discuss the matter of Jagran Prakashan Ltd.(367ITR534) of Hon ble Allahabad High Court.In that matter the assessee was carr .....

X X X X X X X

Extract - Part text only
Click here to Access Full Contents

X X X X X X X

nder section 148 on the basis of the audit report. It was indicated that an amount of ₹ 1.2 crores had been disclosed as expenses under section 35A being one-fourteenth cost of ₹ 17 crores, which was the cost of copyright for the use for its business purposes, that the assessee permitted other companies to publish the Hindi newspaper without any consideration, that the assessee was not charging any amount on the use of the same copyright from these companies and, consequently, prima .....

X X X X X X X

Extract - Part text only
Click here to Access Full Contents

X X X X X X X

ere reasons to believe that income had escaped assessment for the assessment year 1997-98. On a writ petition the Hon ble High Court held as under: For the Assessing Officer to have reason to believe that there had been some omission or failure to disclose fully or truly all material facts necessary for the assessment there must be material facts based on some reasonable belief which would have a material bearing on the question of underassessment. If there is no material for the formation of an .....

X X X X X X X

Extract - Part text only
Click here to Access Full Contents

X X X X X X X

able to the Assessing Officer at the time of the completion of the original assessment. Reason to believe could never be an outcome of a change of opinion.Consequently,before taking any action, he is required to substantiate his satisfaction in the reasons recorded by him. If such reasons recorded disclose a mere change of opinion the assessment proceedings cannot be initiated. ………Once the Assessing Officer has made an assessment on the primary facts and documents placed bef .....

X X X X X X X

Extract - Part text only
Click here to Access Full Contents

X X X X X X X

s recorded by the Assessing Officer nowhere stated that there was a failure on the part of the assessee to disclose fully and truly all material facts necessary for the assessment for that assessment year. On the other hand, in proceedings under section 143(3) the assessee had disclosed all the primary facts relevant to the decision on the question of the consideration paid for purchase of copyright before the Assessing Officer. The Assessing Officer had made a detailed discussion and recorded a .....

X X X X X X X

Extract - Part text only
Click here to Access Full Contents

X X X X X X X

r at the time when the original assessment was made and the Assessing Officer had applied his mind to that material and accepted the contention canvassed by the assessee.The Assessing Officer had dealt with the audit report and justified his assessment order indicating in his order that the issue pertaining to deemed gift and the purchase consideration was examined in detail looking to the business necessity for the assessee to acquire the copyright and held that the quantum of purchase consider .....

X X X X X X X

Extract - Part text only
Click here to Access Full Contents

X X X X X X X

lure of the assessee to disclose the relevant and material facts led to under assessment or escapement of income for the assessment year under consideration.From the reasons recorded the belief of assessee in failure of the assessee is not emerging.The FAA has also not dealt with the issue at all.The operative part of this order reads as under: In view of the foregoing,I find that the issuance of notices u/s.148 by the AO is in order and no interference is therefore called for.This ground of app .....

X X X X X X X

Extract - Part text only
Click here to Access Full Contents

X X X X X X X

conditions of reopening of the matter,after a period of four years,were missing.Effective ground of appeal filed by the assessee is decided in its favour. As we have held that the assessment order for the AY.under appeal was not valid,therefore we are not adjudicating the second ground raised by the assessee. ITA./6364/Mum/2013-AY.2006-07: 6.Facts and circumstances of the case for the AY.under appeal are identical to the facts of the earlier AY.-the only difference is about the amount of commiss .....

X X X X X X X

Extract - Part text only
Click here to Access Full Contents

X X X X X X X

al is within the period of four years.The assessee had argued that the reopening was result of change of opinion.However,the FAA dismissed the appeal filed by the assessee on the similar reasons that have been narrated in the earlier part of our order. 8.Before us,the AR stated that the AO called for the details of directors remuneration for making disallowance u/s.14 A of the Act,that the assessee had supplied the necessary details to the AO,that he had applied his mind and had taken an informe .....

X X X X X X X

Extract - Part text only
Click here to Access Full Contents

X X X X X X X

sment of income of escapement of income.He referred to the cases that find place at para no.4 of our order. 9.We find that while completing the original assessment,the AO had called for information about commission payment and had considered it while computing the disallowance to be made under section 14A of the Act.At that time if he did not invoke the provisions of section 36(1)(ii)then it has to be presumed that he had applied his mind and had taken a conscious decision about the disputed ite .....

X X X X X X X

Extract - Part text only
Click here to Access Full Contents

X X X X X X X

rlier part of the order.Following the same,we hold that action taken by the AO u/s.147of the Act with regard to the commission payment made to the Director is invalid.Even on merits the issue is covered by the judgment of Ohm Stock Brokers Pvt.Ltd.(supra).We find that facts of the judgment are almost similar to the facts of the present appeal.Therefore,in our opinion,the order of the FAA has to be reversed.Effective ground of appeal is decided in favour of the assessee as we are of the opinion t .....

X X X X X X X

Extract - Part text only
Click here to Access Full Contents

X X X X X X X

 

 

 

 

 

Discussion Forum
what is new what is new
 


Share:            

|| Home || About us || Feedback || Contact us || Disclaimer || Terms of Use || Privacy Policy || TMI Database || Members ||

© Taxmanagementindia.com [A unit of MS Knowledge Processing Pvt. Ltd.] All rights reserved.

Go to Mobile Version