GST Helpdesk   Subscription   Demo   New User   Login      
Tax Management India .com
TMI - Tax Management India. Com
Extracts
Home List
← Previous Next →

2015 (12) TMI 563 - ITAT HYDERABAD

2015 (12) TMI 563 - ITAT HYDERABAD - TMI - Eligibility for deduction u/s 80IA - Held that:- Assessing Officer is not entitled, in the consequential proceedings, the scope of which is confined to giving effect to the order of the Tribunal, to sit in judgment over the view taken by the Tribunal on the issue in dispute, and if at all there is any grievance on account of the finding given by the Tribunal on the point at dispute, it should pursue the other appellate legal remedies provided in the sta .....

X X X X X X X

Extract - Part text only
Click here to Access Full Contents

X X X X X X X

percentage of completion method as mentioned in Accounting Standard (AS) – 7 ‘Construction Contracts’ notified by the Companies Accounting Standard Rules, 2006. Percentage of completion is determined on the basis of surveys performed. From the above, the profit generated by each project can be determined by applying the percentage of completion method under projects eligible for deduction u/s 80IA or non eligible projects. In our considered view, this cannot be the reason to deny the benefit to .....

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 time and also the projects are not time bound, it is impractical to present books of account on project wise and year wise. The method adopted by the assessee is based on the accounting standard approved by the ICAI. These standards are tested and proven method. Considering the above findings, we observe that assessee is following the proper method of accounting and appropriate books to claim deduction u/s 80IA of the Act. - Decided in favour of assessee. - ITA No. 1828/Hyd/2014 - Dated:- 4-12 .....

X X X X X X X

Extract - Part text only
Click here to Access Full Contents

X X X X X X X

n of income for the AY 2009-10, declaring total income of ₹ 26,89,66,421/- after claiming deduction u/s 80IA of ₹ 162,67,521/-. The scrutiny assessment was completed and the AO rejected the depreciation on building and rejected the deduction u/s 80IA of the Income-tax Act (in short Act). While rejecting the deduction u/s 80IA, AO observed as below: a) The assessee did not begin to operate the infrastructure facility dur ing the FY 2008-09 and hence cannot claim deduct ion u/s 80IA fo .....

X X X X X X X

Extract - Part text only
Click here to Access Full Contents

X X X X X X X

this tribunal had adjudicated in favour of the assessee for the similar findings of the AO in the earlier AYs 2005-06, 2006-07 and 2007-08 in ITA Nos. 269/hyd/2009, ITA No. 1165/H/09 and ITA No. 1171/Hyd/2010 respectively in the consolidated order dated 16/03/12 and for AY 2008-09 in ITA No. 414/Hyd/12 dated 17/06/13. 4. Aggrieved by the order of CIT(A), the revenue is in appeal before us raising the following grounds: 1. The learned CIT (A) erred in both in law and on facts of the case. 2. 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

A of the Act worked out on pro rata basis of turnover , though the assessee had not maintained separate books of accounts, more so specif ically in view of the Hon'ble Supreme Court judgment in the case of Ar isudhana Spinning Mills Ltd Vs CIT, Ludhiana (dated 05/09/12 5. Ld. DR relied on the order of AO. 6. Ld. AR submitted that the issue in dispute is covered in favour of the assessee by the decision of the Tribunal in assessee s own case for earlier AYs. 7. We have considered the argument .....

X X X X X X X

Extract - Part text only
Click here to Access Full Contents

X X X X X X X

ugh all the case laws cited by both the parties. We find that the provisions of Section 80IA (4) of the Act when introduced afresh by the Finance Act, 1999, the provisions under section 80IA (4A) of the Act were deleted from the Act. The deduction available for any enterpri se earlier under section 80IA (4A) are also made available under Section 80IA (4) itself. Further, the very fact that the legislature mentioned the words (i) "developing" or (ii) "operating and maintaining" .....

X X X X X X X

Extract - Part text only
Click here to Access Full Contents

X X X X X X X

essee, who enters into a contract with another person including Government or an undertaking or enterprise referred to in Section 80 IA of the Act, for executing works contract, will not be eligible for the tax benefit under section 80 IA of the Act. We find that the word "owned" in sub- clause (a) of clause (1) of sub section (4) of Section 80IA of the Act refer to the enterprise. By reading of the section, it is clears that the enterprises carrying on development of infrastructure de .....

X X X X X X X

Extract - Part text only
Click here to Access Full Contents

X X X X X X X

ccording to sub-clause (a), clause (i) of sub section (4) of Section 80-IA the word "it" denotes the enterprise carrying on the business. The word "it" cannot be related to the infrastructure facility, particularly in view of the fact that infrastructure facility includes Rail system, Highway project, Water treatment system, Irrigation project, a Port, an Airport or an Inland port which cannot be owned by any one. Even otherwise, the word "it" is used to denote an e .....

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 works contractor is purely depends on the nature of the work undertaken by the assessee. Each of the work undertaken has to be analyzed and a conclusion has to be drawn about the nature of the work undertaken by the assessee. The agreement entered into with the Government or the Government body may be a mere works contract or for development of infrastructure. It is to be seen from the agreements entered into by the assessee with the Government. We find that the Government handed over the poss .....

X X X X X X X

Extract - Part text only
Click here to Access Full Contents

X X X X X X X

ny loss to the public caused in the process would be the responsibility of the assessee. The assessee has to develop the infrastructure facility. In the process, all the works are to be executed by the assessee. It may be laying of a drainage system; may be construction of a project; provision of way for the cattle and bullock carts in the village; provision for traffic without any hindrance, the assessee's duty is to develop infrastructure whether it involves construction of a particular it .....

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 funds, its expertise, its employees and takes the responsibility of developing the infrastructure facility. The losses suffered either by the Govt. or the people in the process of such development would be that of the assessee. The assessee hands over the developed infrastructure facility to the Government on completion of the development. Thereafter, the assessee has to undertake maintenance of the said infrastructure for a period of 12 to 24 months. During this period, if any damages are occ .....

X X X X X X X

Extract - Part text only
Click here to Access Full Contents

X X X X X X X

contract but has to be considered as a development of infrastructure facility. Therefore, the assessee is a developer and not a works contractor as presumed by the Revenue. The circular issued by the Board, relied on by learned counsel for the assessee, clearly indicate that the assessee is eligible for deduction under section 80IA (4) of the Act. The department is not correct in holding that the assessee is a mere contractor of the work and not a developer. 34. We also find that as per the prov .....

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" is used to denote the person who enters into such contract. Even a person who enters into a contract for development of infrastructure facility is a contractor. Therefore, the contractor and the developer cannot be viewed differently. Every contractor may not be a developer but every developer developing infrastructure facility on behalf of the Government is a contractor. 35. We find that the decision relied on by the learned counsel for the assessee in the case of CIT vs. Laxmi Civil En .....

X X X X X X X

Extract - Part text only
Click here to Access Full Contents

X X X X X X X

he Act, intended to cover the entities carrying out developing, operating and maintaining the infrastructure facility keeping in mind the present business models and intend to grant the incentives to such entities. The CBDT, on several occasions, clarified that pure developer should also be eligible to claim deduction under section 80IA of the Act, which ultimately culminated into Amendment under section 80IA of the Act, in the Finance Act 2001, to give effect to the aforesaid circulars issued b .....

X X X X X X X

Extract - Part text only
Click here to Access Full Contents

X X X X X X X

inserted, certainly, to deny the tax holiday to the entities who does only mere works contact or sub-contract as distinct from the developer. This is clear from the express intension of the parliament while introducing the Explanation. The explanatory memorandum to Finance Act 2007 states that the purpose of the tax benefit has all along been to encourage investment in development of infrastructure sector and not for the persons who merely execute the civil construction work. It categorically 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

ase of B.T.Patil cited supra is prior to amendment to sec 80IA(4), after the amendment the section 80IA(4) read as (i) developing or (ii) operating and maintaining or (iii) developing, operating and maintaining any infrastructure facility, prior to amendment the "or" between three activities was not there, after the amendment "or" has been inserted w.e.f. 1-4-2002 by Finance Act 2001. Therefore, in our considered view, the assessee should not be denied the deduction under sec .....

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 profit from such contracts which involves development, operating, maintenance, financial involvement, and defect correction and liability period is to be computed by assessing officer on prorata basis of turnover. The assessing officer is directed to examine and grant deduction on eligible turnover as directed above. It is needless to say that in similar circumstances, similar view has been taken by the Chennai Bench of the Tribunal and deduction u/s. 80IA was granted in the case of M/s. Che .....

X X X X X X X

Extract - Part text only
Click here to Access Full Contents

X X X X X X X

orts, ports and rapid urban rail transport systems. For that purpose, private sector participation by way of investment in development of the infrastructure sector and not for the persons who merely execute the civil construction work or any other work contract has been encouraged by giving tax benefits. Thus the provisions of section 80IA shall not apply to a person who executes a works contract entered into with the undertaking or enterprise referred to in the section but where a person makes .....

X X X X X X X

Extract - Part text only
Click here to Access Full Contents

X X X X X X X

ated 29th February 2012 has taken similar view and granted deduction under section 80IA of the act. 37. Further, we make it clear that where the assessee has carried out the development of infrastructure work in Consortium and not as a subcontractor, then also the assessee is entitled for deduction u/s 80IA of the Act. The same is applicable in case of work allotted by Government Corporation/Government Bodies. 38. Further in the case of R.R. Constructions, the Chennai Bench of the Tribunal in it .....

X X X X X X X

Extract - Part text only
Click here to Access Full Contents

X X X X X X X

he business of (i) developing or (ii) operating and maintaining or (iii) developing, operating and maintaining any infrastructure facilities, which fulfil all the above conditions. There cannot be any question of providing a condition for such an enterprise to start operating and maintaining the infrastructure facility on or after 01.04.1995. From the assessment year 2000-01, deduction is available if the assessee is carrying out the business of any one of the above mentioned three types of acti .....

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 of infrastructure facility carried out by the assessee, it cannot be said that the assessee did not develop the infrastructure facility. If the interpretation done by the Assessing Officer is accepted, no enterprise carrying on the business of only developing he infrastructure facility would be entitled to deduction under section 80IA(4), which is not the intention of the law. An enterprise, who develop the infrastructure facility is not paid by the Government, the entire cost of developmen .....

X X X X X X X

Extract - Part text only
Click here to Access Full Contents

X X X X X X X

ason that he is not having the right/authorization to operate the infrastructure facility and to collect toll there from, has no other source of recoupment of his cost of development. While filing the return, the assessee had made claim under section 80IA(4) of the Act. 4. The assessee has also produced all six agreements regarding six projects undertaken before the Assessing Officer, whose copies are available before us also. It is a fact that even after taking a contract from the Government, 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

eveloper to claim exemption under section 80IA(4). The Hon'ble Bombay Bench of ITAT while deciding the case of Patel Engineering Ltd. vs. DCIT in ITA No.1221/Mum/2004 has gone to the extent of holding that the assessee, a civil contractor, having executed a part of contracts of irrigation and water supply on 'build and transfer' basis and handed over them to contractee Governments, was eligible for deduction under section 80IA(4). 5. We have also taken a similar view in ITA No. 554/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

ch a benefit. Explanation to section 80IA was inserted by Finance Act, 2007 with retrospective effect from 1.4.2000 which has further been amended by Finance (No. 2) Act, 2009 with retrospective effect from 1.4.2000. The amendment in this Explanation was necessitated due to contrary judicial decision on this issue. Thus, we can unequivocally now say that any undertaking or enterprise which executes the infrastructure development project, as referred to in sub-section(4) as a works contract award .....

X X X X X X X

Extract - Part text only
Click here to Access Full Contents

X X X X X X X

9;. It is only with effect from 1.4.2000, this section was divided into two portions 80IA and 80IB. Section 80IA(4) prescribes about the deduction available to a developer who develops infrastructure facilities. In view of the amendment inserted by the Finance Act, 2007, with retrospective effect from 1.4.2000, the deduction u/s 80IA is available to those assessees who are 'investing and developing infrastructure facility' and not to persons who simply executes 'works- contracts' .....

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 for tax benefit under section 80- IA. 10. We have found that the assessee-company is a works contractor, who has entered into agreement with the local bodies to execute certain part of the work awarded to it through contract for infrastructure facility. It is true that where a person who makes infrastructure and himself executes development work and carries out civil work will be eligible for tax benefit u/s 80IA of the Act. In contrast to this, a person who enters into a contract with another .....

X X X X X X X

Extract - Part text only
Click here to Access Full Contents

X X X X X X X

ssee-company fulfils all the relevant conditions. The facts of this case go to prove that the assessee is a 'developer' of infrastructure facilities. The reasons for our above conclusion are given in the following paras. Firstly, the assessee-company not only designs but also creates new products. The assessee had undertaken four projects during the relevant year and executed, constructed, delivered and maintained by it. As per the definition of Advanced Law Lexicon [placed at page 533 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

rs or such other works of the State Government or public undertakings as the State Government may be by notification, specify in this behalf at any of its stages entered into by the State Government or by an official of the State Government or public undertaking and includes an agreement for the supply of goods or material and all other matters relating to execution of any of the said works. The case of ACIT vs Indwell Lianings Pvt. Ltd (supra), on which the Assessing Officer has placed reliance .....

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 Pocket Dictionary, in relation to a corporation or business, the term "undertaking" denotes its whole enterprise and the word "enterprise" connotes all the related activities performed either through unified operation or common control by any person or persons for a common business purpose. The mens legis with reference to developer of infrastructure facility can be gathered from the memorandum explaining the provisions in the Finance Bill, 2007, reported in [2007] 289 .....

X X X X X X X

Extract - Part text only
Click here to Access Full Contents

X X X X X X X

was lacking in our country. The purpose of the tax benefit has all along been for encouraging private sector participation by way of investment in development of the infrastructure sector and not for the persons who merely execute the civil construction work or any other works contract. Accordingly, it is proposed to clarify that the provisions of section 80-IA shall not apply to a person who executes a works contract entered into with the undertaking or enterprise referred to in the said secti .....

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 will accordingly apply in relation to the assessment year 2000-01 and subsequent years." It is made abundantly clear that the prescription of section 80- IA shall not apply to a person who executes work contracts entered into with an undertaking or enterprise. Thus, in a case where a person who makes investment and himself executes development works and carries out civil works, will be eligible for tax benefit under section 80- IA of the Act. In contrast to this, a person who enters into .....

X X X X X X X

Extract - Part text only
Click here to Access Full Contents

X X X X X X X

his issue. We, therefore, restore the order of the Assessing Officer and reverse the order of the Commissioner of Income-tax (Appeals). 11. To further elaborate the discussion on this issue, paras 5 & 6 of the decision of ITAT Pune Bench rendered in the case of Laxmi Civil Engg. P. Ltd vs Addl. CIT,order dated 8.6.2011 are being extracted herein below: 5. We heard both the parties and perused the orders of the revenue. The contentious issues before us are (i) whether the contractor is synony .....

X X X X X X X

Extract - Part text only
Click here to Access Full Contents

X X X X X X X

eteness, the said paragraph is reproduced as under:- "22. The submission which was urged on behalf of the Revenue is that Clause (iii) of sub-section (4A) of section 80-lA, one of the conditions imposed was that the enterprise must start operating and maintaining the infrastructure facility on or after 1st April, 1995. The same requirement is embodied in sub clause (1) of sub-clause (4) of the amended provisions. It was urged that since the assessee was not operating and maintaining the fac .....

X X X X X X X

Extract - Part text only
Click here to Access Full Contents

X X X X X X X

nterprise carrying on the business of (i) developing; or (ii) operating and maintaining; or (iii) developing, operating and maintaining any infrastructure facility' which fulfils certain conditions. Those conditions are (I) ownership of the enterprises by a company registered in India or by a consortiums; (II) an agreement with the central or State Government, local authority or statutory body; and (III) the Start of operation and maintenance of the infrastructure facility should commence af .....

X X X X X X X

Extract - Part text only
Click here to Access Full Contents

X X X X X X X

elops, or operates and maintains; or (iii) develops, maintain and operates that infrastructure facility. However, the commencement of the operation and maintenance: of the infrastructure facility should be after 1" April, 1995. In the present case the assessee clearly fulfilled this condition ". Before the amendment that was brought about by parliament by Finance Act, 2001 we have already noted that the consistent line of circulars of the Board postulated the same position. The amendme .....

X X X X X X X

Extract - Part text only
Click here to Access Full Contents

X X X X X X X

above, it is evident that the person who only develops the infrastructure do not have the occasion to operate and maintain the infrastructure. It is further evident that the harmonious reading is necessary and mandatory in view of High Court's judgment in the case of an enterprise carrying on business or developing which is the case of the assessee, all the conditions referred to clause (i) of section 80IA (4) should refer to the conditions as applicable to the developer. In other words, 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

decision in paragraph-22 extracted above, is directly applicable to the facts of the case and eventually is entitled for the deduction under section 80IA (4) of the Act. Accordingly, the modified ground, which is common in all the four appeals is allowed in favour of the assessee. " 12. Let us remind ourselves that the Hon'ble Supreme Court in the case of Bajaj Tempo Ltd vs CIT, 196 ITR 188, has ordained that taxing statute granting incentives for promoting growth and development shoul .....

X X X X X X X

Extract - Part text only
Click here to Access Full Contents

X X X X X X X

he infrastructure facility if it operates the infrastructure facility and if it maintains the infrastructure facility or to put it in simpler terms, the harmonious reading of the provisions in its entirety would lead to the conclusion that this deduction is available to an enterprise who - develops or operates and also maintains; or develops, maintains and operates that infrastructure facility. The provision for giving the impugned incentives has been examined, re-examined, modified and amended .....

X X X X X X X

Extract - Part text only
Click here to Access Full Contents

X X X X X X X

rtain infrastructure is needed, the concerned authorities have a broader picture in their mind aiming at acquiring certain facility for which infrastructure development is required. So, to say, when any assessee/enterprise agrees under a contract to develop such an infrastructure facility, it cannot straight away be dubbed as not the brainchild of that enterprise, but only of the authority in question. Therefore, again this provision in so far as the conditions required to be fulfilled to be eli .....

X X X X X X X

Extract - Part text only
Click here to Access Full Contents

X X X X X X X

given case. It is an undeniable fact that the assessee is engaged in the civil construction work like construction of flyover, bridge underpass, sewerage, water supply etc. for various local bodies, railways, Central/State Governments. In fact, as per the terms of agreement, even the initial proposals formulated by the Department which are stated to be tentative, the assessee has the liberty to make different proposals without detrimental to the general features of the Departmental proposal, li .....

X X X X X X X

Extract - Part text only
Click here to Access Full Contents

X X X X X X X

ion or maintenance of Special Economic Zone, and also includes any person authorized for such purpose by any such developer". In the case of ACIT vs Bharat Udyog Ltd, 'F' Bench of ITAT Mumbai, has concluded that any assessee who is engaged in developing the infrastructure facility and also operating and maintaining the same, is entitled to the benefit of deduction u/s 80IA(4). A copy of this decision is enclosed at page 139 of the paper book. In the case of Patel Engineering Ltd vs .....

X X X X X X X

Extract - Part text only
Click here to Access Full Contents

X X X X X X X

is not necessarily contradictory to the term 'developer'. On the other hand, rather section 80IA(4) itself provides that assessee should develop the infrastructure facility as per the agreement with the Central Government, State Government or a Local Authority. So, entering into a lawful agreement and thereby becoming a contractor should in no way be a bar to the one being a 'developer'. The assessee has developed infrastructure facility as per the agreement with Maharashtra Gov .....

X X X X X X X

Extract - Part text only
Click here to Access Full Contents

X X X X X X X

nces, the assessee has been held to be eligible for deduction u/s 80IA(4). Section 80IA(4)(i)(b) requires development of infrastructure facility and transfer thereof as per agreement and it cannot be disputed in view of the material on record that the assessee has transferred the infrastructure facility developed by it by handing over the possession thereof to the concerned authority as required by the agreement. The handing over of the possession of developed infrastructure facility/project is .....

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 land involved in infrastructure facility/project always belongs to the Government/Local authority etc., whether it be the case of 'BOT' or 'BOOT' and it is handed over by the Government/Authority to the developer for development of infrastructure facility/Project. The same has been the position in the given case as well. So, deduction u/s 80IA(4) is also available to this assessee which has undertaken work of a mere 'developer'. Rather, the statutory provision as 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

decision of ACIT vs Bharat Udyog Ltd, 118 ITD 336 and Patel Engineering Ltd vs Dy. CIT, 84 TTJ 646, are relevant. As per Circular No. 4/2010[F.No. 178/14/2010-ITA-I] dated 18.5.2010, widening of existing roads constitutes creation of new infrastructure facility for the purpose of section 80IA(4)(i) . The assessee is not required to develop the entire road in order to qualify for deduction u/s 80IA as has been held by the Hon'ble Bombay High Court in the case of CIT vs ABG Heavy industries L .....

X X X X X X X

Extract - Part text only
Click here to Access Full Contents

X X X X X X X

ipur, in I.T.A. No. 722 & 723/JP/2008 dated 31.12.2008. The reliance by the ld. CIT(A) on the decision of ITAT, Chennai Bench in the case of ACIT vs Indwell Lianings Pvt. Ltd, 313 ITR(AT) 118, has been enlarged in its finding by the ITAT, Mumbai 'F' Bench in its decision rendered in the case of ACIT vs Bharat Udyog Ltd , by holding that such a deduction is only to be denied to a sub-contractor and not a mini contractor. Similar view has been taken by the ITAT Chennai Bench in the cas .....

X X X X X X X

Extract - Part text only
Click here to Access Full Contents

X X X X X X X

also relevant for this purpose. Moreover, we are in agreement that in incentive provisions, the construction should be liberally given as held by the Hon'ble Supreme Court rendered in the case of Bajaj Tempo Ltd vs CIT, 196 ITR 188. Thus, when the assessee makes investment and himself executes development work and carries out civil works, he is eligible for tax benefit u/s 80IA of the Act. Accordingly, with the foregoing discussion, we hold that the assessee is entitled to deduction u/s 80I .....

X X X X X X X

Extract - Part text only
Click here to Access Full Contents

X X X X X X X

sions in the light of the material on record, we find that the assessee should succeed on this ground. A careful reading of the order of this Tribunal dated 16.3.2012, relevant portion of which has been extracted above, clearly indicates that the Tribunal has decided the issue in favour of the assessee. That being so, the Assessing Officer is not entitled, in the consequential proceedings, the scope of which is confined to giving effect to the order of the Tribunal, to sit in judgment over the v .....

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 ground of the assessee on this issue. Following the above findings of the coordinate bench, we dismiss the grounds of revenue. 8. As regards the 4th ground of revenue, it is observed that the assessee had not maintained separate books of account to claim benefit u/s 80IA, hence, the assessee cannot claim deduction u/s 80IA relying on the Apex Court judgment in case of Arisudhana Spinning Mills Ltd. Vs. CIT. In the above case, the assessee had not maintained separate books for manufacturing 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

 

 

 

 

 



|| Home || Acts and Rules || Notifications || Circulars || Schedules || Tariff || Forms || Case Laws || Manuals ||

|| About us || Contact us || Disclaimer || Terms of Use || Privacy Policy || TMI Database || Members || Site Map ||

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

Go to Mobile Version