Subscription   Feedback   New User   Login      
Tax Management India .com
TMI - Tax Management India. Com
Articles Highlights TMI Notes SMS News Newsletters Calendar Imp. Links Database Experts Contact us More....
Extracts
Home List
← Previous Next →

Saxo India Pvt. Ltd Versus. ACIT,

2016 (2) TMI 604 - ITAT DELHI

Addition on account of transfer pricing adjustment - calculation of the assessee’s PLI - Held that:- In the present case, the assessee has taken a stand that capacity adjustment be allowed on the assumption of all the comparables operating at 100% capacity level, which is not evidenced from any material on record. On a pertinent query, the learned Authorized Representative candidly admitted that no such data was available to vouch such a claim. In the absence of any reliable data to support 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

as the assessee is simply engaged in rendering software development services and there is no sale of any software products, this company, in our considered opinion, ceases to be comparable. It is obvious that from the common pool of income from both the streams of software products and software services, one cannot deduce the revenue from software services and no one knows the impact of revenue from Products on the overall kitty of profit, which may be significant. Since no segmental data of thi .....

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 is also engaged in the customised software development, we find this company to be functionally similar. The same is, therefore, retained in the list of comparables.

L&T Infotech Ltd. - find from the Annual report of this company, which is available in the third paper book that its Profit and loss account shows “Revenue – Revenue software development services and products”. Profit and loss account of this company having a list of software development expenses contains an item `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

ersistent Systems and Solutions Ltd. - The Annual Report of this company has been placed in the second paper book, from which it is lucid that this company is engaged only in providing software development and consultancy services, which is similar to those rendered by the assessee. When confronted, the ld. AR did not raise any objection to the inclusion of this company in the final set of comparables. We, therefore, uphold the impugned order in treating this company as comparable.

Pe .....

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 software products in the total revenue is less, as has been noted by the TPO, yet, we are inclined to take it as non-comparable because there is no precise information about the contribution made by such small sale of software products to the total profit of the company. As no segmental information is available in respect of this company and the figures have been adopted by the TPO at entity level, we, therefore, order for the exclusion of this company from the list of comparables. .....

X X X X X X X

Extract - Part text only
Click here to Access Full Contents

X X X X X X X

gures contain revenue from both software services and software products, as against the assessee only providing software services, we are disinclined to treat this company as comparable

Wipro Technology Services Ltd.earned a revenue from Master services agreement with Citigroup Inc. for the delivery of technology infrastructure services. This agreement was, in fact, executed between the assessee’s AE, Wipro Ltd., and Citigroup Inc., a third person. This unfolds that the transaction 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

le uncontrolled transaction for the purposes of inclusion in the final list of comparables under Rule 10B(1)(e)(ii).

Acropetal Technologies Ltd. (Seg.) as find from the Annual accounts of this company, a copy of which is available at page 892 of the paper book, that it has a separate segment of software development covering `Enterprise solutions’ and `IT infrastructure solutions’. The nature of activity done by this company under these segments is broadly similar to that conducted by .....

X X X X X X X

Extract - Part text only
Click here to Access Full Contents

X X X X X X X

ct segment as is apparent from page 1198 of the paper book which states that: ‘the company has in-house research and development centre involved in developmental activities for new ‘products’ in the fields of simulations and training.’ Once this contention of the assessee is rejected and revenue from software products is excluded to the only inclusion of revenue from software development services segment which is akin to that of assessee, we feel no difficulty in considering this company as comp .....

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 inclusion or otherwise of Zylog Systems Ltd. in the final set of comparables afresh after entertaining objections from the assessee. - ITA No.6148/Del/2015 - Dated:- 5-2-2016 - SHRI R.S. SYAL, AM & SHRI KULDIP SINGH, JM Appellant By : Shri Manoj Pardwani, CA Respondent By : Shri Amrendra Kumar, CIT, DR ORDER PER R.S. SYAL, AM: This appeal by the assessee is directed against the final assessment order dated 26.10.2015 passed by the Assessing Officer (AO) under sections 143(3) read with 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

lso provided technical support services during the relevant year to some unrelated enterprises in India. The assessee reported four international transactions including Provision of Software Development with transacted value of ₹ 20,72,25,235/-, which is disputed in the instant appeal. There is no quarrel on the other three international transactions. The assessee applied the Transactional Net Margin Method (TNMM) as the most appropriate method for demonstrating that the international tran .....

X X X X X X X

Extract - Part text only
Click here to Access Full Contents

X X X X X X X

nd loss account was (-) 15.34%, whereas it had shown profit margin from the international transaction at 22.63%. The Transfer Pricing Officer noticed from the Transfer pricing study report that the comparability adjustment was carried out to arrive at such PLI at 22.63%. On perusal of the details filed by the assessee, it was seen that the expenditure on Personnel cost was allocated on the basis of man-days utilized vis-à-vis the man days available. Similarly, adjustments were found to ha .....

X X X X X X X

Extract - Part text only
Click here to Access Full Contents

X X X X X X X

ot be considered at 300 for the entire year as was claimed by the assessee. He further required the assessee to show that the comparables were operating at 100% capacity utilization level, as was its basis for calculating capacity utilization adjustment in its profit margin. In response, the assessee made general submissions that the comparables were incorporated long ago and were well established vis-à-vis the assessee. However, no specific details of the capacity utilization of comparab .....

X X X X X X X

Extract - Part text only
Click here to Access Full Contents

X X X X X X X

rofit -30021978 OP/OC (%) -12.65 4. Thereafter, he took up five comparable companies cited by the assessee in its Transfer pricing study report with their weighted average profit of last three years at 17.91%. The Transfer Pricing Officer restricted the comparison to the current year data of comparables and also made further additions to such a list of comparables, which after the directions given by the Dispute Resolution Panel (DRP), stood at 18. It is on this basis, that the addition of trans .....

X X X X X X X

Extract - Part text only
Click here to Access Full Contents

X X X X X X X

rnational transaction of Provision of the software development at 22.63%. The TPO worked out such PLI at (-)12.65%. It is this calculation made by the Transfer Pricing Officer, which has been challenged before us on the sole issue of nongranting of capacity utilization adjustment. Apart from that, the ld. AR did not advance argument on any other aspect of the calculation of the assessee s PLI. 6.2. Before proceeding further, we want to clarify that the ld. AR has not disputed the above extracted .....

X X X X X X X

Extract - Part text only
Click here to Access Full Contents

X X X X X X X

ing costs relating to the services rendered to the AE and non-AEs, a copy of which is available on page 324 of the Paper book, that out of total Operating revenue of ₹ 21.78 crore, revenue from AE is to the tune of ₹ 20.81 crore. This shows that major portion of the assessee s revenue is from international transactions only. 6.3. The only issue assailed and argued by the learned Authorized Representative is against not granting of capacity utilization adjustment in the calculation 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

e made only in computation of profit margin of the comparables. Thus, the foremost question for our consideration is whether capacity adjustment, or for that matter, any other adjustment on account of dissimilarity between the assessee and comparables, is warranted in the assessee s calculation of profit level indicator or that of comparables. 6.4. Chapter-X of the Act contains special provisions relating to avoidance of tax. Section 92, which is the first section of this Chapter, provides for 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

d herein which include, inter alia, the transactional net margin method. Sub-section (2) of section 92C provides that the most appropriate method referred in sub-section (1) shall be applied for the determination of ALP in the manner as may be prescribed . Calculation of ALP under the TNMM has been prescribed under Rule 10B(1)(e) of the Income-tax Rules, 1962, which states that for the purposes of section 92C(2), the ALP in relation to the international transaction shall be determined as under : .....

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 computed having regard to the same base ; (iii) the net profit margin referred to in sub-clause (ii) arising in comparable uncontrolled transactions is adjusted to take into account the differences, if any, between the international transaction and the comparable uncontrolled transactions, or between the enterprises entering into such transactions, which could materially affect the amount of net profit margin in the open market ; (iv) the net profit margin realised by the enterprise and refer .....

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 net profit margin realized by the enterprise from the comparable uncontrolled transaction is computed having regard to the same base. Sub-clause (iii) provides that the net profit margin realized by a comparable company, determined as per subclause (ii) above, is adjusted to take into account the differences, if any, between the international transaction and the comparable uncontrolled transactions, ..... which could materially affect the amount of net profit margin in the open market. It 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

of the comparables. Sub-clause (v) states that the net profit margin thus established is then taken into account to arrive at an arm s length price in relation to international transaction. On going through the above sub-clauses of Rule 10B(1)(e), it becomes patent that as per the first step, the net profit margin realized by the enterprise from an international transaction is to be computed. Use of the word realized in the provision richly indicates that it is the calculation of actual operatin .....

X X X X X X X

Extract - Part text only
Click here to Access Full Contents

X X X X X X X

that of the assessee as per clause (i), that is, actual figures without making any adjustment. Then sub-clause (iii) talks of adjusting the actually realized margin of comparables to bring the same at par with the international transaction undertaken by the assessee, so as to iron out the effects of differences between the international transaction and comparable uncontrolled transactions. On going through all the sub-clauses of Rule 10B(1)(e), the natural corollary which follows is that the ne .....

X X X X X X X

Extract - Part text only
Click here to Access Full Contents

X X X X X X X

nd contrary to the legal provisions, which is hereby repelled. 6.6. The learned Authorized Representative tried to convince us on his point of view of allowing capacity adjustment in the profit margin of the assessee, by pressing into service sub-rule (3) of Rule 10B, which reads as under : (3) An uncontrolled transaction shall be comparable to an international transaction if- (i) none of the differences, if any, between the transactions being compared, or between the enterprises entering into 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

ransaction or if such differences exist, then a reasonably accurate adjustment can be made to eliminate the material effects of such differences. A plain reading of sub-rule (3) of Rule 10B brings to the fore that this sub-rule is meant only for ascertaining whether or not a probable comparable uncontrolled transaction is fit for being treated as actual comparable. This is only an entry level judgmental provision for ascertaining the comparability of an otherwise broadly comparable uncontrolled .....

X X X X X X X

Extract - Part text only
Click here to Access Full Contents

X X X X X X X

dly comparable uncontrolled transaction goes out of the reckoning and does not gain entry in the final tally of comparables for the purposes of computing ALP of the international transaction as per the mandate of rule 10B(1)(e). In other words, role of sub-rule (3) to Rule 10B is only to filter out comparable uncontrolled transactions qualifying for inclusion in the determination of the ALP under Rule 10B(1). Mechanism for determining ALP under the TNMM has been enshrined in Rule 10B(1)(e) alone .....

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 provision for allowing adjustment on account of differences between uncontrolled transaction and international transactions from the profit margin of the assessee, then we will have to read sub-rule (3) as a part of machinery for calculating ALP under Rule 10B(1)(e), which has no statutory sanction. Thus, it follows from a conjoint reading of rule 10B(1)(e) with rule 10B(3), that whereas later rule is only meant for deciding the inclusion or otherwise of a probable comparable in the final lis .....

X X X X X X X

Extract - Part text only
Click here to Access Full Contents

X X X X X X X

to the instant case. Our view is fortified by several orders passed by the Delhi benches of the tribunal on this issue including DCIT vs. Claas India Pvt. Ltd. (ITA No.1783/Del/2011) dt. 12.08.2015 (to which one of us, namely, the AM is a party). Ex consequenti, it is held that capacity adjustment, or for that matter any other adjustment, can be legally made only in the profit margin of the comparables, if otherwise factually warranted. 7.1. The foregoing discussion brings us to the next issue 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

sessee calculated its profit margin at 22.63% on the basis of working given at page 324 of the paper book. When we peruse this calculation, it becomes vivid that out of total operating expenses of ₹ 25.72 crore, the assessee has not accounted for operating expenses to the tune of ₹ 8.65 crore anywhere, either in the calculation of operating profit margin from the AE or non-AE transactions. On a specific query, the learned Authorized Representative submitted that this cost 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

s to the same without adjusting it against AE or non-AE segments. We have noticed supra from the language of rule 10B(1)(e)(i) that it talks of finding out profit margin realized , which can be computed by considering all the operating costs incurred. It does not permit ignoring any operating cost actually incurred. By doing so, the assessee has devised a unique method for converting its loss from the AE segment into profit, by artificially excluding huge operating costs actually incurred from 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

seats on which some work can be possibly done notwithstanding the actual number of employees working on them. When we consider the number of employees actually employed by the assessee, it comes out that for the months of April to September, 2010, it was between 58 to 98; from October, 2010 to February, 2011, it was between 106 to 181; and for March, 2011, it was 213. It is beyond our comprehension as to how the assessee is calculating capacity adjustment with full capacity at 300, when actual n .....

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 80%. In order to claim any capacity adjustment, it is for the assessee to show that each of such comparables had their respective capacity utilization of less than 80% so as to call for any favorable adjustment. If one of the comparables, say A, has capacity utilization of 50%, then the profit margin of such comparables is required to be adjusted with the differential capacity adjustment of 30% (80% - 50%). If another comparable, say B, has capacity utilization of 70%, then the profit margin 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

e care of differences between the international transaction and comparable uncontrolled transactions. Then the matter comes up before the TPO to vet the correctness of the assessee s claim. Thus it is apparent that onus to claim any capacity adjustment is always on the assessee, which can be discharged by demonstrating different capacity utilization levels. It is trite law that the burden of proof is always on the one who claims so. It is only when the assessee brings on record some evidence, ei .....

X X X X X X X

Extract - Part text only
Click here to Access Full Contents

X X X X X X X

tment, is akin to putting cart in front of horse, which is manifestly impermissible. In the present case, the assessee has taken a stand that capacity adjustment be allowed on the assumption of all the comparables operating at 100% capacity level, which is not evidenced from any material on record. On a pertinent query, the learned Authorized Representative candidly admitted that no such data was available to vouch such a claim. In the absence of any reliable data to support the difference betwe .....

X X X X X X X

Extract - Part text only
Click here to Access Full Contents

X X X X X X X

cted five companies as comparable and after the direction given by the DRP, the final list as drawn by the Transfer Pricing Officer, stood reduced to 18 comparables. The assessee has agitated inclusion of 10 companies from such a list of comparables which we will examine in seriatim herein below. 9.2. Before venturing to consider the comparability or otherwise of these companies assailed in the extant appeal, it is desirable to first understand the nature of work carried out by the assessee for .....

X X X X X X X

Extract - Part text only
Click here to Access Full Contents

X X X X X X X

nmark, whose copy is available at pages 377 onwards of the paper book. This Agreement states that the assessee is engaged in the business of providing certain software and consulting services and solutions to Buyer (i.e. its AE). Definition of Software services rendered by the assessee to its AE given in this Agreement means and includes services towards software development, software support, software project management services, development of new application, maintenance or upgrading or rewor .....

X X X X X X X

Extract - Part text only
Click here to Access Full Contents

X X X X X X X

hether alone or with others during the course of its performance under this Agreement, shall be the exclusive property of Buyer (i.e. its AE) . Next para 12.2 of the Agreement provides that : The software shall be deemed Buyer s proprietary information and shall not be disclosed to anyone outside of Buyer, or used by Service provider or others without the prior, written consent of Buyer . These clauses of the Agreement adequately indicate that the assessee is simply engaged in software developme .....

X X X X X X X

Extract - Part text only
Click here to Access Full Contents

X X X X X X X

rty rights in the work done by the assessee vest in it. The ld. AR contended that the assessee is mainly developing software and solutions to be used in banking business. However, he could not correlate such a contention with any material on record. With the above brief introduction of the assessee s nature of work, now we will examine the disputed companies as to their comparability or otherwise. (i) E-Infochips Limited: 10.1. The Transfer Pricing Officer included this company in the list of 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

he rival submissions and perusing the relevant material on record, we find that the Annual report of this company is available in the paper book with its Profit and loss account at page 1025. Schedule of Income indicates its operating revenue from software development, hardware maintenance, information technology, consultancy etc. Revenue from hardware maintenance stands at ₹ 3.92 crore, which has been considered by the Transfer Pricing Officer himself as sale of products. Such sale of pro .....

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 revenue from software services and no one knows the impact of revenue from Products on the overall kitty of profit, which may be significant. Since no segmental data of this company is available indicating operating profit from software development services, we order to exclude this company from the list of comparables. (ii) E-Zest Solutions 11.1. The Transfer Pricing Officer considered this company as comparable by observing that it provided similar services as were being provided by the as .....

X X X X X X X

Extract - Part text only
Click here to Access Full Contents

X X X X X X X

hich is available in the paper book. Its Profit and loss account specifies Income from operations . It is further borne out that it is providing end-to-end development, software project development services. As the assessee is also engaged in the customised software development, we find this company to be functionally similar. The same is, therefore, retained in the list of comparables. (iii) L&T Infotech Ltd. 12.1. The assessee argued against the inclusion of this company in the list of com .....

X X X X X X X

Extract - Part text only
Click here to Access Full Contents

X X X X X X X

from the Annual report of this company, which is available in the third paper book that its Profit and loss account shows Revenue - Revenue software development services and products . Profit and loss account of this company having a list of software development expenses contains an item Cost of bought-out items for re-sale with a value of ₹ 25.55 crore. Apart from that, the balance-sheet of this company shows certain Software in its Schedule of fixed assets under the head Intangible asset .....

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 in total revenue. The TPO observed from the Annual report of this company that it was providing support in software development, consultancy and system integration services. He, therefore, considered it as comparable. The assessee is aggrieved. 13.2. We have heard the rival submissions and perused the relevant material on record. The Annual Report of this company has been placed in the second paper book, from which it is lucid that this company is engaged only in providing software development .....

X X X X X X X

Extract - Part text only
Click here to Access Full Contents

X X X X X X X

O negatived this contention and included the same in the final set of comparables. 14.2. After considering the rival submissions and perusing the relevant material on record, we find from Profit & Loss Account of this company, a copy of which is placed at page 1534 of the paper book, that its income from Sale of software services and Products is amounting to ₹ 6101.27 millions. The TPO has himself observed that this company does have some products, but, product revenue is only 7.2% and .....

X X X X X X X

Extract - Part text only
Click here to Access Full Contents

X X X X X X X

comparable because there is no precise information about the contribution made by such small sale of software products to the total profit of the company. As no segmental information is available in respect of this company and the figures have been adopted by the TPO at entity level, we, therefore, order for the exclusion of this company from the list of comparables. vi) Sasken Communications Technologies Ltd. 15.1. The TPO included this company in the set of comparables despite the assessee s 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

tity level figures for the purposes of making comparison. Since such entity level figures contain revenue from both software services and software products, as against the assessee only providing software services, we are disinclined to treat this company as comparable. The assessee s contention is accepted on this issue. vii) Wipro Technology Services Ltd. 16.1. The assessee objected to the inclusion of this company in the list of comparables by arguing that apart from this company being functi .....

X X X X X X X

Extract - Part text only
Click here to Access Full Contents

X X X X X X X

Services Limited) ( the Company ) was incorporated on 15 September, 2004. The entire share capital of the Company was held by Citicorp Banking Corporation, a company incorporated under laws of Delaware, USA, upto 20 January, 2009. Wipro Limited (Wipro) executed an agreement with Citigroup Inc. for acquiring all of Citigroup interest in the Company w.e.f. 21 January 2009. On 21 January 2009, Wipro signed a master service agreement (MSA) with Citigroup Inc. for the delivery of technology infrastr .....

X X X X X X X

Extract - Part text only
Click here to Access Full Contents

X X X X X X X

ogy Services Ltd., was held by Citi Corp. Banking Corporation, USA upto 20th January, 2009. Wipro Ltd., parent company of the assessee, executed an agreement with Citi Group Inc., for acquiring Citi Technology Services Ltd., now called Wipro Technology Services Ltd. On 21.1.2009, Wipro Ltd. signed a master agreement with Citi Group Inc., for the delivery of technology Infrastructure Services and application development and maintenance services for the period of six years, which also includes 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

chmarking. The epitome of comparable uncontrolled transaction is that the companies or transactions in order to fall within the ambit of subclause (ii) of rule 10B(1)(e), should be both comparable as well as uncontrolled. Uncontrolled transaction has been defined in Rule 10A(a) to mean: a transaction between enterprises other than associated enterprises, whether resident or non-resident. This shows that in order to be called as an uncontrolled transaction, it is sine qua non that the same should .....

X X X X X X X

Extract - Part text only
Click here to Access Full Contents

X X X X X X X

in substance between such other person and the associated enterprise . On going through the prescription of sub-section (2) of section 92B, it is clearly borne out that a transaction with a non-AE shall be deemed to be a transaction entered into between two AEs if there exists a prior agreement in relation to the relevant transaction between the third person and the AE or the terms of the relevant transaction are determined in substance between the third person and the AE. When we consider sect .....

X X X X X X X

Extract - Part text only
Click here to Access Full Contents

X X X X X X X

, it ceases to be an uncontrolled transaction and, thereby, goes out of reckoning under Rule 10B(1)(e)(ii). 16.5. Adverting to the facts of the instant case, we find that Wipro Technology Services Ltd. earned a revenue from Master services agreement with Citigroup Inc. for the delivery of technology infrastructure services. This agreement was, in fact, executed between the assessee s AE, Wipro Ltd., and Citigroup Inc., a third person. This unfolds that the transaction of earning revenue from sof .....

X X X X X X X

Extract - Part text only
Click here to Access Full Contents

X X X X X X X

on for the purposes of inclusion in the final list of comparables under Rule 10B(1)(e)(ii). We, therefore, direct removal of this company from the list of comparables. viii) Acropetal Technologies Ltd. (Seg.) 17.1. The TPO considered this company as comparable on segmental level. The assessee s contentions in this regard were rejected. 17.2. After considering the rival submissions and perusing the relevant material on record, we find from the Annual accounts of this company, a copy of which is 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

arables. The impugned order is, therefore, upheld on this score. ix) Sankhya Infotech Ltd. (Seg.) 18.1. The TPO rejected the assessee s contention about the functional dissimilarities of the software development segment of this company and included the same in the final tally of comparables. The assessee is aggrieved against such inclusion. 18.2. We have heard the rival submissions and perused the relevant material on record. Annual accounts of this company are available in the paper book. It 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

elds of simulations and training. Once this contention of the assessee is rejected and revenue from software products is excluded to the only inclusion of revenue from software development services segment which is akin to that of assessee, we feel no difficulty in considering this company as comparable on segmental level. The impugned order is upheld. x) Zylog Systems Ltd. 19.1. The TPO considered this company as comparable by noting in his order that the assessee s objections to its inclusion .....

X X X X X X X

Extract - Part text only
Click here to Access Full Contents

X X X X X X X

 

 

 

 

 

what is new what is new
  ↓     bird's eye view     ↓  


|| 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