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2016 (3) TMI 356 - ITAT BANGALORE

2016 (3) TMI 356 - ITAT BANGALORE - TMI - Transfer pricing adjustment - whether the foreign exchange gain/income from service provided to AE will be part of the operating revenue/income? - Held that:- In view of the coordinate bench of the Tribunal in the case of Rusabh Diamonds (2013 (11) TMI 520 - ITAT MUMBAI ), we hold that the foreign exchange gain/income from service provided to AE will be part of the operating revenue/income of the assessee and consequently it will be part of the operating .....

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to consider the operating margin of the comparable after giving effect to foreign exchange gain or loss in their respective margins to arrive at the mean margin. Accordingly, this issue of the assessee is partly allowed.

Selection of comparable - Held that:- Accentia Technologies Ltd is engaged in diversified activity of medical transcription, medical coding, billing, receivable management. Thus it is clear that the said company is engaged in the healthcare activity and providing BPO .....

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lerx Services Ltd. company is not comparable with BPO company which are engaged only in low end services of data processing. Accordingly, we direct the AO/TPO to exclude Eclerx Services Ltd. from the list of comparables for the purposes of determining ALP.

Infosys BPO Ltd. - revenue earned by this company is from the activity inclusive of operation primarily relates to providing business process management services to other organization engaged in outsourcing business process. This co .....

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travel expenses incurred in foreign currency from the export turnover while computing deduction u/s 10A - Held that:- This issue is now covered by the judgment of the Hon'ble jurisdictional High Court in the case of Tata Elxsi (2011 (8) TMI 782 - KARNATAKA HIGH COURT ) wherein held . When the statute prescribes a formula and in the said formula, ‘export turnover’ is defined, and when the ‘total turnover’ includes export turnover, the very same meaning given to the export turnover by the legislat .....

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ne what the total turnover means then, when the total turnover includes export turnover, the meaning assigned by the legislature to the export turnover is to be respected and given effect to, while interpreting the total turnover which is inclusive of the export turnover - IT(TP)A No.1845/Bang/2013, IT(TP)A No.1777/Bang/2013 - Dated:- 10-11-2015 - SHRI VIJAY PAL RAO, JUDICIAL MEMBER and SHRI G.MANJUNATHA, ACCOUNTANT MEMBER For The Assessee : Shri Ajit Jain, CA. For The Revenue : Shri Bijoy Kumar .....

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quot;Assessing Officer" or "learned AO") and the learned Dispute Resolution Panel ("Panel") erred in upholding the order passed by the learned Additional Commissioner of Income Tax (Transfer Pricing)-I ("Transfer Pricing Officer" or "TPO") ) to the extent prejudicial to the Appellant which was bad in law and in violation of principles of natural justice; 2 That the learned Panel! AO erred in upholding the arm's length price as determined by the TP .....

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ng the arm's length price; v accepting companies without considering the turnover and size of the assessee and comparables; vi rejecting companies having export revenue less than 25% of total operating revenue; vii rejecting companies with different year ending; viii rejecting companies having revenue from Information Technology Enabled Services less than 75% of total operating revenue; ix rejecting companies based on their financial results without considering the functional comparability; .....

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ncial year 2008-09) data for companies should be used for comparability: 4. The learned Panel/AO erred in not providing any adjustments under Rule 10B towards the difference in the risk profile, depreciation, marketing expenditure and research and development expenditure adjustment between the Appellant and the entrepreneurial companies selected as comparables while determining the arm's length price; 5 The learned Panel/A0 erred in upholding the learned TPO's approach of not granting th .....

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penses incurred in foreign currency' of ₹ 2,138,709 from the 'export turnover' which is un-attributable to the delivery of export services while computing the deduction under section 10A of the Act; 3. Ground No.1 is general in nature and does not require any specific adjudication. 4. At the time of hearing, learned AR of the assessee has stated that the assessee does not press ground No.2(i), (vi), (vii) and (viii), ground No.3, 4 and 6 and pleaded that the same may be dismiss .....

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s of end to end BPO services. The assessee has entered into service agreement dated 1/4/2005 with its Associated Enterprise (AE) to provide 24/7 contact centre outsourcing service. AE of the assessee M/s. ISPL, iSeva Inc. incorporated in November 1999 in United States of America and is holding company of the assessee. During the year under consideration, the assessee has reported the financial results and segmental results including international transactions as reported u/s 92C reproduced by th .....

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id (Rs.) Amount received (Rs.) Technical support & financial services - 568,959,962 Infrastructure Management Services - 60,332,684 Reversal of Reimbursement of Expenses 1,085,913 - 7. The TPO has recorded the business profile of the assessee at page 2 as under: Business Profile ISPL has established itself as a domain specific and industry focused company with significant expertise in industries including mortgage processing, banking and high technology. It provides Business Process Outsourc .....

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e to bench mark its international transaction, the assessee selected 11 comparables which are reproduced by the TPO in para.3.4 as under: Sl. No. Name of the comparable Remarks 1 Allsec Technologies Ltd. The company qualifies all the filters applied by the TPO. Thus the company is considered as a comparable. 2 Caliber Point Business Solutions Ltd. This company has year ending other than March. Reliable financial data will not be available for a 12 month period. This cannot be used as a comparabl .....

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ness process. 6 Informed Technologies India Ltd. The company qualifies all the filters applied by the TPO. Thus the company is considered as a comparable. 7 Infosys BPO Ltd. The company qualifies all the filters applied by the TPO. Thus the company is considered as a comparable. 8 Inhouse Productions Ltd. Export to sales is just 0.09%, hence rejected. 9 KPIT Cummins Global Business Solutions Ltd. RPT is 94.70%, hence rejected. Solutions Ltd. 10 NIIIT Smarserve Ltd. Rejected: RPT> 25%. 11 R Sy .....

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the Company Margin 1 Infosys BP0 Ltd. 24.41% 2 Aditya Birla Minacs Worldwide Ltd. 23.86% 3 Microland Ltd,(both segments) 1 .53% 4 Allsec Technologies Ltd. 16.63% 5 Accentia Technologies Ltd. 46.40% 6 Informed Technologies India Ltd. 22.61% 7 Cosmic Global Ltd. 40.61% 8 Eclerx Services Ltd 57.50% AVERAGE PLI 25.04% Thus the TPO has arrived at the mean margin of 25.04%. The TPO has also made an upward adjustment on account of working capital at the rate of 1.61% and finally computed the adjusted m .....

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O in making the proposed adjustment on account of transfer pricing. 8. Before us, the assessee has basically raised two arguments - (i) regarding re-computation of the operating profit of the assessee by excluding foreign exchange gain and (ii) regarding functional comparability of the companies selected by the TPO. 9. First we will take up the issue of re-computation of the operating profit of the assessee by excluding foreign gain and other income. The learned AR of the assessee has pointed ou .....

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assessee at page 7 of the paper book and submitted that the TPO has excluded a sum of ₹ 6,33,42,675/- while recomputing the profit margin of the assessee which has been shown by the assessee under the head other income in schedule 12. The learned AR of the assessee has referred to schedule 12 of the profit and loss account and submitted that out of this amount of ₹ 6,33,42,675/- an amount of ₹ 5,74,78,906/- pertains to net foreign exchange gain of sale proceeds received from t .....

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bmitted that that the Tribunal, while considering an identical issue of foreign exchange gain being part of the operating profit has held that if the foreign exchange gain is earned by the assessee in respect of the import/export activity, then the same will be treated as part and parcel of the operating profit. On the other hand, learned Departmental Representative has referred to the finding of the DRP at page 64 of the directions and submitted that the DRP has considered the objections of the .....

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considered as part of the operating revenue or the income of the assessee Foreign exchange gain or loss is dependent on the factors beyond the purview of the tax-payer and therefore, will not be considered as part of the operating revenue or income of the assessee. He has relied upon the orders of the authorities below. 10. We have considered the rival submissions as well as the relevant material on record. There is no dispute about the fact that as far as the amount of foreign exchange gain is .....

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ons and price determination between the parties and particularly when the transactions are cross-border transactions. Therefore, the extraneous factors which are taken as the reason for not considering foreign exchange gain as part of the operating revenue are also influencing the business activity of the assessee in respect of international transaction. Therefore, we do not agree with the contentions of the learned Departmental Representative that foreign exchange gain is not dependent on the o .....

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on record. The assessee has entered into forward contracts for the purpose of hadging of foreign currency exposure on export and import of diamonds with AEs. Therefore, the hadging of foreign currency has nexus with the export and import activity of the assessee and the exposure of the assessee in relation to the export and import. The OECD guidelines in para 2.82 are as under; 2.82 Whether foreign exchange gains and losses should be included or excluded from the determination of the net profit .....

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net margin applied to a transaction in which the foreign exchange risk is borne by the tested party, foreign exchange gains or losses should be consistently accounted for (either in the calculation of the net profit indicator or separately). 10.1 It is clear that in case of hedging of foreign currency exposure on the underlining trade receivable or payable the profit of loss will be treated in the same way in determining the net profit. 10.2 In view of the facts that the assessee has entered int .....

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t will be part of the operating profit of the assessee for the purpose of determining the ALP in respect of the international transaction. However, the related aspect on this issue is also to be kept in mind that while taking the margins of the comparables, the effect of foreign exchange in the margins of the comparables should also be taken into account. Therefore, we direct the AO/TPO to re-compute the margin of the assessee by including foreign exchange gain but exclude other incomes on accou .....

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arguments only with respect to the 4 comparables viz: (1) Accentia Technologies (2) Comic Global Ltd. (3) Eclerx Services Ltd., and (4) Infosys BPO Ltd. The comparability of each of these companies are dealt with one by one as under: 11.1. Accentia Technologies Ltd. The learned AR of the assessee has submitted that though the TPO has recorded the business profile of the assessee, however, the international transactions of the assessee are carried out only in respect of service of contact centre .....

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his objection, learned AR of the assessee has submitted that even otherwise this company is not functionally comparable with the assessee so far as services provided to the AE. He has referred to various business transactions and services provided by Accentia Technologies Ltd., and submitted that this company is in the various segments of activities like medical transcription, medical coding, medical billing, etc. The activity of medical transcription and medical coding is entirely different fro .....

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esentative has submitted that this company satisfies the filter test applied by the TPO for selecting companies in the category of Information Technology Service (ITES) company. The assessee is also engaged in the activity of providing ITeS to its AE and therefore, both the assessee as well as Accentia Technologies Ltd., are engaged in the similar business activity. He has referred to the findings of the TPO and the DRP and submitted that the DRP has rejected the objections raised by the assesse .....

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nder consideration. Though the extraordinary event of merger or acquisition, if influenced the business as well as the revenue of a company then said company is not considered as a good comparable for the purpose of determination of the ALP however, in this case, it is not clear from the Annual Report whether the business of M/s.Oak Technologies Inc has been acquired and merged with the said company during the year under consideration. It appears that Accentia Technologies Ltd., has purchased up .....

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iness activity. Therefore, in the absence of complete relevant facts, it cannot be held that the socalled acquisition of M/s.Oak Technologies can be considered as an extraordinary event having impact on the revenue as well as business activity of Accentia Technologies Ltd. Accordingly, this argument of the learned AR of the assessee is rejected for want of complete facts. iii) As regards the functional dissimilarity, we note that Accentia Technologies Ltd is engaged in diversified activity of me .....

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t the company Accentia Technologies Ltd cannot be considered as a functionally comparable company with the services provided by the assessee to its AE. The TPO is directed to exclude this company from the set of comparables. 11.2. Eclerx Services Ltd. The learned AR of the assessee has submitted that this company is engaged in the high-end services and therefore, this company is basically a KPO and not a BPO. He has referred to Annual Report of this company at page 26 of the paper book -II and s .....

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process outsourcing as well as in the activity of process reengineering and automation apart from middle office and back office support to capital market. Therefore, keeping in the diversified high-end services, this company cannot be considered as functionally comparable with the assessee. In support of his contention, he has relied upon the decision of the Special Bench of the Mumbai Tribunal in the case of Maersk Global Services (147 ITD 83). i) On the other hand, learned Departmental Repres .....

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ents. The service provided by Eclerx Services Ltd., is in various areas including capital market and therefore, the services are in the nature of consultancy and end to end support through trade centre including trade confirmation, settlement, transaction, maintenance and analytic and reporting. Thus it is apparent from the nature of the activity of this company that it is not providing a simple service of data processing but it is engaged in the activity of providing high-end services involving .....

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per book. A perusal of the same shows that the said company provides data analytics and data process solutions to some of the largest brands in the world and is recognized as experts in chosen markets-financial services and retail and manufacturing. It is claimed to be providing complete business solutions by combining people, process improvement and automation. It is claimed to have employed over 1500 domain specialists working for the clients. It is claimed that eClerx is a different company w .....

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solutions offered that include data analytics, operations management, audits and reconciliation, metrics management and reporting services. It also provides tailored process outsourcing and management services along with a multitude of data aggregation, mining and maintenance services. It is claimed that the company has a team dedicated to developing automation tools to support service delivery. These software automation tools increase productivity, allowing customers to benefit from further co .....

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e of the view that if the functions actually performed by the assessee company for its AEs are compared with the functional profile of M/s eClerx Services Pvt. Ltd. and Mold-Tec Technologies Ltd., it is difficult to find out any relatively equal degree of comparability and the said entities cannot be taken as comparables for the purpose of determining ALP of the transactions of the assessee company with its AEs. We, therefore, direct that these two entities be excluded from the list of 10 compar .....

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bmitted that though this company was initially selected by the assessee, however, the assessee has raised objections against this company even before the TPO and further before the DRP. Therefore, this company, if found functionally different, has to be excluded from the list of comparables. The learned AR of the assessee has pointed out that this company is having more than 17000 employees in comparison to only 6 employees of the assessee. Therefore, even on the parameter of the scale and stren .....

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hence this company cannot be considered as a good comparable for the purpose of determining the ALP. Apart from the above objections, learned AR of the assessee has further submitted that this company is engaged in providing business process management services to organizations with outsourcing their business process. Therefore, this company is in a different kind of business activity in providing the management service of business processes and is not directly providing any business process ou .....

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es below. ii) We have considered the rival submissions as well as relevant material on record. We note that in para 16.2.15 of the Annual Report of this company, it has been reported that there was amalgamation w.e.f 1/4/2008. The relevant part of the information provided in the Annual Report reads as under: Amalgamation of PAN Financial Services India Private Limited The Board of Directors in their meeting held on October 6. 2008. approved, subject to the approval of the Honorable High Courts o .....

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March 10, 2009 respectively. Accordingly on the scheme becoming effective, the financial statement of PAN Financial has been merged with the company. It is clear that there was extraordinary event of amalgamation during the year under consideration. Therefore, in view of the extraordinary development of amalgamation of another company, this company cannot be considered as a good comparable for the assessment year under consideration. Apart from this, we further note that as per the segment repo .....

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of customers. The accounting principles consistently used in the preparation of the financial statements are also consistently applied to record income in individual segments. These are set out in the note on significant accounting policies. Thus it is clear that the revenue earned by this company is from the activity inclusive of operation primarily relates to providing business process management services to other organization engaged in outsourcing business process. This company is not engage .....

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on the ground that this company has major revenue from translation services. Therefore, this company is functionally different from the services provided by the assessee to its AE. The learned AR of the assessee has referred to the Annual report of this company and submitted that that out of the total revenue of ₹ 7,37,02,584/-, this company has earned revenue from translation charges to the tune of ₹ 6,99,35,756/-. Therefore, substantial part of the revenue has been earned from the .....

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tention, he has relied upon the decision of the co-ordinate bench of this Tribunal in the case of Lam Research (India) Pvt. Ltd. vs. DCIT in ITA No.1437/Bang/2014 dated 30/4/2015. i) On the other hand, learned Departmental Representative has submitted that the comparability of this company has been examined by the TPO as well as by the DRP. The TPO has rejected the objections raised by the assessee in respect of this company by holding that the translation service are in the nature of ITeS and t .....

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enue of ₹ 6,99,35,756/- out of total revenue of ₹ 7.37 crores has been earned by this company from the activity of translation services. We further note that the company has debited an expenditure of more than ₹ 3 crore on account of translations charges paid. Thus it is clear that this company is outsourcing its services of translation work which is the main activity of this company yielding major revenue earned during the year. Thus it is manifest from the record that this co .....

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lobal Ltd. 19. The main objection of assessee with reference to the inclusion of this company is with reference to outsourcing of its main activity. Even though this company is in assessee's TP study, it has raised objection before the TPO that this company's employee cost is less than 21.30% and most of the cost is with reference to the outsourcing charges or translation charges, and as such this is not a comparable company. The TPO, though considered these submissions, rejected the sam .....

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he material on record that outsourcing charges of this case constitute 57.31% of the total operating costs. This does not appear to us to be a valid reason for eliminating this case from the list of comparables. On going through the Annual accounts of Cosmic Global Limited, a copy of which has been placed on record, we find that its total revenue from operations are at ₹ 7.37 crore divided into three segments, namely, Medical transcription and consultancy services at ₹ 9.90 lacs, Tra .....

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PO segment alone, there is no need to examine the position under other segments. The entire outsourcing is confined to Translation charges paid at ₹ 3.00 crore, which is strictly in the realm of the Translation segment, revenues from which are to the tune of ₹ 6.99 crore. If this segment of Translation is not under consideration for deciding as to whether this case is comparable or not, we cannot take recourse to the figures which are relevant for segments other than accounts BPO. Th .....

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xcluded CG-VAK with turnover from Accounts BPO segment at ₹ 86.10 lacs. As the segmental revenue of BPO segment of Cosmic Global Limited at ₹ 27. 76 lac is still on much lower side, the reasons given above would fully apply to hold Cosmic Global Limited as incomparable. This case is, therefore, directed to be excluded from the list of comparables." In view of the detailed analysis of the coordinate Bench of the Tribunal in the above referred case, in this case also we accept the .....

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s, therefore, we do not propose to decide the issue of comparability of other comparables selected by the TPO. Accordingly, the AO/TPO is directed to recomputed the ALP after excluding the above 4 companies from the set of comparables. Further, the TPO has also to consider the benefit of tolerance range +/-5% as per the proviso to sec.92C. 13. The next ground raised by the assessee in respect of corporate tax matter is regarding reducing travel expenses incurred in foreign currency from the expo .....

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ncurred in foreign currency from the total turnover also while computing the deduction u/s 10A of the I.T. Act as the decision of the High Court is binding, without appreciating the fact that there is no provision in section 10A that such expenses should be reduced from the total turnover also, as clause (iv) of the explanation to section 10A provides that such expenses are to be reduced only from the export turnover. 3. The DRP erred in not appreciating the fact that the jurisdictional High Cou .....

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it is clear from the grounds raised in the revenue s appeal as well as the corporate tax issue raised by the assessee that only common issue arises is in respect of the computation of deduction u/s 10A after reducing the travel expenses incurred in foreign currency from the export turnover. Therefore, we propose to dispose of the revenue s appeal as well as the ground raised by the assessee on this issue simultaneously. 14. The AO reduced travel expenses incurred in foreign currency of ₹ 2 .....

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Hon ble High Court has held as under: From the aforesaid judgments, what emerges is that. there should be uniformity in the ingredients of both the numerator and she denominator of the formula, since otherwise it would produce anomalies or absurd results. Sec. 10A is a beneficial section. It is intended to provide incentives to promote exports. The incentive is to exempt profits relatable to exports. In the case of combined business of an assessee, having export business and domestic business, t .....

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iness of an undertaking, it may include export business and domestic business, in other words, export turnover and domestic turnover. The export turnover would be a component, or part of a denominator, the other component being the domestic turnover. In other words, to the extent of export turnover, there would be a commonality between the numerator and the denominator of the formula. In view of the commonality, the understanding should also be the same. In other words, if the export turnover in .....

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the numerator that is export turnover would nevertheless form part of the denominator. Though when a particular word is not defined by the legislature and an ordinary meaning is to be attributed to the same, the said ordinary meaning to be attributed to such word is to be in conformity with the context in which it is used. When the statute prescribes a formula and in the said formula, export turnover is defined, and when the total turnover includes export turnover, the very same meaning given t .....

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