Contact us   Feedback   Annual Subscription   New User   Login      
Tax Management India .com
TMI - Tax Management India. Com
Extracts
Home List
← Previous Next →

2016 (4) TMI 389 - ITAT DELHI

2016 (4) TMI 389 - ITAT DELHI - TMI - Non-booking of excise duty refund as revenue in its profit and loss account - Held that:- Assessee collected Central Excise Duty in respect of the unit eligible for deduction under section 80IB of the Act, in the sale bills issued to the customers and subsequently paid to the Central Government, however, same payment was not claimed in the profit and loss account as expenses as the assessee was eligible for refund of the said duty from the Central Excise Dep .....

X X X X X X X

Extract - Part text only
Click here to Access Full Contents

X X X X X X X

finding of the ld. Commissioner of Income-tax(Appeals) on the issue in dispute - Decided against revenue

Deduction under section 80IB in respect of central excise duty refund - Held that:- Excise duty was part of the sale receipt and thus derived from the business of manufacturing activity. Deduction under section 80IB in respect of central excise duty refund allowed. See CIT versus Dharmpal Premchand Ltd [2008 (11) TMI 231 - DELHI HIGH COURT ] - Decided against revenue

Hig .....

X X X X X X X

Extract - Part text only
Click here to Access Full Contents

X X X X X X X

ed Commissioner of Income-tax(Appeals) on the issue in dispute is well reasoned and no interference on our part is required - Decided against revenue - ITA No. 6172/Del/2012, ITA No. 5063/Del/2011 - Dated:- 8-4-2016 - Smt. Diva Singh, Judicial Member And Sh. O. P. Kant, Accountant Member For the Appellant : Sh. K. Sampath & Raj Kumar, Advocates For the Respondent : Sh. P. DAM Kanunjna, Sr.DR ORDER Per O. P. Kant, A. M. These two appeals of the Revenue and the assessee are preferred against .....

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 Ld. CIT(A) has erred in deleting the addition of ₹ 10,18,41,937/-made by the AO on account of excise duty being refunded to the assessee but the same has not been booked as revenue. 2. The Ld. CIT(A) has erred in ignoring the fact that the excise is being refunded to the assessee but the same has not been booked as revenue. 3. The Ld. CIT(A) has erred in holding that the excise duty has been credited in profit and loss account and already accounted for in the receipts is factually wrong .....

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. 5. The Ld. CIT(A) has erred in deleting the disallowance made by the AO on the issue of deduction u/s 80-IB of the Act in view of the fact that excise duty refund does not have any direct nexus with the 'operational profit' derived by the assessee and will not qualify for deduction u/s 80IB, 6. The Ld. CIT(A) has not appreciated the facts of the case that the assessee company has made its whole of the sales to its own sister concern 'Mentha & Allied Products Ltd.', whe .....

X X X X X X X

Extract - Part text only
Click here to Access Full Contents

X X X X X X X

income filed, the assessee claimed deduction under section 80IB of the Income-tax Act, 1961 (for short the Act ) of ₹ 6,03,03,648/-. The case of the assessee was selected for scrutiny and notice under section 143(2) of the Act was issued and served within the stipulated period. It was observed by the Assessing Officer ( for short the AO") that the assessee had set up a unit in the State of Jammu and Kashmir and has been claiming deduction under section 80IB of the Act on the profit 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

ment was also not booked in profit and loss account. This contention of the assessee was not accepted and according to the AO excise refund of ₹ 9,91,86,041/- was not credited to the profit and loss account, he added the said sum to the income of the assessee. Further, the AO held that central excise duty refund was not derived from the industrial undertaking and it was in the nature of incentives granted by the government, and therefore not eligible for deduction under section 80IB of 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

ndings of the AO, the assessee filed appeal before the Commissioner of Incometax( Appeals), who allowed the appeal. Aggrieved, the Revenue is in appeal before the Tribunal challenging the findings of the ld. Commissioner of Incometax( Appeals). 4. In ground No. 1 to 3 of the appeal, the Revenue has raised the issue of non-booking of excise duty refund as revenue in its profit and loss account. 5. The ld. Department Representative ( in short DR ) relied on the order of the AO, whereas on the cont .....

X X X X X X X

Extract - Part text only
Click here to Access Full Contents

X X X X X X X

We have heard the rival submissions and perused the material on record. The learned Commissioner of Income-tax(Appeals) has decided the issue as under: So far as the first issue regarding the non inclusion of excise duty refund in the P&L account is concerned, the Assessing Officer was clearly in error. The sales bills, the sales account and figure of sales as taken in the P&L account are inclusive of the element of excise duty which has been charged in invoices and posted along-with inv .....

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 been highlighted by the appellant before the Assessing Officer. The excise duty as collected by the appellant having been shown as part of the sales, the Assessing Officer was clearly in error in once again including the same for assessment. 1 am also in agreement with the other point as raised on behalf of the appellant that the excise duty was required to be accounted for consistent with the method of accounting pursued by the appellant. Having pursued mercantile method of accounting, the ex .....

X X X X X X X

Extract - Part text only
Click here to Access Full Contents

X X X X X X X

excise duty collections. 5.2 We find that the assessee collected Central Excise Duty in respect of the unit eligible for deduction under section 80IB of the Act, in the sale bills issued to the customers and subsequently paid to the Central Government, however, same payment was not claimed in the profit and loss account as expenses as the assessee was eligible for refund of the said duty from the Central Excise Department, after verification of the payments in accordance to the notification issu .....

X X X X X X X

Extract - Part text only
Click here to Access Full Contents

X X X X X X X

cordingly, we uphold the finding of the ld. Commissioner of Income-tax(Appeals) and the grounds Nos. 1 to 3 of the Revenue are dismissed. 6. In ground Nos. 4 and 5, the Revenue has challenged allowing deduction under section 80IB of the Act in respect of central excise duty refund. 6.1 The ld. DR relying on the findings of the AO submitted that the central excise duty refund was an incentive granted by the government and not part of the profit derived from the Industrial Undertaking and, therefo .....

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 CIT versus Dharmpal Premchand Ltd (2009) 317 ITR 353 and submitted that the Special Leave Petition filed by the Revenue against the said decision was dismissed by the Hon ble Apex Court. He further reiterated the submission made before the ld. CIT(A) that Hon ble High Court of Guwahati in the case of Meghalya Steels Ltd in the order dated 16/09/2010 held that excise duty refund is covered under the purview of exemption provided under section 80-IB of the Act. 6.3 We have heard the rival subm .....

X X X X X X X

Extract - Part text only
Click here to Access Full Contents

X X X X X X X

referred to as the eligible business), there shall, in accordance with and subject to the provisions of this section, be allowed, in computing the total income of the assessee, a deduction from such profits and gains of an amount equal to such percentage and for such number of assessment years as specified in this section. (2) ……………………………….. 6.4 So claiming deduction under section 80-IB of the Act, the first prer .....

X X X X X X X

Extract - Part text only
Click here to Access Full Contents

X X X X X X X

xemption, the assessee first collected the excise duty on the goods from the customers and paid to the government and subsequently the assessee has been granted refund of the excise duty paid, in accordance with the notifications granting exemption to the assessee. The assessee claimed this excise duty refund as part of profit from the industrial undertaking and claimed deduction under section 80-IB of the Act. The assessee is treating this refund of excise duty as part of the profit of the unde .....

X X X X X X X

Extract - Part text only
Click here to Access Full Contents

X X X X X X X

same from the customers and therefore there was a direct nexus of the excise duty refund with the manufacturing activity carried out by the assessee. The assessee relied on the judgment of the Hon ble jurisdictional High Court in the case of Commissioner of Income Tax versus Dharmpal Premchand Ltd. reported in 317 ITR 353. In the said judgment, the Hon ble High Court has held as under: 5. Having considered the decisions cited by the learned counsel for the Revenue, as well as, by the counsel 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

and industrial activity. As a matter of fact, in the questions proposed by the Revenue, there is no specific question, that this finding of the authorities below is perverse. There is of course a very broad based and general question that the order passed by the Tribunal is perverse in law and on facts. According to us, such a question is vague. A perusal of the grounds of appeal would substantiate this aspect of the matter. There is no ground taken by the Revenue whereby the substantial findin .....

X X X X X X X

Extract - Part text only
Click here to Access Full Contents

X X X X X X X

ities. 6.6 Subsequent to the above judgment of the jurisdictional High Court, the Hon ble Supreme Court in the case of Liberty India versus CIT (supra) decided the issue of deduction under section 80-IB of the Act in respect of profit from duty drawback and DEPB and held that these are not profit derived from the industrial undertaking and, therefore, same are not eligible for deduction. The relevant findings of the Hon ble Supreme Court on the issue are as under: Discussions and findings: 12. 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

erefore, when s. 80-IA/80-IB refers to profits derived from eligible business, it is not the ownership of that business which attracts the incentives. What attracts the incentives under s. 80-IA/80-IB is the generation of profits (operational profits). For example, an assessee company located in Mumbai may have a business of building housing projects or a ship in Nava Sheva. Ownership of a ship per se will not attract s. 80-IB(6). It is the profits arising from the business of a ship which attra .....

X X X X X X X

Extract - Part text only
Click here to Access Full Contents

X X X X X X X

ligible business in sub-ss. (3) to (11A) constitutes a stand-alone item in the matter of computation of profits. That is the reason why the concept of "Segment Reporting" stands introduced in the Indian Accounting Standards (IAS) by the Institute of Chartered Accountants of India (ICAI). 14. Analyzing Chapter VI-A, we find that s. 80-IB/80-IA are the Code by themselves as they contain both substantive as well as procedural provisions. Therefore, we need to examine what these provisions .....

X X X X X X X

Extract - Part text only
Click here to Access Full Contents

X X X X X X X

y which arises for determination is: whether the DEPB credit/duty drawback receipt comes within the first degree sources? According to the assessee(s), DEPB credit/duty drawback receipt reduces the value of purchases (cost neutralization), hence, it comes within first degree source as it increases the net profit proportionately. On the other hand, according to the Department, DEPB credit/duty drawback receipt do not come within first degree source as the said incentives flow from Incentive Schem .....

X X X X X X X

Extract - Part text only
Click here to Access Full Contents

X X X X X X X

re. [see CIT vs. Kirloskar Oil Engines Ltd. (1985) 44 CTR (Bom) 98 : (1986) 157 ITR 762 (Bom)] 15. Continuing our analysis of s. 80-IA/80-IB it may be mentioned that sub-s. (13) of s. 80-IB provides for applicability of the provisions of sub-s. (5) and sub-ss. (7) to (12) of s. 80-IA, so far as may be, applicable to the eligible business under s. 80-IB. Therefore, at the outset, we stated that one needs to read ss. 80-I, 80-IA and 80-IB as having a common Scheme. On perusal of sub-s. (5) of s. 8 .....

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 80-IB have a common scheme and if so read it is clear that the said sections provide for incentives in the form of deduction(s) which are linked to profits and not to investment. On analysis of ss. 80-IA and 80-IB it becomes clear that any industrial undertaking, which becomes eligible on satisfying sub-s. (2), would be entitled to deduction under sub-s. (1) only to the extent of profits derived from such industrial undertaking after specified date(s). Hence, apart from eligibility, sub-s. (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

zation is provided for by credit to customs duty against export product. Under DEPB, an exporter may apply for credit as percentage of FOB value of exports made in freely convertible currency. Credit is available only against the export product and at rates specified by DGFT for import of raw materials, components etc. DEPB credit under the Scheme has to be calculated by taking into account the deemed import content of the export product as per basic customs duty and special additional duty paya .....

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 provide for repayment of customs and excise duty paid by an assessee. The refund is of the average amount of duty paid on materials of any particular class or description of goods used in the manufacture of export goods of specified class. The rules do not envisage a refund of an amount arithmetically equal to customs duty or central excise duty actually paid by an individual importer-cum-manufacturer. Sub-s. (2) of s. 75 of the Customs Act requires the amount of drawback to be determined on 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

nment of India. In the circumstances, we hold that profits derived by way of such incentives do not fall within the expression "profits derived from industrial undertaking" in s. 80-IB. 19. Since reliance was placed on behalf of the assessee(s) on AS-2 we need to analyse the said standard. 20. AS-2 deals with valuation of inventories. Inventories are assets held for sale in the course of business; in the production for such sale or in form of materials or supplies to be consumed in 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

rectly attributable to the acquisition. Hence trade discounts, rebate, duty drawback and such similar items are deducted in determining the costs of purchase. Therefore, duty drawback, rebate etc. should not be treated as adjustment (credited) to cost of purchase or manufacture of goods. They should be treated as separate items of revenue or income and accounted for accordingly (see : p. 44 of Indian Accounting Standards and GAAP by Dolphy D souza). Therefore, for the purposes of AS-2, Cenvat cr .....

X X X X X X X

Extract - Part text only
Click here to Access Full Contents

X X X X X X X

cturing, tax planning on sundry balances being written back, liquidation of current assets etc. Therefore, we are of the view that duty drawback, DEPB benefits, rebates etc. cannot be credited against the cost of manufacture of goods debited in the P&L a/c for purposes of s. 80-IA/80-IB as such remissions (credits) would constitute independent source of income beyond the first degree nexus between profits and the industrial undertaking. 23. We are of the view that Department has correctly ap .....

X X X X X X X

Extract - Part text only
Click here to Access Full Contents

X X X X X X X

ck receipt/DEPB benefits do not form part of the net profits of eligible industrial undertaking for the purposes of ss. 80-I/80-IA/80-IB of the 1961 Act. 25.The appeals are, accordingly, dismissed with no order as to costs. 6.7 The Ld AR submitted that the Special Leave Petition filed by the Revenue against the judgment of the Hon ble Jurisdictional High Court in the case of Commissioner of Income Tax versus Dharmpal Premchand Ltd (supra) was rejected by the Hon ble Apex Court and, therefore, th .....

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 (SC) 99 and Liberty India versus CIT (2009) 225 CTR (SC) 233. 6.9 In the case of Meghalya Steels Ltd ( supra), the assessee claimed deduction under section 80-IB of the Act on the subsidies received which consisted of transport subsidy, interest subsidy and power subsidy. The Hon ble Supreme Court held that all the subsidies are reimbursed to the assessee towards element of cost relating to manufacturing or sale of their products and thus there existed a direct nexus between the profit and gai .....

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 is in Cambay Electric Supply Industrial Company Limited v. Commissioner of Income Tax, Gujarat II, this Court held that since an expression of wider import had been used, namely "attributable to" instead of "derived from", the legislature intended to cover receipts from sources other than the actual conduct of the business of generation and distribution of electricity. In short, a step removed from the business of the industrial undertaking would also be subsumed within .....

X X X X X X X

Extract - Part text only
Click here to Access Full Contents

X X X X X X X

and gains are derived from business or an industrial undertaking. This Court has stated that there should be a direct nexus between such profits and gains and the industrial undertaking or business. Such nexus cannot be only incidental. It therefore found, on the facts before it, that by reason of an export promotion scheme, an assessee was entitled to import entitlements which it could thereafter sell. Obviously, the sale consideration therefrom could not be said to be directly from profits 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

to manufacture or sale of their products, there can certainly be said to be a direct nexus between profits and gains of the industrial undertaking or business, and reimbursement of such subsidies. However, Shri Radhakrishnan stressed the fact that the immediate source of the subsidies was the fact that the Government gave them and that, therefore, the immediate source not being from the business of the assessee, the element of directness is missing. We are afraid we cannot agree. What is to be .....

X X X X X X X

Extract - Part text only
Click here to Access Full Contents

X X X X X X X

gains" spoken of by Sections 80-IB and 80-IC have reference to net profit. And net profit can only be calculated by deducting from the sale price of an article all elements of cost which go into manufacturing or selling it. Thus understood, it is clear that profits and gains are derived from the business of the assessee, namely profits arrived at after deducting manufacturing cost and selling costs reimbursed to the assessee by the Government concerned. 19. Similarly, the judgment in Pandi .....

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 subsidies aforementioned went towards reimbursement of actual costs of manufacture and sale of the products of the business of the assessee. 20. Liberty India being the fourth judgment in this line also does not help Revenue. What this Court was concerned with was an export incentive, which is very far removed from reimbursement of an element of cost. A DEPB drawback scheme is not related to the business of an industrial undertaking for manufacturing or selling its products. DEPB entitlement .....

X X X X X X X

Extract - Part text only
Click here to Access Full Contents

X X X X X X X

provided for by credit to customs duty against the export product. In such a scenario, it cannot be said that such duty exemption scheme is derived from profits and gains made by the industrial undertaking or business itself. 21. The Calcutta High Court in Merino Ply & Chemicals Ltd. v. CIT, 209 ITR 508 [1994], held that transport subsidies were inseparably connected with the business carried on by the assessee. In that case, the Division Bench held:- "We do not find any perversity 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

recoupment is to make up possible profit deficit for operating in a backward area. Therefore, it is beyond all manner of doubt that the subsidies were inseparably connected with the profitable conduct of the business and in arriving at such a decision on the facts the Tribunal committed no error." 22. However, in CIT v. Andaman Timber Industries Ltd., 242 ITR 204 [2000], the same High Court arrived at an opposite conclusion in considering whether a deduction was allowable under Section 80H .....

X X X X X X X

Extract - Part text only
Click here to Access Full Contents

X X X X X X X

ndhyopadhyay, learned Advocate appearing for the appellant, submitted that the impugned judgment is contrary to a judgment of this Court in the case of CIT v. Andaman Timber Industries Ltd. reported in (2000) 242 ITR, 204 wherein this Court held that transport subsidy is not an immediate source and does not have direct nexus with the activity of an industrial undertaking. Therefore, the amount representing such subsidy cannot be treated as profit derived from the industrial undertaking. Mr. Band .....

X X X X X X X

Extract - Part text only
Click here to Access Full Contents

X X X X X X X

adhyay. The judgment of the Apex Court in the case of Liberty India(supra) was in relation to the subsidy arising out of customs draw back and duty Entitlement Pass-book Scheme (DEPB). Both the incentives considered by the Apex Court in the case of Liberty India could be availed after the manufacturing activity was over and exports were made. But, we are concerned in this case with the transport and interest subsidy which has a direct nexus with the manufacturing activity inasmuch as these subsi .....

X X X X X X X

Extract - Part text only
Click here to Access Full Contents

X X X X X X X

like setting up the plant and machinery, the incentives will not be given. Refund of sales tax will also be in respect of taxes levied after commencement of production and up to a period of five years from the date of commencement of production. It is difficult to hold these subsidies as anything but operation subsidies. These subsidies were given to encourage setting up of industries in the State of Andhra Pradesh by making the business of production and sale of goods in the State more profita .....

X X X X X X X

Extract - Part text only
Click here to Access Full Contents

X X X X X X X

enue, by levy and collection of tax or duty. The object of the Scheme is to improve trade and commerce between the remote parts of the country with other parts, so as to bring about economic development of remote backward regions. This was sought to be achieved by the Scheme, by making it feasible and attractive to industrial entrepreneurs to start and run industries in remote parts, by giving them a level playing field so that they could compete with their counterparts in central (nonremote) ar .....

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 cost of transportation between a point in central area (Siliguri in West Bengal) and the actual location of the industrial unit in the remote area, so that the industry could become competitive and economically viable." (Paras 14 and 15) 25. The decision in Sahney Steel and Press Works Ltd. v. Commissioner of Income Tax, A.P. - I, Hyderabad (1997) 7 SCC 764, dealt with subsidy received from the State Government in the form of refund of sales tax paid on raw materials, machinery, and fi .....

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 before us being CIT v. Dharampal Premchand Ltd., 317 ITR 353 from which an SLP preferred in the Supreme Court was dismissed. This judgment also concerned itself with Section 80-IB of the Act, in which it was held that refund of excise duty should not be excluded in arriving at the profit derived from business for the purpose of claiming deduction under Section 80-IB of the Act. 28. It only remains to consider one further argument by Shri Radhakrishnan. He has argued that as the subsidies that .....

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 head "income from other sources", which is a residuary head of income that can be availed only if income does not fall under any of the other four heads of income. Section 28(iii)(b) specifically states that income from cash assistance, by whatever name called, received or receivable by any person against exports under any scheme of the Government of India, will be income chargeable to income tax under the head "profits and gains of business or profession". If cash assista .....

X X X X X X X

Extract - Part text only
Click here to Access Full Contents

X X X X X X X

, Calcutta and Delhi High Courts have correctly construed Sections 80-IB and 80-IC. The Himachal Pradesh High Court, having wrongly interpreted the judgments in Sterling Foods and Liberty India to arrive at the opposite conclusion, is held to be wrongly decided for the reasons given by us hereinabove. 6.10 We find from the para 29 of the aforesaid judgment that the judgment of the Hon ble Delhi High Court in the case of the Dharmpal Premchand Ltd. (supra) , where also the issue of deduction unde .....

X X X X X X X

Extract - Part text only
Click here to Access Full Contents

X X X X X X X

6 the Revenue has raised the issue of higher deduction claimed by the assessee under section 80-IB of the Act in respect of the sales made to its sister concern. 7.1 The Ld DR relying on the order of the Assessing Officer submitted that entire sales were made to the sister concern namely M/s Mentha & Allied products Ltd (MAPL) and the gross profit rate of the assessee was higher than the other concerns in similar trade ,therefore the restricting of the deduction to normal profit at the rate .....

X X X X X X X

Extract - Part text only
Click here to Access Full Contents

X X X X X X X

ome-tax(Appeals) has decided the issue as under: 3.1 I have considered the findings of the Assessing Officer and the arguments advanced on behalf of the appellant. I have also examined the bills of the unrelated parties who have supplied the same commodity to Mentha & Allied Products Ltd. during the same year. The rate variations as noticed by me in the invoices are only marginal and in fact in many cases the rates at which the appellant has sold to Mentha & Allied Products Ltd. are lowe .....

X X X X X X X

Extract - Part text only
Click here to Access Full Contents

X X X X X X X

agree with the appellant that the net profit realization is not a proper indication of the trading result and that a safer and more reliable estimate would be the gross profit realization. The appellant has shown the profits of the preceding years where from it is evident that the results of the subject year are not as attractive as those of the preceding years. From the assessment order of Mentha & Allied Products Ltd., it is clear that if facts as narrated by the Assessing Officer in 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

ppellant could not be compared with the current rates of outsiders with Mentha & Allied Products Ltd. In the circumstances of the case there appears to be no justification for disturbing the book result by the Assessing Officer after taking recourse to Section 80- IA (10) of the Act. The interference as made by the Assessing Officer is 5n erroneous premises and unnecessary. The claim as made by the appellant is found to be correct. The ground of appeal stands allowed. 7.4 We find that the sa .....

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