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

2016 (5) TMI 58 - ITAT DELHI

2016 (5) TMI 58 - ITAT DELHI - [2016] 45 ITR (Trib) 448 - Deemed dividend u/s 2(22) - Loan / Advances received from public company cum NBFC - Held that:- The assessee before the Assessing Officer and the learned Commissioner of Income-tax (Appeals) has submitted that both these companies are public limited companies and they have produced evidences to substantiate that the STLL is a listed company at the Delhi Stock Exchange and Jaipur Stock Exchange and also the shareholding pattern as on March .....

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 and it cannot be stretched to more than that for which the deeming provision can be literally interpreted. Nothing can be added or implied while interpreting a deeming provision. One can only look at the language used. Therefore, we concur with the learned Commissioner of Income-tax (Appeals) that the lender company, i.e., M/s. STLL is a public limited company and so the loan/advance/ICD given to the assessee does not fall in the ken of section 2(22)(e) and moreover, the lender company is a NB .....

X X X X X X X

Extract - Part text only
Click here to Access Full Contents

X X X X X X X

for the investment, could not be controverted by both the authorities below. The Assessing Officer erred in concluding that since the assessee-company is incurring interest expenditure so no surplus fund is available to the assessee-company is erroneous on the fact that the total shareholder fund without interest burden is to the tune of ₹ 34.46 crores and, therefore, thus we have no hesitation to delete the disallowance. See East India Pharmaceutical Works Ltd. v. CIT [1997 (3) TMI 5 - 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

r 2008-09. 2. First we take up the Revenue's appeal being I. T. A. No. 2768/Del/2012. 3. The solitary ground taken by the Revenue is against the deletion of addition of ₹ 1,03,12,934 made by the Assessing Officer under section 2(22)(e) of the Income-tax Act, 1961 (hereinafter "the Act"). 4. The assessee is engaged in the business of civil construction. During the year under consideration, the return of income declaring total income of ₹ 35,26,578 was filed on September .....

X X X X X X X

Extract - Part text only
Click here to Access Full Contents

X X X X X X X

claims, one of the issues is against the addition of ₹ 1,03,12,934 under section 2(22)(e) of the Act, which is the dispute in the present appeal. The facts relating to this issue are as follows. 6. The Assessing Officer vide show-cause notice dated December 9, 2010, asked the assessee to explain as to why loan of ₹ 1,03,12,934 taken from M/s. Sindhu Trade Links Ltd. (hereinafter "STLL") be not treated as deemed dividend in view of the facts that directors of the assessee- 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

ending business. (ii) M/s. STLL is a listed company on the Delhi stock exchange and Jaipur stock exchange. Proof of being listed is enclosed herewith. Section 2(22)(e) of the Income-tax Act, 1961, is applicable only in respect of closely held companies. (iii) M/s. Sindhu Realtor Pvt. Ltd. is not holding more than 10 per cent. shares in M/s. STLL. (copy of shareholding of M/s. Sindhu Trade Links Ltd. is enclosed herewith). Hence section 2(22)(e) of the Income-tax Act, 1961, is not applicable. (iv .....

X X X X X X X

Extract - Part text only
Click here to Access Full Contents

X X X X X X X

ssessee's submission that STLL is a public limited company and is in the category of NBFC, the Assessing Officer observed that it has no merit on the issue because of the following reasons : (i) "Sindhu Trade Links Ltd." (STLL) is a limited company only because its paid-up share capital base is more than ₹ 5 crores but it is not a widely held public limited company in which the public are substantially interested, as envisaged in section 2(22)(e) of the Income-tax Act, 1961. .....

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 whether with or without a right to participate in profits) holding not less than ten per cent. of the voting power, or to any concern in which such shareholder is a member or a partner and in which he has a substantial interest (hereafter in this clause referred to as the said concern) or any payment by any such company on behalf, or for the individual benefit, of any such shareholder, to the extent to which the company in either case possesses accumulated profits ; (ii) Although the STLL has .....

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 year under review. The company does not hold any public deposit as on date and will not accept the same in future without the prior approval of the Reserve Bank of India in writing. (iv) The authorised representative vide letter dated December 13, 2010, has furnished shareholding pattern of STLL as on March 31, 2008. It is seen from there that though the authorised representative submitted that the STLL is a public limited company, but has failed to substantiate that it is a public limited 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

4. Shri Dev Suman Sindhu 5. Shri Vrit Pal Sindhu As regards the assertion of the authorised representative that the company STLL is a public limited company, it is being demonstrated here with that this is not "a company in which public are substantially interested" because- This is a company in which shares have not been traded by the public at large ; a. Although the authorised representative has claimed that the STLL is a listed company at Delhi Stock Exchange and Jaipur Stock Exch .....

X X X X X X X

Extract - Part text only
Click here to Access Full Contents

X X X X X X X

there were 279 share holders of this company, but major quantity of shares were held by Mr. Sindhu and his family members/associates. 8. The Assessing Officer observed that out of five directors, Sindhu and his family members themselves control nearly 59 per cent. shareholdings of the STLL and in this situation, it could not be accepted that the STLL was a public company where public was substantially interested. He further observed that the percentage of shares of other directors and their fam .....

X X X X X X X

Extract - Part text only
Click here to Access Full Contents

X X X X X X X

blic limited company in which the public were substantially interested and the onus was also on the assessee-company that the shares of the STLL were widely traded and its shares were available in the open market for purchase and sale by any common man/person and held that the assessee failed to discharge its onus and the Assessing Officer countered the submissions of the assessee that the STLL was an NBFC and therefore the deeming provision of section 2(22)(e) would not be applicable by giving .....

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 as this assessee is concerned, it has failed to substantiate that the transactions by the STLL in the form of advances or loans were 'in the ordinary course of its business'. The onus was cast on the assessee-company to substantiate that the loans and advances received by it from the group company or associates company (STLL), in which common directors are beneficial shareholders, were in the ordinary course of business, i.e., advancing of loans and advances on interest of the payer 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

10. Aggrieved, the assessee went in appeal before the learned Commissioner of Income-tax (Appeals) who deleted the addition by observing as under : "Ground Nos. 4, 5, 6 and 7 : Addition of ₹ 1.03 crores under section 2(22)(e) of the Income-tax Act, 1961, being inter corporate deposit received from company holding NBFC certificate. The Assessing Officer made the above addition on account of loans received from two companies, holding them to be associated companies as well as companies .....

X X X X X X X

Extract - Part text only
Click here to Access Full Contents

X X X X X X X

eful perusal, reproducing the same was not found called for since the material issue is whether section 2(22)(e) of the Act is applicable in this case. b. The appellant has submitted extensive arguments on this issue. Again, the crucial issue is found to be whether the lender companies are ones in which the public are substantially interested. Section 2(22)(e) : Not applicable to widely held companies : Section 2(22)(e) uses the words : any payment by a company 'not being a company in which .....

X X X X X X X

Extract - Part text only
Click here to Access Full Contents

X X X X X X X

her in item (A) or in item (B) are fulfilled, namely : (A) shares in the company (not being shares entitled to a fixed rate of dividend whether with or without a further right to participate in profits) were, as on the last day of the relevant previous year, listed in a recognised stock exchange in India in accordance with the Securities Contracts (Regulation) Act, 1956 (42 of 1956), and any rules made thereunder ;' It was vehemently argued that these conditions are fulfilled by the lender 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

all the words of Rowlatt J in Cape Brandy Syndicate v. Inland Revenue Commissioners [1921] 1 KB 64 at page 71, that : '. . . in a taxing Act one has to look merely at what is clearly said. There is no room for any intendment. There is no equity about a tax. There is no presumption as to a tax. Nothing is to be read in, nothing is to be implied. One can only look fairly at the language used'. Even while quoting this in the assessment order the Assessing Officer seeks to go beyond the inte .....

X X X X X X X

Extract - Part text only
Click here to Access Full Contents

X X X X X X X

eted. This ground is ruled in favour of the appellant." 11. The Revenue, being aggrieved, is in appeal before us on the aforesaid issue. 12. The learned Departmental representative relied on the order of the Assessing Officer and submitted that loan of ₹ 1.03 crores taken from M/ s. Sindhu Trade Links Ltd. (STLL) was rightly treated as deemed dividend in view of the facts that directors of the assessee-company are substantially interested in the said company and also some of the share .....

X X X X X X X

Extract - Part text only
Click here to Access Full Contents

X X X X X X X

, rather it was a company which was closely held by the promoter Mr. Sindhu and his family members and therefore the saving clause (ii) of section 2(22) of the Act would not be applicable and come to the rescue of the assessee- company insofar as invoking section 2(22)(e) was concerned. The learned Departmental representative submitted that the assessee failed to prove the onus that STLL was a widely held public limited company in which the public were substantially interested and that the share .....

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 by the Assessing Officer. 13. The learned authorised representative for the assessee reiterated the submissions made before the learned Commissioner of Income-tax (Appeals) and for the sake of clarity, the same are reproduced hereunder : "Ground III-Amount involved is ₹ 1,03,12,934 The appellant-company has received inter corporate deposits of ₹ 1.03 crores from M/s. Sindhu Trade Links Ltd. (STLL) during the year under assessment. The appellant-company was show-caused vide no .....

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 Act be invoked.' It was submitted vide letter dated December 13, 2010 (copy enclosed) that STLL is a NBFC certificate holding company and also stock exchange listed company. Proof of being NBFC and listed companies was submitted during the course of assessment proceedings. It was also pleaded while submitting the shareholding charts of STLL that the appellant-company is not holding shares exceeding 10 per cent. of M/s. Sindhu Trade Links Ltd.'s total shareholding. Also none 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

y, not being a company in which the public are substantially interested, of any sum (whether as represent ing a part of the assets of the company or otherwise) made after the 31st day of May, 1987, by way of advance or loan to a shareholder, being a person who is the beneficial owner of shares (not being shares entitled to a fixed rate of dividend whether with or without a right to participate in profits) holding not less than ten per cent. of the voting power, or to any concern in which such sh .....

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 money is a substantial part of the business of the company ; The assessee-company submitted the interpretation of the section point-wise vis-a-vis observation of the learned Assessing Officer as follows : 1. Section 2(22)(e) : Shareholding conditions not applicable Section 2(22)(e) of the Income-tax Act, 1961, is attracted when a shareholder having shares not less than 10 per cent. receive any advance or loan from such company or any concern receive any advance or loan from such company in w .....

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 STLL that there is no shareholder holding 10 per cent. in these companies, who is further holding 20 per cent. in the assessee-company. Hence section 2(22)(e) of the Income-tax Act, 1961, is not applicable since shareholding condition, mandatory for applicability of section 2(22)(e) of the Income-tax Act, 1961, are not satisfied. Section 2(22)(e) applicable in the hands of shareholder : Neither the appellant-company is shareholder in these companies nor there is a shareholder holding 10 per 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

as under : (18) 'company in which the public are substantially interested'-A company is said to be a company in which the public are substantially interested- (b) if it is a company which is not a private company as defined in the Companies Act, 1956 (1 of 1956), and the conditions specified either in item (A) or in item (B) are fulfilled, namely :- (A) shares in the company (not being shares entitled to a fixed rate of dividend whether with or without a further right to participate in p .....

X X X X X X X

Extract - Part text only
Click here to Access Full Contents

X X X X X X X

change and Jaipur Stock Exchange. (b) Shareholding pattern as on March 31, 2008, of the assessee- company. Stand taken by the learned Assessing Officer : a. The learned Assessing Officer has observed on page 10-paras (ii) and (iii) that for STLL, in the director's report, it has been stated that shares were not traded during the year and also further stated that company has not accepted the public deposits. b. The learned Assessing Officer observed at page 11 that STLL has claimed that it 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

arned Assessing Officer's observation : The assessee-company replied to the observations made by the learned Assessing Officer point-wise : a. Trading of shares and acceptance of public deposit are no parameters to check whether a company is a widely held company or not. It is section 2(18) definition which should prevail while assessing whether a company is a company, in which public is substantially interested or not. b. The allegation of the learned Assessing Officer that the appellant- 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

spended or delisted, stock exchanges would not have raised the annual listing fee bills. Further as per information available in public domain on Delhi Stock Exchange website at http://www.dseindia.org.in/sitepages/list companies.php it can be seen that STLL is a listed company on Delhi Stock Exchange. Since the list involve 2830 companies, the assessee- company submitted the relevant extract showing evidence in regard to STLL only. Further submitted that there was no adverse material on record .....

X X X X X X X

Extract - Part text only
Click here to Access Full Contents

X X X X X X X

ern of NSE/BSE listed reputed companies for DLF Ltd., TATA Consultancy Services Ltd., Reliance Ltd. as on March 31, 2008 have been placed on record. The same is available in public domain on the websites of NSE and BSE. The assessee-company submitted that from the shareholding pattern of these companies, it can be seen that promoter shareholding for these companies is much more that what is for the assessee- company. Somewhere it is hovering around 88 per cent. Still they are regarded as listed .....

X X X X X X X

Extract - Part text only
Click here to Access Full Contents

X X X X X X X

xchange that : (b) At least 10 per cent. of each class or kind of securities issued by a company was offered to the public for subscription through advertisement in newspapers for a period not less than two days and that applications received in pursuance of such offer were allotted subject to the following conditions : (a) minimum 20 lakhs securities (excluding reservations, firm allotment and promoters contribution) was offered to the public ; Provided that if a company does not fulfil the con .....

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 inter corporate deposits Provisions of section 2(22)(e) of the Income-tax Act, 1961, are not applicable to inter corporate deposits. They are applicable to payments by way of advance or loans only. Reliance in this regard has been placed on Bombay Oil Industries Ltd. v. Deputy CIT [2009] 28 SOT 383 (Mumbai) (copy placed on record) wherein the hon'ble Income-tax Appellate Tribunal, Mumbai, has held that since there is a clear distinction between the words advance or loan and inter corpora .....

X X X X X X X

Extract - Part text only
Click here to Access Full Contents

X X X X X X X

mpany. The assessee-company submitted that the appellant-company is not a shareholder in the STLL, further note that the STLL is a non- banking finance company and registered with the Reserve Bank of India since 1998 in category of loan investment company and engaged in activities of shares sale, financial activities, loan syndication activities and hypothecation activities. Proof of being NBFC companies was submitted during the course of assessment proceedings vide letter dated December 13, 201 .....

X X X X X X X

Extract - Part text only
Click here to Access Full Contents

X X X X X X X

ils shows that STLL is perusing NBFC activities and inter corporate deposit has also been advanced in the ordinary course of activities." 14. We have heard both sides and perused the material on record. The only dispute is whether the lender companies which has made deposits (inter corporate deposits (ICD)) will fall under the deeming provision under section 2(22)(e) of the Act or not. We find that section 2(22)(e) excludes public company "not being a company in which the public are su .....

X X X X X X X

Extract - Part text only
Click here to Access Full Contents

X X X X X X X

dividend whether with or without a further right to participate in profits) were, as on the last day of the relevant previous year, listed in a recognised stock exchange in India in accordance with the Securities Contracts (Regulation) Act, 1956 (42 of 1956), and any rules made thereunder." 15. We find that the assessee before the Assessing Officer and the learned Commissioner of Income-tax (Appeals) has submitted that both these companies are public limited companies and they have produced .....

X X X X X X X

Extract - Part text only
Click here to Access Full Contents

X X X X X X X

activities, loan syndication activities and hypothecation activities. It is a well-settled principle of law that deeming provision has to be interpreted strictly and it cannot be stretched to more than that for which the deeming provision can be literally interpreted. Nothing can be added or implied while interpreting a deeming provision. One can only look at the language used. Therefore, we concur with the learned Commissioner of Income-tax (Appeals) that the lender company, i.e., M/s. STLL 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

T. A. No. 2706/Del/2012. The effective ground taken by the assessee is against confirming the disallowance of total interest debited to profit and loss account of ₹ 16,15,903 in view of the fact that the assessee has given share application money of ₹ 9.86 crores which is not earning any interest income and the assessee has no surplus funds without appreciating that the assessee-company is available with interest-free shareholder funds of ₹ 34.46 crores. 18. The Assessing Offic .....

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 or not and he further show caused as to in the case of non-allotment of such shares why not an appropriate rate of interest be charged thereupon in view of the facts that it is bearing an interest burden of ₹ 16,15,903 apart from bank charges of ₹ 47,906. He further observed that the assessee had made a veiled attempt to show that it was not bearing any interest burden due to amount paid as share application money. After observing the assessee's contention and the details furni .....

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 not in the business of finance and it was also not a NBFC company it could not be said that it had advanced this much huge amount in the ordinary course of business. He further opined that the assessee was in the business of civil construction where money was very much required and further, the assessee had not proved that the money which it advanced in the form of/in the garb of share application money were actually allotted to the assessee. He held that the assessee had failed to substanti .....

X X X X X X X

Extract - Part text only
Click here to Access Full Contents

X X X X X X X

ssing Officer, however, observed that keeping in line with the various hon'ble courts, interest could be disallowed from the profit and loss account to the extent of quantum of fund diverted by the assessee to other persons and where no interest was charged or interest was charged at lower rate of interest. Accordingly, the Assessing Officer was of the opinion that interest was disallowable for diversion of fund of ₹ 9,86,87,800 and if the same was calculated at the rate of 18 per cent .....

X X X X X X X

Extract - Part text only
Click here to Access Full Contents

X X X X X X X

unt. Accordingly, the Assessing Officer ordered to disallow the interest debited to the profit and loss account and made an addition of ₹ 16,15,903 to the income of the assessee. 19. Aggrieved, the assessee went in appeal before the learned Commissioner of Income-tax (Appeals) who confirmed the action of the Assessing Officer on this issue. 20. The learned authorised representative reiterated the submissions made before the learned Commissioner of Income-tax (Appeals) and the relevant 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

advances to other parties to pursue to strategic goals by making investments in other companies. Allegation No. 2 The assessee-company has failed to substantiate as to whether the money advanced in the garb of share application money will give any income to the assessee-company in the ordinary course of business. The assessee-company has not shown any return on income/interest on these amounts. (page 3 of the assessment order). Reply to allegation : The investment are generally made to gain in 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

g of people who has long-term horizon for making investments. Though in the case of appellant-company, no allotment was made but this is purely normal. Even in the case of IPDs, people do get back their money back due to non-allotment of shares. Also there is no binding provision in SEBI or Companies Acts for non-listed companies to pay interest if no share allotment has been made in reasonable time. Merely the fact that no income has accrued, is that mean that transaction was for non-business p .....

X X X X X X X

Extract - Part text only
Click here to Access Full Contents

X X X X X X X

course of assessment proceedings also, it is pretty clear that the appellant-company has sufficient free funds and it is free to use them at his own discretion according to needs. It is not open to the learned Assessing Officer to assess what the need of the appellant-company is ? It is a decision which is normally entrusted by the shareholders of the company to its faithful management who take the decisions depending upon the financial needs, aspirations, goals or objects set for the company. .....

X X X X X X X

Extract - Part text only
Click here to Access Full Contents

X X X X X X X

urnished above evidence the fact that the appellant-company was available with more than sufficient free funds for use at its own discretion. Reliance is placed on CIT v. Hotel Savera [1999] 239 ITR 795 (Mad), wherein the hon'ble Madras High Court has held that once it is established that the assessee-company is having sufficient free funds, presumption would always be made that advances to third parties have been made out of own free funds. Further the assessee-company submitted that where .....

X X X X X X X

Extract - Part text only
Click here to Access Full Contents

X X X X X X X

egard is placed on CIT v. Reliance Utilities and Power Ltd., I. T. A. No. 1398 of 2008 (Mumbai High Court) pronounced on January 9, 2009 [2009] 313 ITR 340 (Bom). (Copy of judgment placed on record). Hence the assessee-company pleaded disallowance made of interest shall be deleted since the appellant-company has utilised borrowed money for the purposes of earning income and interest-free funds of ₹ 34.46 crores means they are in abundance considering the amount of share application money 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

loss account of ₹ 16,15,903 for the reason that the assessee-company has given advance/share application money of ₹ 9.86 crores which is not yielding any interest income and made a finding also that the assessee- company has no surplus fund since it has also borrowed funds which is bearing an interest burden of ₹ 16,15,903 apart from bank charges of ₹ 47,906. So, according to the Assessing Officer, since share certificates have not been allotted to the assessee-company, .....

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 disallowance only to that extent. He also noted that the fact that the assessee had taken interest bearing loans shows that the assessee does not have any surplus funds. During the appellate proceedings, the assessee's claim that it had sufficient surplus fund which is to the tune of ₹ 34.46 crores and the amount of share application money/advances paid is only ₹ 9.86 crores that works out to 28.63 per cent. of the total shareholder funds has not been taken into consideration 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

under the guise of share application money. Before us, the learned authorised representative took our attention to the following facts which are revealed by perusal of balance-sheet as on March 31, 2008, which is as below : Following is the shareholders fund position of the appellant-company as on March 31, 2008 : (Rs.) Paid-up share capital 2,62,00,000 Share premium 2,34,00,000 Profit and loss account 62,84,839 Share application money 28,88,00,000 Total shareholder fund available without intere .....

X X X X X X X

Extract - Part text only
Click here to Access Full Contents

X X X X X X X

ht to the judgment of the hon'ble Bombay High Court in the case of CIT v. Reliance Utilities and Power Ltd. [2009] 313 ITR 340 (Bom), wherein the judgment of the hon'ble Supreme Court in the case of East India Pharmaceutical Works Ltd. v. CIT [1997] 224 ITR 627 (SC) and the hon'ble Calcutta High Court in Woolcombers of India Ltd. v. CIT [1982] 134 ITR 219 (Cal) relied on, held as under (page 344 of 313 ITR) : "16. If there be interest-free funds available to an assessee sufficie .....

X X X X X X X

Extract - Part text only
Click here to Access Full Contents

X X X X X X X

at in essence and true character the taxes were paid out of the profits of the relevant year and not out of the overdraft account for the running of the business and in these circumstances the appellant was entitled to claim the deductions. The Supreme Court noted that the argument had considerable force, but considering the fact that the contention had not been advanced earlier it did not require to be answered. It then noted that in Wool comber's case (supra) the Calcutta High Court had 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

 

 

 

 

 



|| 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