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“Success is the result of small efforts, repeated

day in and day out.”

-R.Colier

INTEGRITY FIRST

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Cost

S. No. Topic

1.

Unitech under the radar of insolvency

2.

Corporate social responsibility

3.

Evaluation of digital controls

INDEX

Radar of

Insolvency

This article aims to highlight

Radar of Insolvency

CA Kunal Jain and Ayush Khandelwal

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Unitech under the radar of insolvency

Introduction

Unitech Limited is India's second largest real estate investment company, and has recently claimed to be the largest real estate builder in the country. The company is based in New Delhi and ranks 1484, in Forbes Global 2000 listing of the top 2000 public companies in the world by Forbes magazine, 32nd in India. Its construction business includes highways, roads, powerhouses, transmission lines, and it has residential projects called Unitech Cities/Uni World, in cities like Mumbai, Delhi, Kolkata, Chennai, Hyderabad, Mohali, Bangalore, Kochi, Noida, Greater Noida, Agra, Lucknow, Varanasi, Gurgaon, and Ghaziabad.

The company is founded by 5 partners, Ramesh Chandra, Dr. S. P. Srivastava, Dr. P K Mohanti, Dr. Ramesh Kapoor and Dr. Bahri originally formed as United Technical Consultant Private Ltd in 1972 as a soil investigation company. They later moved into civil engineering contracts in 1974. The company began to enter into real estate in 1986. and started to increase focus on Real Estate in 2000. Today, it is India's second-largest listed real estate firm after DLF ltd.

Reason for Downfall

Unitech had formed a large joint venture with Norway-based Telenor Group to create Unitech Wireless Ltd., in August 2009, it secured a 50 billion rupee ($1 billion) loan from State Bank of India (SBI.BO) to fund its mobile phone network rollout. And after almost 2 years in 2011, due to the 2G-spectrum scam controversy, the company got involved in a public spat due to which its Chairman Sanjay Chandra al while on bail over Telenor's pressure to do so, followed by news of Unitech's settlement of issues by agreeing to sell its entire stake in the Unitech Wireless to shift the business to a new entity owned by the former almost 1 year later and then Telenor shifted the erstwhile United Wireless' entire assets into a newly formed holding company as its majority-owned subsidiary Telewings Communications Services Pvt. Ltd., another JV which 26% stake was owned by an investment firm named Lakshdeep Investments & Finance Pvt. Ltd. and rest of the 74% owned by Telenor directly, thus sealing the end of Unitech's presence into telecommunications so far, only after 15 days since last development.

Unitech Wireless is one of the accused in the 2G spectrum scam. It is alleged that they were able to attain 2G licenses by bribing officials in the Indian Government even though they didn't have any previous telecom experience. As a fallout of this they had a total of 22 licenses cancelled by virtue of a court order, and their Managing Director Sanjay Chandra sent to jail.

Unitech, once the country‟s second largest real estate firm after DLF Ltd, owes a total of over Rs7,800 crore to 16,300

home buyers in 61 projects, according to data collated by Mint. The MCA petition, parts of which were seen by Mint,

cites the fate of 19,000 home buyers, 15000 small depositors and 7 lakh shareholders as being of public interest. The

firm has also defaulted on debentures worth Rs 251.78 crore and owes small depositors Rs 596.76 crore.

The move comes amid turmoil in India‟s real estate sector after a prolonged slowdown. Insolvency proceedings have

been initiated against promoters of many realty firms, including Amrapali Group and Jaypee Infratech, after angry

customers dragged the builders to court. Last month, the government amended the insolvency and bankruptcy code to

include home buyers as a class of creditors to real estate firms.

Highlights of Unitech’s insolvency

The National Company Law Tribunal (NCLT) suspended directors of Unitech Ltd and allowed the government

to appoint nominees to the board as the ministry of corporate affairs (MCA) moved to take over the indebted

real estate firm -- a step with few precedents in India‟s corporate and legal landscape.

NCLT issued notices to Unitech and sought a response in four weeks. The tribunal will examine the names of

the 10 directors to be nominated by the government on December 20. The directors appointed by the

government would comply with all the orders of the Supreme Court which is overseeing the recovery of dues

and refunds to over 4,688 home buyers, said the NCLT after hearing Unitech‟s lawyers.

Flats in Unitech's Vistas project were booked in 2009. However, after Unitech failed to deliver the project on

time, homebuyers moved to National Consumer Disputes Redressal Commission in 2014 and consumer forum

then ordered Unitech to pay the principal with an interest of 18 per cent.

The MCA is seeking to take control of the private firm as there are allegations of fund diversion against the

company, said a person aware of the matter. It has filed its petition under section 241 of the Companies Act,

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2013 that allows the government to apply to the tribunal if it feels that a company is operating in a manner

prejudicial to public interest -- in this case, homebuyers, shareholders and depositors.

This is only the second time that the government is invoking public interest to take over a private firm after

Satyam Computer Services, whose founder Ramalinga Raju admitted in 2009 to fudging the books of the

company over several years to the tune of Rs.7,136 crore.

The NCLT observed that there is a prima facie case that the affairs of the company are not being carried out

honestly and there are a large number of irregularities in the company.

The government is empowered to proceed under Section 241 of the Companies Act for mismanagement

against a company. However, Supreme Court is already hearing pleas against Unitech‟s default in handing

over several residential projects in Delhi-NCR, and NCLT is subordinate to Supreme Court. The ultimate aim

is to secure the interests of the consumer and Supreme Court is monitoring the issue,” said Aishwarya Sinha,

counsel for homebuyers who haven‟t got possession of their flats.

The NCLT also restrained Sanjay Chandra and Ajay Chandra, directors of Unitech, from engaging in

transactions related to their personal wealth till an investigation into alleged siphoning and diversion of

money are concluded.

Sanjay and Ajay Chandra, part of the firm‟s promoter family, were arrested in a case of alleged forgery

lodged by buyers of homes in a Gurugram Unitech project. On October 30, the Supreme Court directed

Unitech to deposit Rs 750 crore by December to secure bail for Sanjay Chandra.

Unitech shares rose 20% to hit the upper circuit at Rs 7.29 on the BSE after the reports about the

government‟s move to take over the company emerged.

A day after the Supreme Court expressed serious apprehension about the manner in which the Centre moved

the National Company Law Tribunal (NCLT) to take control of embattled real estate firm Unitech Ltd‟s board

without seeking its permission, the apex court decided to stay the NCLT order. The stay of NCLT‟s order

Friday means that Unitech‟s promoter Sanjay Chandra, who is currently in jail, can now resume negotiations

from prison for sale of assets to generate Rs 750 crore that he has been asked to deposit in court by end of this

month.

Some legal experts say that “it would have been best that the government taken over the company and turned

it around by getting a new promoter, just as what it did in the case of Satyam,”

The government for once made a move to protect the interest of stuck home buyers but committed a huge

procedural error by not approaching the top court first. A court or tribunal does not have a carte blanche to

pass an order of its liking when a case is brought before it. The rules of procedure must be followed while

administering justice. NCLT did not help the home buyers‟ cause by deviating from the procedure and

allowing government‟s application without directing the government to take leave of the Supreme Court first.

„Procedural justice‟ is a means to achieve „substantive justice‟ and the Supreme Court today punished the

government for not adhering to procedure. However, I am hopeful that the government will get another

opportunity soon.

“We want to avoid insolvency of this company, otherwise the 19,000 home buyers will be left high and dry,”

said Additional Solicitor General Sanjay Jain.

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This article aims to:

Highlighting concepts of CSR

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Corporate

Social

Responsibility

CA GAURAV BHATIA & PRAKASH MISHRA

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Corporate Social Responsibility

Meaning Corporate social responsibility (CSR) is a business approach that contributes to sustainable development by delivering economic, social and environmental benefits. CSR is a very broad concept that addresses many and various topics such as human rights, corporate governance, health and safety, environmental effects, working conditions and contribution to economic development.

Definition as per notification dated 27th Feb 2014- “Corporate Social Responsibility (CSR)” means and includes but is not limited to :-

(i) Projects or programs relating to activities specified in Schedule VII to the Act; or ( (ii)Projects or programs relating to activities undertaken by the board of directors of a company (Board) in pursuance of recommendations of the CSR Committee of the Board as per declared CSR Policy of the company subject to the condition that such policy will cover subjects enumerated in Schedule VII of the Act.

Applicability: As per section 135 of Companies Act 2013

Every Company having

(i) Net worth of Rs 500 Crore or more during Financial Year or

(ii) Turnover of Rs 1000 Crore or more during Financial Year or

(iii) Net profit of Rs 5 Crore or more during any Financial Year.

Shall constitute the corporate social Responsibility committee of the Board consisting of three or more Director out of which atleast one Director shall be an independent Director.

Amount to be Expended on CSR Activities:

1) The company shall spend at least 2% of its average net profit as per Section 198 of Companies act,2013 for the immediately preceding three financial years on corporate social responsibility activities.

2) CSR expenditure shall include all expenditure including contribution to corpus for projects or programs relating to CSR activities approved by the Board on the recommendation of its CSR Committee, but does not include any expenditure on an item not in conformity or not in line with activities which fall within the purview of Schedule VII of the Act.

Activities specified in Schedule VII which companies may include in their CSR Policies are as follows:-

(i) – Eradicating hunger, poverty and malnutrition

– Promoting health care including preventive healthcare and sanitation including contribution to the Swach Bharat Kosh set up by the Government for promotion of sanitation

– Making available safe drinking water

(ii) – Promoting education, including special education and employment enhancing vocation skills especially among children, women, elderly and the differently abled

– Livelihood enhancement projects

(iii) – Promoting gender equality

– Empowering women

– Setting up homes and hostels for women and orphans

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– Setting up old age homes, day care centres and such other facilities for senior citizens

– Measures for reducing inequalities faced by socially and economically backward groups

(iv) – Ensuring environmental sustainability

– Ecological balance

– Protection of flora and fauna

– Animal welfare

– Agroforestry

– Conservation of natural resources

– Maintaining quality of soil, air and water including contribution to the Clean Ganga Fund set up by the Central Government for rejuvenation of river Ganga.

(v)– Protection of national heritage, art and culture including restoration of buildings and sites of historical importance and works of art

– Setting up of public libraries

– Promotion and development of traditional arts and handicrafts

(vi) Measures for the benefit of armed forces veterans, war widows and their dependants

(vii) Training to promote

– Rural sports

– Nationally recognized sports

– Paralympic sports

– Olympic sports

(viii) Contribution to

– The Prime Minister‟s National Relief Fund or

– Any other fund set up by the Central Government for socioeconomic development and relief and welfare of SC/ST/OBC, minorities and women

(ix) Contributions or funds provided to technology incubators located within academic institutions which are approved by Central Govt.

(x) Rural development projects.

(xi) Slum area development.

3) First preference shall be given to Local Area & Area around it, where company operates for spending amount earmarked for activities

4) In case of failure to expend the amount on CSR Activities, the Board of Directors shall specify the reason for non-expenditure in the Board‟s Report.

Composition of CSR Committee:

The companies which covered u/s 135 shall constitute CSR Committee as under:

( i) an unlisted public company or a private company covered under sub-section (1) of section 135 which is not required to appoint an independent director pursuant to sub-section (4) of section 149 of the Act, shall have its CSR Committee without such director (ii) a private company having only two directors on its Board shall constitute its CSR Committee with two such directors (iii) with respect to a foreign company covered under these rules, the CSR Committee shall comprise of at least two persons of which one person shall be as specified under clause (d) of

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sub-section (1) of section 380 of the Act and another person shall be nominated by the foreign company.

The CSR Committee shall institute a transparent monitoring mechanism for implementation of the CSR projects or programs or activities undertaken by the company.

Functions of CSR committee: Formulate and recommend to the Board, a Corporate Social Responsibility Policy which shall indicate

the activities to be undertaken by the company as specified in Schedule VII

Recommend the amount of expenditure to be incurred on the activities which may be included by

companies in their CSR policies

Monitor the Corporate Social Responsibility Policy of the company from time to time.

Prepare a transparent monitoring mechanism for ensuring implementation of the projects / programmes / activities proposed to be undertaken by the company.

Consequences of Non-Compliance of Provision: If a company contravenes the provision, shall be punishable with

Fine which shall not be less than 50 Thousand, but which may extend to 25 Lakhs, And

Every officer of the Company who is in Default, shall be punishable with Imprisonment for a Term which may extend to three years or

Fine which shall not be less than 50 Thousand, but which may extend to 5 Lakhs, or Both

Disclosure of CSR: Every company, except foreign company shall disclose the Annual report on CSR, containing specified in

the Annexure, in its Board Report and publish in website as well.

In case of Foreign Company, the Balance Sheet file under Section 381(1) (b) shall contain an annexure

regarding reporting on CSR

CSR audit:

A Corporate Social Responsibility audit aims at identifying environmental, social or governance risks

faced by the organization and evaluating managerial performance in respect of those.

Taxation Liability:

CSR expenditure, being an application of income, is not incurred wholly and exclusively for the purposes

of carrying on business. As the application of income is not allowed as deduction for the purposes of

computing taxable income of a company, amount spent on CSR cannot be allowed as deduction for

computing the taxable income of the company. If such expenses are allowed as tax deduction, this would

result in subsidizing of around one-third of such expenses by the Government by way of tax

expenditure.”

Corporate social initiatives:

Corporate social responsibility includes six types of corporate social initiatives:

1. Corporate philanthropy: company donations to charity, including cash, goods, and services, sometimes via a corporate foundation

2. Community volunteering: company-organized volunteer activities, sometimes while an employee receives pay for pro-bono work on behalf of a non-profit organization

3. Socially-responsible business practices: ethically produced products which appeal to a customer segment

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4. Cause promotions: company-funded advocacy campaigns

5. Cause-related marketing: donations to charity based on product sales

6.Corporate social marketing: company-funded behavior-change campaigns

Potential business Benefits:

Triple bottom line:

"People, planet and profit", also known as the triple bottom line, form one way to evaluate CSR. "People" refers to fair labour practices, the community and region where the business operates. "Planet" refers to sustainable environmental practices. Profit is the economic value created by the organization after deducting the cost of all inputs, including the cost of the capital (unlike accounting definitions of profit).

Risk management:

Managing risk is an important executive responsibility. Reputations that take decades to build up can be ruined in hours through corruption scandals or environmental accidents. These draw unwanted attention from regulators, courts, governments and media. CSR can limit these risks

Brand differentiation:

CSR can help build customer loyalty based on distinctive ethical values. Some companies use their commitment to CSR as their primary positioning tool. Some companies use CSR methodologies as a strategic tactic to gain public support for their presence in global markets.

Reduced scrutiny:

Corporations are keen to avoid interference in their business through taxation and regulations. A CSR program can persuade governments and the public that a company takes health and safety diversity and the environment seriously, reducing the likelihood that company practices will be closely monitored.

ANNEXURE

FORMAT FOR THE ANNUAL REPORT ON CSR

ACTIVITIES TO BE INCLUDED IN THE BOARD’S REPORT

1. A brief outline of the company‟s CSR policy, including overview of projects or programs proposed

to be undertaken and a reference to the web-link to the CSR policy and projects or programs.

2. The Composition of the CSR Committee.

3. Average net profit of the company for last three financial years.

4. Prescribed CSR Expenditure (two per cent of the amount as in item 3 above).

5. Details of CSR spent during the financial year:

(a) Total amount to be spent for the financial year;

(b) Amount unspent, if any;

(c) Manner in which the amount spent during the financial year is detailed below:

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S.

No

CSR

project or

activity

identified

Sector

in which

the

project

is

covered

Projects or

programs

(1) Local

area or

other

(2) Specify

the state

and district

where

projects or

programs

was

undertaken

Amount

outlay

(budget)

projects or

programs-

wise

Amount

spent on the

projects or

programs

Sub-heads:

(1) Direct

expenditure

on projects or

programs

(2)

Overheads

Cumulative

expenditure

up to the

reporting

period

Amount

spent:

Direct or

through

implementing

agency *

1.

2.

3.

Total

*Give details of implementing agency:

6. In case the company has failed to spend the two per cent of the average net profit of the last three

financial years or any part thereof, the company shall provide the reasons for not spending the amount in

its Board report.

7. A responsibility statement of the CSR Committee that the implementation and monitoring of CSR

Policy, is in compliance with CSR objectives and Policy of the company.

Sd /-

Chief Executive Officer or

Managing Director or

Director

Sd /-

Chairman CSR Committee

Sd /-

(Person specified under clause

(d) of sub -section (1) of

section 380 of the Act)

(wherever applicable)

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Evaluation of Digital

Control: Pivotal to

Effective Assurance

This article aims to highlights the importance of Digital Control

`

CA Kunika Thakur & Himanshu Aggarwal

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Evaluation of digital control: Pivotal to Effective

Assurance

Introduction

The emerging digital economy is disrupting the way business get done, more so challenging the several

dimension of conventional transaction cycles and internal controls that are now embedded in IT. It is rare to

find any business vertical that has not been touched by digitalization.

Why should an entity bother about evaluation of digital control?

Information is the key driver for any business enterprise and today, a business entity cannot survive without IT.

With the increasing adoption of information technology, business today relies on software systems and

applications more than ever. Many of these IT systems generate and process data that is used in the preparation

of financial statements of a company.

So, it is essential to understand the inherent risks that come along with the adoption of IT, if not managed can

lead to governance disasters due to a variety of risk factors.

Hancock Health Ransomware Attack – A Case study

Hancock Health, a health system based in Greenfield, Indiana, was hit with a ransomware attack Thursday night

i.e. on January 11, 2018. The hackers were able to access the system through a hospital server which was

using the Remote Desktop Protocol (RDP) service. The hackers got into the server using a compromised

administrative account setup by a vendor of the hospital.

They used a variant of ransomware called SamSam, which encrypts data files on the systems and uses a private

key to unlock them.

According to Hancock Regional Hospital, their leadership team ultimately made the decision to pay the ransom

demanded by the hackers, which was four bitcoin i.e. $55000. After paying the ransom, a private key was then

obtained and the files unlocked.

Risk mitigation consideration

Organizations can help mitigate their risk exposure by considering the following actions:

Ensure that vulnerability management (including vulnerability scanning/remediation) is a robust and

mature enterprise-level program.

Maintain backups for basic critical data and storage at another safe place outside regular business

premises.

Implement endpoint monitoring, giving teams visibility into malicious behavior occurring at that level.

Ensure that the organization has a comprehensive security awareness training program in place at

regular intervals.

Maintain an effective enterprise incident response plan that is regularly tested and measured for

effectiveness against ransomware, as well as regularly updated to reflect the current cyber threat .

Regular physical check of storage data.

Regular interval check / control system in operation.

Record of password of each concerned staff member.

Periodical change in password of data and its proper deletion once concerned staff changes.

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Tested sincere staff may have access to data.

To ensure that critical systems are not connected to/accessible from the internet.

Password protected screen saver be installed at all critical points.

Staff training in initial area may be encouraged to go on long leave at least once in a year so that

replaced staff may detect weak area of former.

Impact of digital risks on Assurance

Digital risks bring in the importance of IT governance that supports corporate governance from the perspective

of top management oversight over how enterprise digital information is managed and governed. Hence

assurance professionals behold as critical conscience keepers to the state of controls, including those over IT,

that in turn impact stakeholder interest.

The assurance by auditors about external financial audit and internal audits, are based on objective assessments

that primarily rely on examination on test basis and supporting evidences. However, such assurance finds their

foundation in the auditor‟s confidence on the state of internal controls that are now embedded in digitalized

environment.

Use of CAAT as an audit technique

In a diverse world of client enterprise, the greatest challenge for an auditor is to access, analyze, and audit this

maze of data. CAAT enables auditors to move from era of ticks of using pencil or pen to the era of clicks by using

a mouse.

CAATs stands for Computer Assisted Audit Techniques, are a collection of computer based tools and techniques

that are used in an audit for analyzing data in electronic form to obtain audit evidence.

Advantages of using CAAT

CAATs facilitate the auditors to test a huge volume of data, or the operation of the controls in a system,

precisely and rapidly and are therefore, very cost efficient when operated appropriately.

CAATs lessen the level of human error in testing and facilitate a very high level of audit evidence to be

derived.

The application of CAATs frees up expensive human capital that would otherwise be engaged in key

areas to concentrate on judgmental areas.

Internal Financial Control (IFC)

As per section 134 of companies act 2013, the term internal financial control means the policy & procedure

adopted by the company for ensuring

orderly and efficient conduct of its business, including adherence to company‟s policies,

safeguarding of its assets,

prevention and detection of frauds and errors,

accuracy and completeness of accounting records, and

Timely preparation of reliable financial information.

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Auditor’s responsibility regards Internal Financial Control

As per section 143 (3) (i) of companies act 2013, the

auditor is required to state in audit report whether the

company has adequate internal financial controls system

in place and the operating effectiveness of such controls.

This is a significantly enlarged scope as against the limited

responsibilities in this regard cast under CARO 2016 that

covered only specific aspects.

The directors and management have primary

responsibility of implementing and maintaining an

effective internal control framework and auditors are

expected to evaluate, validate and report on the design and

operating effectiveness of internal financial control.

The companies Act, 2013 has placed a greater emphasis on the effective implementation and reporting on the

internal controls for a company. The table below gives a summary of the requirements of the Act.

Reference Who is responsible? Applicability

Sec 134(5)(e) Board of Directors Listed companies

Rule 8 (5) of companies

(Accounts) rules

Board of Directors All companies

Sec 149(8) & schedule IV Independent Directors All companies having Independent

directors

Sec 177 Audit committee All companies having audit committee

Sec 143(3) (i) Statutory auditors All companies

Meaning of Financial statements

Financial statements is a formal record of the financial activities and position of a business, person, or other

entity. Financial statement in relation to a company, includes—

1) a balance sheet as at the end of the financial year;

2) a profit and loss account, or in the case of a company carrying on any activity not for profit, an

income and expenditure account for the financial year;

3) cash flow statement for the financial year;

4) a statement of changes in equity, if applicable; and

5) any explanatory note annexed to, or forming part of, any document referred to in sub-clause (i)

to sub-clause (iv):

Provided that the financial statement, with respect to One Person Company, small company and

dormant company, may not include the cash flow statement.

Compliance with

applicables rules &

regulations

Effectiveness & efficiency

of operations

Objective of Internal financial

control (IFC)

Prevention & detection of

frauds

Safeguarding of assets

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Steps to be taken by auditor before justifying its reliance on the system

While evaluating the reliability of the accounting and internal control system, the auditor would consider

whether these system:

1) Ensure that authorized, correct and complete data is made available for processing;

2) Provide for timely detection and correction of errors;

3) Ensure that the case of interruption in the work of the CIS environment due to power, mechanical or

processing failures, the system restarts without distorting the completion of the entries and records;

4) Ensure that accuracy and completeness of output;

5) Provide adequate data security against fire and other calamities, wrong processing, frauds etc.;

6) Prevent unauthorized amendments to the program;

7) Provide for safe custody of source code of application software and data files.

Periodicity of review of working of system

As already mentioned, many of the processes of an enterprise are embedded in IT. The whole system of entity is

depending on effectively working of Information system. So there is also need of review of working of

information system. The information system should be reviewed periodically, at least two times in a year so that

there is no interruption in the working of enterprise.

Internal check system

The system provides existence of checks on the day to day transactions which operate continuously as part of the

routine system whereby the work of each person is either proved independently or is made complimentary to the

work of another.

Objective of Internal check system

To avoid errors and fraud with ease

To avoid and minimize the possibility of commission of errors and fraud by any staff.

To increase the efficiency of the staff working within the organization

To protect the integrity of the business by ensuring that accounts are always subject to proper scrutiny

and check.

To prevent and avoid the misappropriation or embezzlement of cash and falsification of accounts.

Approach to auditing IT controls

In a controls-based audit, the audit approach can be classified into three broad phases comprising of planning,

execution, and completion. In this approach, the considerations of automated environment will be relevant at

every phase as given below:

during risk assessment, the auditor should consider risk arising from the use of IT systems at the

company;

when obtaining an understanding of the business process and performing walkthroughs the use of IT

systems and applications should be considered;

while assessing the entity level controls the aspects related to IT governance need to be understood and

reviewed;

pervasive controls including segregation of duties, general IT controls and applications should be

considered and reviewed;

during testing phase, the results of general IT controls would impact the nature, timing and extent of

testing;

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when testing of reports and information produced by the entity (IPE) generated through IT systems and

applications;

At completion stage, evaluation of control deficiencies may require using data analytics and CAATs.

Conclusion

Audit objective may not be achieved by using conventional audit approaches and techniques. Hence, it is

essential to evaluate significant digital control in performing external, financial and internal audits and its

impact on corporate governance. Ignoring of evaluation of digital control can significantly elevate audit and

governance risks.

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Contact Name E-mail Mobile Mr. Anuj Somani anujsomani@kgsomani.com +91 9871098777 Mr. Bhuvnesh Maheshwari bhuvneshmaheshwari@kgsomani.com +91 9810031993

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Disclaimer

• This material and the information contained herein prepared by the authors is of a general nature and does not exhaustively deal with the subject discussed. • Although the authors have put their earnest effort in providing accurate and appropriate information, the article is not intended to be relied upon as the sole basis for any decision which may affect you or your business. The authors recommend you take professional advice before acting on specific issues. • KGS is neither responsible for any views, opinions and statements made by the authors nor is liable for consequences, if any, arising from actions based on such views or opinion.

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