Issues & Mandatory Issues & Mandatory Requirements of Scrutiny Requirements of Scrutiny

AssessmentAssessment

Presentation by:CA AVINASH RAWANI

� In the last two decades most of thetaxpayers of India had a wonderful time withthe Income-tax Department.�This was because of the scheme ofdepartment to cover most of the assessmentunder summary.� In recent times, the procedure for selectionof the scrutiny cases underwent sea change.

IntroductionIntroduction

of the scrutiny cases underwent sea change.�As a result, many cases are picked up underscrutiny as per norms laid down by CBDT,which are declared each year

26/30/2012

� Intimation u/s 143(1) shall be issuedonly if:-

(i) any tax or interest is due on thebasis of return filed by assessee or

(ii) any refund is due on the basis ofsuch return.

� Thus, prima facie adjustments arenow not permissible.

Section 143(1)Section 143(1)

now not permissible.� Acknowledgement of return will be

treated as deemed intimation.`

36/30/2012

� Amendment of intimation / deemedintimation can be made u/s 154 of the Act.

� Opportunity has to be given to assessee, ifamendment has the effect of reducing therefund or increasing the liability of assessee.

Amendment of IntimationAmendment of Intimation

� Rectification or Revision of Online filedReturns has to be made online unless theReturn has been transferred from CPC.

46/30/2012

�Notice u/s. 143(2)- Production of evidence insupport of return of income.�Notice u/s. 142(1)-Production of accounts ordocuments or furnish specified information.Assessee cannot be called upon to produceaccounts relating to period more than 3 yearsprior to previous year.�Summons u/s 131-Discovery/Inspection,Enforcing attendance, compelling productionof accounts /documents and issuingcommission.� Power to impound books of accounts u/s

Inquiry in Scrutiny Inquiry in Scrutiny AssessmentAssessment

� Power to impound books of accounts u/s131(3)�Notice u/s 133(6)-Collectingaccounts/information�Sec. 142A-Reference for valuation.

56/30/2012

�The purpose of the scrutiny assessment isto verify correctness of the incomedeclared by the assessee.

� Starts with Issue of Notice under Section143(2) of the Act stating the date ofhearing and is generally accompanied

Purpose of ScrutinyPurpose of Scrutiny

hearing and is generally accompaniedwith Notice under Section 142(1) seekingthe details of the requirement ofinformation seeked by the AssessingOfficer;

66/30/2012

�Notice is to be SERVED upon the assesseewithin 6 months from the end of theAssessment Year i.e. Notice for AY 2011-12to be issued latest by 30th September, 2012.

� Issue of Notice after the time limit specifiedis not valid and cannot be enforced;

Issue of Notice Issue of Notice –– Time PeriodTime Period

�Amendments made in the IT Act stating thatcomplying Time Barred Notice issued will alsobe a Valid Notice, duly enforceable andcannot be challenged.

76/30/2012

� Scrutiny is based only for verification of certain information like investments, expenses or claims;

� Department’s Internal Circular regarding scrutiny in these case should be limited to that extent;

Concept of Limited ScrutinyConcept of Limited Scrutiny

that extent;

� Can Assesee object if other additional information is called for?

6/30/2012 8

� Assessee is required to submit therequired information and details as soughtby AO;

� All the details or details in part may besubmitted;

Submission of the Desired Submission of the Desired

InformationInformation

� Attend personally on the date or file aletter seeking adjournment to avoidpenalties

6/30/2012 9

�The assessee is duty bound to complywith all the notices issued in the course ofassessment proceeding.

�Assessee should reply all the queriesraised either by way of letter or ordersheet entries.

� If the assessee or his AR can not remainpresent, adjournment application should

Procedure of AssessmentProcedure of Assessment

present, adjournment application shouldbe filed before date of hearing.

106/30/2012

� Submission of physical copy of the e-FiledReturn;

� Submission of Annual Report, Tax AuditReport in physical format which shouldmatch exactly with the e-Filed ROI;

Submission of the InformationSubmission of the Information

� Supporting documents for claims ofrebates & deductions under variousprovisions

6/30/2012 11

� The Information sought by AO should besubmitted to his satisfaction;

� In case of any doubt for any allowance ofexpenses etc., the necessary case law infavour of the assessee should preferablybe given for better justification of theclaim;

Submission of Details Submission of Details

claim;

� Submit only required information assought to avoid waste of time and be tothe point;

6/30/2012 12

� Gain the source and judge the AO abouthis requirement of the Information;

� Submit as much reliable information toprove your claim;

Can also take the opinion of the Sr.

Submission of Details Submission of Details

� Can also take the opinion of the Sr.Counsel and can be submitted in case ofdoubt;

� Confusing AO can create more problems.

6/30/2012 13

� Assessee should explain fall in gross profitby showing that margin of profit was lowduring relevant year compared to pastyears.� In absence of omission or defects in books

of accounts and records, addition cannotbe made. Case laws:CIT v. Vikarm Plastic (239 ITR 161) (Guj)

Fall In Gross ProfitFall In Gross Profit

CIT v. Vikarm Plastic (239 ITR 161) (Guj)CIT v. Dr. Rajnikant Dave (281 ITR 6) (Del)

146/30/2012

� A.O cannot reject book results merely onthe basis of disparity in consumption ofelectricity vis a vis production without anysupporting evidence.

Case Law:

St. Teresa’s Oil Mills v. State of Kerala (76ITR 365) (Ker)

Estimate of ProductionEstimate of Production

ITR 365) (Ker)

156/30/2012

� Assessee should prove identity, capacity oflenders as well as genuineness of transaction.� Where lender is assessed to tax, assessee can

avoid addition by filing confirmation withparticulars of PAN.� Case Laws:

Addl. CIT Vs. Hanuman Agrawal (151 ITR 150)(Pat)CIT Vs. Orissa Corporation (P) Ltd. (159 ITR 78)

New LoansNew Loans

CIT Vs. Orissa Corporation (P) Ltd. (159 ITR 78)(SC)CIT Vs. Gopal & Co. (204 ITR 285) (Gau.)Jalan Timbers Vs. CIT (223 ITR 11) (Gau.)CIT Vs. Rohini Builders (256 ITR 360) (Guj.)

166/30/2012

� In case of new share capital, assessee isrequired to prove only identity ofshareholders. Case Laws:

CIT Vs. Steller Inv. Ltd (192 ITR 287)(Del)

CIT Vs. Kwick Travels (199 ITR 85) (St.)(Del)

New Share CapitalNew Share Capital

(Del)

CIT Vs. Sophia Fin. Ltd. (205 ITR 98)(Del) (FB)

CIT Vs. Steller Inv. Ltd. (251 ITR 263)(SC)

176/30/2012

� In case of gift, the heavy burden is caston assessee to prove the genuineness ofgifts. The burden to produce donor is onassessee.� If donor is assessed to tax and confirmed

donation of money to assessee bypersonally appearing before AO, theaddition can be avoided.

Receipts by way of GiftReceipts by way of Gift

addition can be avoided.Case Law:-� Murlidhar Lahorimal Vs. CIT(280 ITR

512) (Guj)

186/30/2012

� Assessee is not required to prove sourceof the source of credit.

Case Laws:Hastimal V. CIT (49 ITR 273)(Mad.)Tolaram Daga V. CIT (59 ITR 632)(Assam)Nemichand Kothari v. CIT (264 ITR 254)(Gau)

Source of SourceSource of Source

(Gau)Murlidhar Lahorimal Vs. CIT(280 ITR 512)(Guj)

196/30/2012

� Section 41(1) cannot be applied for current yearwhen liability was incurred.� There must be some benefit in the form of

remission or cessation.� The burden is on revenue that assessee claimed

deduction in past years.(Ref: CIT v. PranlalDoshi-201 ITR 756).� In CIT v. Sugauli Sugar Works P.Ltd (236 ITR 518

(SC) and Ambica Mills Ltd v. CIT(54 ITR 167)(Guj), it was held that the fact that the period of

Remission/Cessation of Remission/Cessation of LiabilityLiability

(Guj), it was held that the fact that the period oflimitation prescribed by the Limitation Act hadexpired, does not mean that the debt wasextinguished merely because remedy by way ofsuit was barred.

206/30/2012

� In CIT v. Voltamp Transformers P. Ltd. v.CIT (129 ITR 105) (Guj), it was held thatpayments are not to be judged from theviewpoint of a revenue officer but fromthe viewpoint of a businessman.

� In CBDT’s circular dated 6/7/68, it hasbeen observed that “The income-taxofficer is expected to exercise his

Payments to AssociatesPayments to Associates

officer is expected to exercise hisjudgement in a reasonable and fairmanner and provision is not be applied ina manner which will cause hardship inbona fide cases.”

216/30/2012

� In CIT v. Dhanrajgiri Raja Narasingiriji (91ITR 544), it was held by Supreme Courtthat ‘It is not open to the department toprescribe what expenditure an assesseeshould incur and in what circumstances heshould incur that expenditure. Every

Claim of ExpenditureClaim of Expenditure

should incur that expenditure. Everybusinessman knows his interest best.’

226/30/2012

� In the case of difference between stock asreported to revenue and bank, no additioncan be made if there is difference in valueand not quantity. (Ashokkumar v. ITO)(201 CTR 178) (J & K).� In case of difference in stock in quantities,

the addition can be avoided on basis offollowing case laws.

Investment in stockInvestment in stock

following case laws.CIT v. General Metal Works (172 ITR 173) (All)

CIT v Sind. Rice & Gen. Mills(281 ITR 428) (PH)CIT v. Padmavati Cotton (236 ITR 340) (Mad)

236/30/2012

Various Parameters:

� The intention at the time of purchase� The length of period of holding� The frequency of transactions� Owned fund v. Borrowed fund� Time devoted� The infrastructure and set up employed� The volume of transaction� Alternative occupation� The ratio of purchase and sales/holding

Business Income v. Capital GainBusiness Income v. Capital Gain

� The ratio of purchase and sales/holding� Circumstances responsible for sale� Post utilisation of proceeds� Treatment in books of account� MOA/AOA� No. of scripts

246/30/2012

� Instruction No. 1827 dated 31/8/89� Draft Circular dated 16/5/2007� Cir. No. 4/2007 dated 16/6/2007� Deepaben A. Shah 99 ITD 218 (Ahd)� Fidelity Northstar Star 288 ITR 641 (AAR)� Revashankar Kothari 283 ITR 338 (Guj)� Smt. Neerja Birla v. Asst CIT 66 ITD 148(Mum)

Circulars and Case LawsCirculars and Case Laws

(Mum)� Janak S. Rangwalla v. Asst CIT (11 SOT 627)� General Ele.Pension Trust (280 ITR 425)(AAR)� Ramanarain Sons Ltd v. CIT(41 ITR 534)(SC)

256/30/2012

� Assessee should place evidence in form ofbills, challan, entry in stock register,payment by crossed cheques etc.� Case Laws:

Dy. CIT v Adinath Ind-252 ITR 476 (GUJ)ITO v Sunsteel-92 TTJ 1126 (AHD)Sri Rama Multitec v ACIT-92 TTJ 568 (AHD)CIT V S. M. Omer– 201 ITR 608 (CAL)CIT V. M.K. Brothers-163 ITR 249(GUJ)

Bogus/NonBogus/Non--genuine Purchasesgenuine Purchases

CIT V S. M. Omer– 201 ITR 608 (CAL)CIT V. M.K. Brothers-163 ITR 249(GUJ)Balaji Tex. Ind.P.L. V ITO–49 ITD 177(BOM)J. R. Sol. Ind. P.L V ACIT–68 ITD 165 (CHD.)Milkfood Ltd. V. DCIT – 65 TTJ 848 (DEL)

CIT V. Kashiram Textile Mills P. Ltd. - 284 ITR61 (GUJ)

266/30/2012

� Our Institute suggested exclusive method butsection 145A talks about inclusive method. Bothmethods are revenue neutral.� So auditor gives reconciliation in the tax audit

report & demonstrates that even whenadjustments are made as per provisions ofsection 145A, there is no impact on the figure ofnet profit / loss.� However, AO makes adjustment only to the

figure of closing stock so as to make addition.

Inclusion of taxes/dutiesInclusion of taxes/duties--SecSec--145A145A

figure of closing stock so as to make addition.Case Laws:CIT v. Indo Nippon Chemicals Ltd (261 ITR 275)(SC)Dy. CIT v. Gandhar Oil Ltd. (104 TTJ 630)(Mum)

276/30/2012

� The stock cannot be valued at market price, if it is higher than cost price. Case Law:Sanjeev Woolen Mills v. CIT (279 ITR 434) (SC)� If the value of closing stock is disturbed in

any year, the corresponding adjustment invalue of opening stock of next year should

Whether stock can be valued at Market Whether stock can be valued at Market Price?Price?

value of opening stock of next year shouldbe given. Case Law:CIT v. Chandrika Towers (275 ITR 173) (MP)

286/30/2012

� Collection of amount on account of contribution for ESIC, PF from Staff.

� Payment made after due date specified in the respective funds?

Case Law of Radhakrishna Foodland v/s

Contributions to FundsContributions to Funds

� Case Law of Radhakrishna Foodland v/s ACIT (ITA No. 4211/Mum/2006)

6/30/2012 29

� Disallowance for Amounts paid, but tax not deducted?

� Disallowance for Amount of TDS deducted, but not paid?

Recent Budgetary Amendments, whether

Section 40(a)(Section 40(a)(iaia) )

� Recent Budgetary Amendments, whether retrospective?

6/30/2012 30

�1/5th of the total expenses allowable each year for 5 years?

�Restricted to 2.5% and 5% of

Preliminary Expenses u/s 35DPreliminary Expenses u/s 35D

�Restricted to 2.5% and 5% of capital investments and cost of project?

6/30/2012 31

� Deemed Dividend for payments made to beneficial holders;

� Income Tax law and provisions.

� Amount should have been paid during the year;

Section 2(22)(e)Section 2(22)(e)

year;

� Case Laws in favour and against available.

6/30/2012 32

Addition on basis of Stamp Addition on basis of Stamp DutyDuty

� Addition cannot be made on basis ofincreased stamp duty payable byassessee on higher valuation made byrevenue authorities.Case Laws:Case Laws:

Dinesh Mittal v. ITO (193 ITR 770) (All)CGT v. R. Damodaran (247 ITR 698)

(Mad)

336/30/2012

� I.T authorities can accept the audit reportwhere books of accounts are destroyed &they can also draw inference from thesame regarding supporting materials fordeductions claimed.

Case Law:-

Destruction of books of Destruction of books of accountsaccounts

CIT. V. Jay Engg. Works Ltd. – 113 ITR 389(Del)

346/30/2012

� Renting of Immovable Property with a motive to earn rent;

� Renting of Immovable Property as a Business Centre;

Deductions and Claims for Expenses in

Rental Income or Business IncomeRental Income or Business Income

� Deductions and Claims for Expenses in both the cases;

6/30/2012 35

� Justification to be given for system of accounting adopted;

� Information about the same in IT Return and in the Tax Audit Reports;

Proving the said system through

Method of AccountingMethod of Accounting

� Proving the said system through Accounting methods;

6/30/2012 36

� AIR Information are 1st sort of Querry raised by the AO;

� Always give reconciliation of Income and Taxes Claimed at the time of Assessment;

One major source of scrutiny is

Reconciliation of Income with Reconciliation of Income with Form 26ASForm 26AS

� One major source of scrutiny is Information;

6/30/2012 37

� Payments where TDS has been deducted by other parties;

� Purchase/Sale of Property exceeding Rs. 30 Lacs or more;

� Credit Card Expenses exceeding Rs. 2 lakhs per annum;

� Investments in New Issue of Shares/ MF

Information available in AIRInformation available in AIR

� Investments in New Issue of Shares/ MF exceeding Rs. 1 lakhs;

� Fixed Deposit in any bank in excess of Rs. 2 Lakhs;

6/30/2012 38

� Investments in Bond in excess of Rs. 5 Lakhs;

� Cash Deposits in Savings Account in excess of certain limit;

Cash withdrawal exceeding certain limits

Information available in AIRInformation available in AIR

� Cash withdrawal exceeding certain limits from bank accounts

6/30/2012 39

� Applicable when there is both taxable and exempt income?

� Tax Audit requires to give the workings of the same;

Notification No. 45/2008

Disallowance under Sec 14ADisallowance under Sec 14A

� Notification No. 45/2008

� Case laws

6/30/2012 40

� Additional Depreciation is available onPlant and Machinery used formanufacturing

� Available only in the Initial Ass Yr.

Claim to be made in the Return;

Depreciation ClaimDepreciation Claim

� Claim to be made in the Return;

� Can the claim be made subsequently?

6/30/2012 41

� It has been held by Supreme Court inGoetze (India) Ltd. Vs. CIT (284 ITR 323)that new claim for deduction cannot beentertained by assessing authorityother than by way of filing revised returnof income.

New Claim During AssessmentNew Claim During Assessment

� However, the above decision does notimpinge on the power of ITAT to admitnew claim.

426/30/2012

�Assessing officer may make the additionin respect of actual income understatedby assessee by suppressing receipt and/orinflating expenses. The assessing officercan also make addition under deemingprovisions of the Act like Sec. 68, 69,69A, 69B, 69C even though there is no

Incorrect or Incomplete Incorrect or Incomplete InformationInformation

69A, 69B, 69C even though there is noevidence of earning of actual income byassessee.

436/30/2012

� Section 142A was retrospectively inserted toempower AO to refer VO to make estimate ofany movable or immovable assets for thepurpose of making addition under deemingprovision of section 69, 69A and 69B.

� When the expenditure of construction issupported by bills/vouchers and no defect or

Reference to ValuationReference to Valuation

supported by bills/vouchers and no defect oromission is found out, the addition onaccount of understatement of constructioncost cannot be made.

446/30/2012

� A.O may with the previous approval of ChiefCommissioner or Commissioner, direct theassessee to get the accounts audited byaccountant.� Opportunity must be provided to assessee before

directing him to get the accounts audited.� Max. time limit for special audit – 180 days.� Expenses pertaining to special audit shall be paid

by Central Government where directions areissued on or after 01/06/2007.

Special Audit Special Audit –– Sec. 142(2A)Sec. 142(2A)

issued on or after 01/06/2007.� A.O cannot direct the special auditor to prepare

books of accounts. Ref: Bajrang Textiles V. CIT -3 SOT 115 (Jodh.)� Special audit report is not binding on Assessing

officer.

456/30/2012

Best judgment assessment can be made in the following cases, if:-

- No return of income is filed, or- Assessee fails to comply with all the

terms of notice issued u/s 142(1) or 142(2A) or section 143(2)

But� A.O should give opportunity before

passing order u/s 144.

Best Judgment Asst. Best Judgment Asst. –– Sect. Sect. 144144

� A.O should give opportunity before passing order u/s 144.

� Opportunity not necessary where notice u/s 142(1) is issued.

466/30/2012

� JCIT is empowered to issue directions toA.O to complete the assessment.Directions can be issued, either on his –(i) own motion or(ii) on a reference being made by A.O or

(iii) on application of assessee.

Issue of directions Issue of directions -- Sec. 144ASec. 144A

� Directions which are prejudicial toassessee shall not be issued withoutgiving opportunity of hearing to assessee.

476/30/2012

� Notice u/s 148 cannot be issued afterexpiry of 4 years from the end of relevantA.Y, if:-

(i) Assessment is completed u/s143(3)/147 &

(ii) Income chargeable to tax hasescaped assessment not on account of

ReassessmentReassessment––Sec. 147Sec. 147

escaped assessment not on account offailure on part of assessee to disclosefully & truly all material facts.

� Notice cannot be issued on the basis ofmere change of opinion.

486/30/2012

� Assessee should ask for reasons recordedu/s 148 after filing return of income inresponse to notice.

� After receipt of reasons, if assessee wantsto object validity of assessment, heshould file objections before AO on basisof reasons recorded.

Reasons u/s 148(2)Reasons u/s 148(2)

of reasons recorded.

� AO is duty bound to pass speaking orderon objections raised by assessee. (Ref:GKN Driveshafts (Ind) Ltd. v. ITO (259ITR 19) (SC)

496/30/2012

� No general information can be gatheredby AO during reassessment. Only specificinquiry can be made qua items ofreassessment and roving inquiry is notpermitted. So assessing officer cannotmake additions in respect of items notcovered by reasons recorded u/s 148.(Vipan Khanna v. CIT (255 ITR 220)

Scope of ReassessmentScope of Reassessment

(Vipan Khanna v. CIT (255 ITR 220)(P&H)

506/30/2012

The Supreme Court in the case ofDhirajlal Girdherilal v. CIT (26 ITR 736),Dhkershwari Cotton Mills Ltd. V. CIT (26ITR 755), Omar Salay Mohammed v. CIT(37 ITR 151), Lalchand Bhagatlal AmbicaRam v. CIT (37 ITR 288) and CIT v.Daulatram Rawatmal v. CIT (26 ITR 736)held that the assessment is liable to be

Sanctity of InquirySanctity of Inquiry

held that the assessment is liable to becancelled if it is based on conjectures,surmises and presumptions and not onhard rock of facts and relevant material.

516/30/2012

In C. Vasantlal & Co. v. CIT (45 ITR 206) (SC),

the Supreme Court held that it was open to anincome-tax officer to collect materials to facilitateassessment even by private enquiry. But if hedesires to use materials so collected, theassessee must be informed of the materials(Dhakeshwari Cotton Mills Ltd. v. CIT (26 ITR775)(SC). The Supreme Court in case of

Sanctity of InquirySanctity of Inquiry

775)(SC). The Supreme Court in case ofKishinchand Chellaram v. CIT(125 ITR 713) heldthat materials collected cannot be kept backfrom assessee by revenue authorities

526/30/2012

� The details of comparable case should begiven by assessing officer and if it is notgiven, assessee should ask for the same.

� Assessee should demand crossexamination of witnesses who furnishedadverse information /statement toassessing officer.

Sanctity of InquirySanctity of Inquiry

assessing officer.

� If cross examination is not demanded, theassessee cannot plead at later stage thatas cross examination is not allowed, theaddition is wrong.

536/30/2012

�Penalties under Section 271(1)(c) is generally part of any Assessment Order;

�Levy of Penalty, if no mention of the same is in AO?

�Wrong submission of facts or Incorrect

Penalties under assessmentPenalties under assessment

�Wrong submission of facts or Incorrect Interpretation of the Law, facts of the case to decide the levy?

546/30/2012

�In case of the addition, assessing officermay initiate penalty proceeding u/s.271(1)(c) for concealment of income.

�If the notices are not complied, assessingofficer may initiate penalty proceedingsu/s. 271(1)(b).

�Where there is failure to state truth,

Penalties under assessmentPenalties under assessment

�Where there is failure to state truth,refusal to sign any statement and non-compliance of the summons u/s 131, theassessing officer may initiate penaltyproceeding u/s 272(A)(1).

556/30/2012

� It has been held that the issue which isnot touched upon on revision cannot bebasis for making addition in assessmenttaken in pursuance of order u/s 263-Ref:CIT v. D. N. Doshani & Co. (280 ITR 275)(Guj)

Assessment after revisionAssessment after revision

(Guj)

566/30/2012

� Protective assessment has beenrecognised by judicial decisions althoughthere is no specific provision in the Act.� If substantive assessment is not made,

protective assessment becomessubstantive assessment.� There cannot be recovery in case of

protective assessment.

Protective AssessmentProtective Assessment

protective assessment.� Although protective assessment is

permissible, protective penalty order isnot permissible.

576/30/2012

� Commissioner (Appeals) as an appellate authority has power to stay demand which is in dispute in appeal before him.◦ Prem Prakash Tripathi vs. CIT (1994) 208 ITR 461M 463-64 (All)

◦ Paulsons Litho Works vs. ITO (1994) 208 ITR 676, 689 (Mad)

Power to Stay for recovery of Power to Stay for recovery of DemandDemand

676, 689 (Mad)

◦ Tin Mfg. Co. of India vs. CIT (1995) 212 ITR 451, 452 (All)

◦ Bongaigaon Refinery & Petro Chemicals Ltd. vs. CIT (1999) 239 ITR 871 (Gau.)

6/30/2012 58

� Notice is received well in advance;

� Collect suitable evidences and file the claims along with the submissions;

� Submit all information at a time. Ensure that the correct and true information is

Preparation of ScrutinyPreparation of Scrutiny

that the correct and true information is submitted;

� Always ensure to keep the copies of the documents submitted & acknowledged

6/30/2012 59

� Take ample precaution at the time of filing of the Return;

� Ensure all credits in Form 26AS are duly reconciled before filing the Return;

Mentor to the Tax Payer by convincing to

Preparation of ScrutinyPreparation of Scrutiny

� Mentor to the Tax Payer by convincing to provide true and correct information;

� A journey well began is half done;

6/30/2012 60

Doubts & Doubts & QuerriesQuerries

� Any Questions

� Thank You

23/06/2012 61

� Thank You

C.A. Avinash V. Rawani

61

Compiled by CA Avinash Rawane

• The views stated in the material and also discussed are purely of the compiler for the discussions at the seminar and should not be used for any legal interpretation. Any decision to be taken by the user of this information is to be taken after studying the requisite provisions of the respective Act and specific

23/06/2012 Compiled By : CA Avinash Rawane 62

information is to be taken after studying the requisite provisions of the respective Act and specific applications to particular client. Neither the compiler nor the Institute shall be responsible for the same.