TAX BULLETIN

September - 2020

DIRECT TAX UPDATES

Judicial Updates

Summary:

In the given case, the assessee was a shareholder of a company 'JFAL'. Vide amalgamation scheme, 'JFAL' got

amalgamated with another company 'JSL'. Consequently, the assessee transferred its shareholding in 'JFAL' in lieu of

receipt of shares of 'JSL'. The assessee claimed that said transaction was exempt from capital gain tax under section

47(vii). AO, however, calculated profit on receipt of shares of 'JSL' under scheme of amalgamation and taxed same as

business income. The matter was argued before the Tribunal wherein the Tribunal without recording a finding as to

whether shares qualified as 'capital asset' or 'stock in trade', allowed assessee's appeal holding that no profit accrued

when shares of amalgamated company were received in lieu of shares of amalgamating company.

The department went in appeal before the High Court, wherein the court held that when assessee gets shares of

amalgamated company in lieu of shares of amalgamating company, a transfer does take place within meaning of

section 2(47) and hence, impugned order passed by Tribunal was to be set aside. Further, the court remanded the

matter back to tribunal to go into the factual aspects as to whether shares were kept by assessee as 'capital asset' or

'stock in trade' to determine the amount of taxable income and to levy the income tax thereon.

Read Full Judgement: CIT v. Nalwa Investment Ltd.

1. Receipt of shares of amalgamated company in lieu of shares of amalgamating company is a 'transfer' within the meaning of section 2(47):

Case of: CIT v. Nalwa Investment Ltd. [High Court, Delhi ] In favour of: Revenue

Direct Tax

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2. Expenses for awareness on agriculture, medical camps etc., incurred by Assessee Trust formed for running educational institution, could be regarded as part of educational activity:

Case of: Kamaraj Educational Trust v. CCIT [High Court, Madras] In favour of: Assessee

Summary:

In this case, the assessee-trust was established with an object of running an educational institution. During the year

2013-14, the assessee incurred certain expenses for awareness on agriculture, scientific research, blood donation

camp etc. and claimed exemption u/s 10(23C)(vi). The Chief Commissioner rejected assessee's claim by taking a view

that assessee trust was only for education and not for other activities. This view was also confirmed by the tribunal.

Subsequently, the matter was placed before the High Court that observed that awareness on agriculture, medical

camps and eye camp activity could very well be treated as part of activities carried out in school itself and thus,

expenses incurred on such activities shall be regarded as expenses incurred for the purposes for which the trust was

formed. Hence, the order of Chief Commissioner was set aside.

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Direct Tax

Judicial Updates

Summary:

In this case, the assessee sold a plot of land and received consideration in several instalments in different assessment

years. During the relevant financial year, a sum of certain amount was received out of total consideration. The

assessee offered to tax, the amount of consideration which was received during previous year. Later on, Assessing

Officer issued a reopening notice against assessee raising objection with manner in which capital gains from sale

agreement with respect to said plot was offered to tax by assessee on receipt basis. In response to same, assessee

filed return withdrawing amount of capital gains and offering to tax capital gains on entire sale consideration.

Assessing Officer completed reassessment and taxed capital gains arising on entire sale consideration for relevant

assessment year. He also levied penalty under section 271(1)(c) on assessee for furnishing inaccurate particulars of

income as a result of default committed by assessee in not offering capital gains arising out of entire sale

consideration in relevant assessment year.

Assessee contended that there was a complete disclosure by assessee and, therefore, it was not a case of assessee

furnishing inaccurate particulars of income or of concealing particulars of income. The court noted that it was quite

evident that assessee had declared full facts and sale agreement at first instance. Full factual matrix or facts were

before Assessing Officer while passing assessment order. Thus, assessee had never suppressed any material fact from

revenue. It was another matter that claim based on such facts was found to be inadmissible. This was not same thing

as furnishing inaccurate particulars of income as contemplated under section 271(1)(c).

Read Full Judgement: Omprakash T. Mehta Kapila v. ITO

3. No penalty could be levied where the assessee had declared full facts and sale agreement at first instance but failed to declare the entire sale consideration:

Case of: Omprakash T. Mehta Kapila v. ITO [High Court, Bombay] In favour of: Assessee

4. Impugned ad hoc disallowance made by AO under section 14A without establishing any nexus between expenditure incurred and earning of exempt dividend income was to be deleted:

Case of: Triveni Engineering & Industries Ltd. v. Addl. CIT [ITAT, Delhi] In favour of: Assessee

Summary:

During the year 2000-01, the assessee earned exempt dividend income by making investment in shares out of surplus

funds. The AO while relying on Rule 8D read with section 14A made ad hoc disallowance without establishing any

nexus between expenditure incurred and earning of exempt dividend.

The matter was argued before the Tribunal wherein the tribunal held that such an ad-hoc disallowance u/s 14A made

by the AO without establishing any nexus between expenditure incurred and earning of exempt dividend income was

to be deleted.

Read Full Judgement: Triveni Engineering & Industries Ltd. v. Addl. CIT

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Direct Tax

Judicial Updates

5. Once reassessment proceedings are held to be validly initiated, Assessing Officer is free to assess any other income which comes to his notice in course of proceedings under section 147:

Case of: Devi Construction Company v. DCIT [ITAT, Pune] In favour of: Revenue

Summary:

The case was reopened u/s 147 as the AO had reasons to believe that the assessee has shown some bogus

purchases. However, while assessing the matter, the AO observed that the assessee had also claimed Telephone and

Vehicle expenses at Rs. 6,44,245/-. The assessee could not prove that such expenses were incurred wholly and

exclusively for the purpose of business. Considering the fact that some personal use was involved, the AO made

disallowance at 20% of expenses under both the heads. The ld. CIT(A) reduced the rate of disallowance from 20% to

10%.

Before the tribunal, the assessee objected to the disallowance of such expenses and contended that no fresh

material relating to the above addition came to the notice of the AO in the proceedings u/s 147 and hence he could

not have made this addition on the basis of roving enquiries in the reassessment proceedings.

The Hon’ble tribunal while holding the assessment as valid observed that the expression `coming to the notice of the

AO' in section 147 does not mean that the AO, on finding some fresh escaped income during the course of

reassessment proceedings, should quietly make the addition without confronting it to the assessee. The correct

sequence of events for taxing the income of the nature of the second component is that when some ex facie income

chargeable to tax, which earlier escaped assessment, comes to the notice of the AO during the course of proceedings

u/s 147, he should confront the assessee with his point of view and seek comments before making the addition, if

warranted, after making further enquiry. There is a palpable difference in two situations, viz., one, where some ex

facie escaped income comes to the notice of the AO and he makes enquiry before making the addition and two,

where enquiry is made before some ex facie escaped income comes to the notice of the AO.

Read Full Judgement: Devi Construction Company v. DCIT

Circulars/ Notifications

CBDT has amended Rule 37BC to provide that the provisions of section 206AA shall not apply in respect of payments

made to a person being a non-resident, not being a company, or a foreign company where the provisions of section

139A do not apply to such person on account of rule 114AAB.

It shall be noted that section 206AA contains the provisions for requirement to furnish the Permanent Account

Number by the deductee for deduction of TDS. Further, Rule 114AAB specifies the class or classes of person to whom

provisions of section 139A shall not apply i.e. the persons that are not required to obtain Permanent Account

Number.

Read Notification: 58/2020

1. CBDT amends Rule 37BC of Income Tax Rules, 1962:

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Direct Tax

CBDT has amended the E-assessment Scheme 2019 notified vide Notification No. 61/2019 dated 12.09.2019 to

include reassessment under section 147 under its purview. Besides, the name of the Scheme has been changed from

‘E-assessment Scheme, 2019’ to ‘Faceless Assessment Scheme, 2019’. Further, a new procedure for assessment

under the Faceless Assessment Scheme is prescribed. Also, the rules related to ‘Authentication of electronic record’

has been amended. With this scheme, all the cases of scrutiny assessment and reassessment have come under the

purview of Faceless Assessment Scheme, 2019.

Read Notification: 60/2020

2. CBDT amends Faceless Assessment Scheme 2019 to include inter-alia reassessment u/s 147:

Union Budget 2020 has introduced a new section 10(23FE) in order to promote investment of sovereign wealth

funds, including the wholly-owned subsidiary of Abu Dhabi Investment Authority (ADIA). This section grants tax

exemption to interest, dividend and capital gains income of Sovereign Wealth Fund and a wholly -owned

subsidiary of the ADIA subject to fulfilment of certain conditions, in respect of investment made in the

infrastructure sector or other deserving notified sectors before 31st March, 2024 and with a minimum lock -in

period of 3 years.

CBDT has now vide Notification No. 67/2020 dated 17.08.2020 has prescribed additional conditions to be

satisfied by the pension fund for availing the exemption from income in the nature of dividend, interest or long -

term capital gains arising from an investment made by it in India, whether in the form of debt or share capital

or unit under section 10(23FE). One of the important condition is filing of a certificate in Form No. 10BBC from a

Chartered Accountant.

Rule 2DB and Rule 2DC have been inserted in the Income Tax Rules, 1962 for the purpose. The pension fund is

also required to file its return of income in India within the due date specified in section 139(1).

Read Notification: 67/2020

3. CBDT notifies additional conditions for Pension Funds for Exemption under section 10(23FE):

In furtherance to the declared policy objective of the Government to encourage digital transactions and move

towards a less- cash economy, the Finance (No. 2) Act 2019 inserted a new provision namely section

269SU in the Income-tax Act, 1961, which provides that every person having a business turnover of more than

Rs. 50 crores during the immediately preceding previous year shall mandatorily provide facilities for accepting

payments through prescribed electronic modes. Further, a new provision namely section 10A was also inserted

in the Payment and Settlement Systems Act 2007 (“the PSS Act”), which provides that no Bank or system

provider shall impose any charge on a payer making payment, or a beneficiary receiving payment, through

electronic modes prescribed under section 269SU of their IT Act. Subsequently vide notification no. 105/2019

dated 30 12.2019 (i) Debit Card powered by RuPay: (ii) Unified Payments Interface (UPI) (BHIM -UPI); and (iii)

Unified Payments Interface Quick Response Code (UPI QR Code) (BHIM-UPI QR Code) were notified as prescribed

electronic modes under section 269SU of the IT Act.

A circular no. 32/2019 dated 30.12.2019 was issued by the Board to clarify that based on section 10A of the PSS

Act, any charge including the MDR (Merchant Discount Rate) shall not be applicable on or after 01st January,

2020 on payment made through prescribed electronic modes.

Now, the CBDT, based on representation received that some banks are imposing and collecting charges on

transactions carried out through prescribed electronic modes, clarified that no Bank /service provider can

impose any charges on transactions made through Debit Card, BHIM UPI & BHIM UPI QR CODE on or after 1 st

January 2020 and any such charges if recovered are advised to be immediately refunded.

Read Circular: 16/2020

4. CBDT clarifies on imposition of charges on prescribed electronic modes u/s 269SU:

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Direct Tax

Circulars/ Notifications

GST UPDATES

Judicial Updates

Summary:

• The taxpayer has entered into a contract to provide mud engineering, drilling waste management and other

related services (‘oilfield services’).

• The AAR laid down two pre-conditions to ascertain whether the supply is a composite supply or not-

Firstly, the supplies should be naturally bundled and

Secondly, they should be supplied in conjunction with each other.

• The AAR examined the following issues:

The meaning of the word ‘naturally bundled’ and concluded that the supply as per the contract is naturally

bundled in the ordinary course of business, wherein the principal supply is supply of service (mud

engineering or drilling waste management services);

The meaning of the word ‘conjunction’ and stated that the word ‘conjunction’ would imply “occurrence or

happening of the two things or events namely supply of services and supply of goods together or

simultaneously”;

The AAR stated that though the supplies as mentioned in the contract are naturally bundled, they cannot be

said to be supplied in conjunction with each other as the supply of goods and technical personnel are two

independent services;

• Accordingly, the AAR held that services do not satisfy the test of ‘composite supply’. Therefore, supply of goods

and services will be treated as separate supplies attracting tax rates as applicable these supplies separately;

Read Full Ruling: M/s. Haliburton Offshore Services Inc.

1. Supply of mud engineering service along with supply of imported mud chemicals and additives do not qualify as a composite supply:

Case of: M/s. Haliburton Offshore Services Inc. Decision by: AAR, Andhra Pradesh

Goods & Services Tax

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Summary:

• M/s. Daicel Chiral Technologies (India) Private Limited (‘Taxpayer’) is engaged in supply of pharmaceutical

research & development services;

2. Input Tax Credit (“ITC”) on lease premium charges, annual lease rentals & maintenance charges paid to lessor shall not be allowed:

Case of: M/s. Daicel Chiral Technologies (India) Private Limited Decision by: AAR, Telangana

Judicial Updates

• In order to expand its business, the taxpayer has acquired a land on lease with the arrangement to pay lease

charges in the form of one-time premium, annual lease rentals and maintenance charges;

• The AAR stated that through the conditions as stipulated under section 16 of Act is satisfied, there is a specific

restriction under section 17 of the Act with regard to availability of ITC;

• The AAR stated that as per section 17 of the Act, ITC on account of construction of an immovable property is

restricted;

• As the purpose of acquiring the land is for construction of a building, the said activity is squarely covered under

the restriction of section 17 of Act;

• Accordingly, it was held that ITC on one-time lease charges, annual lease rentals and maintenance charges is not

available to the taxpayer.

Read Full Ruling: M/s. Daicel Chiral Technologies (India) Private Limited

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Goods & Services Tax

3. Services provided to vehicle owners under warranty is a supply to the manufacturer and not to the individual buyer:

Case of: M/s. Volvo-Eicher Commercial Vehicles Ltd. Decision by: AAR, Karnataka

Summary:

• M/s. Volvo-Eicher Commercial Vehicles Ltd (‘taxpayer’) is a joint venture company between Volvo Group and

Eicher Motors Ltd. The taxpayer is an exclusive distributor for marketing, sales and distribution of Volvo trucks

manufactured by M/s. Volvo India Private Ltd, a wholly owned subsidiary of Volvo Sweden;

• The taxpayer sells the vehicles with a standard warranty of 1 to 2 years and the cost of which is already included

in sale price charged from the customer (warranty recipient). The taxpayer is responsible for the service of such

warranty claims of its customers and expenses incurred for discharging the warranty obligation is reimbursed by

the M/s. Volvo Sweden as per the agreement;

• The taxpayer had sought advance ruling on whether the costs reimbursed by M/s. Volvo Sweden for supplies

made by the taxpayer to Indian customers under warranty, would qualify as export of services to M/s. Volvo

Sweden. It was held that the supply is a composite supply of goods and services to the customers wherein the

principal supply is that of goods or services depending on individual case to case basis and therefore, the said

transaction is an intra-state or inter-state transaction as per place of supply and does not qualify as the export of

service;

Judicial Updates

• Aggrieved by the above order of AAR, taxpayer filed an appeal before AAAR which held as under:

That the recipients of the service in the given scenario would be M/s. Volvo Sweden, as it is at their

behest that the taxpayer has undertaken the activity of repair and/or replacement of parts to the

customer during the warranty period. The reimbursement received from Volvo Sweden is consideration

paid by the manufacturer to the taxpayer for carrying-out the service during the warranty period, which

was part of the obligations of Volvo Sweden;

That the activities performed by the taxpayer for repair and servicing of Volvo vehicles for Indian

customers under the warranty period amounts to composite supply of goods and services for M/s.

Volvo Sweden with the principal supply being a supply of service.

The AAAR did not comment on second question that whether the reimbursements by M/s. Volvo

Sweden to the taxpayer would qualify as ‘export of services’ as the question here involved is

determining the place of supply, which is outside the ambit of advance ruling provisions under the GST

law.

Read Full Ruling: M/s. Volvo-Eicher Commercial Vehicles Ltd.

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Goods & Services Tax

• With effect from 21 August 2020, an applicant for GST registration, other than persons notified under section 25

(6D) of CGST Act, 2017, opts for authentication of Aadhaar number, shall, while submitting the application

required to undergo authentication of Aadhaar number and the date of submission of the application in such

cases shall be the date of authentication of the Aadhaar number, or fifteen days from the submission of the

application in Part B of FORM GST REG-01, whichever is earlier;

• A person who fails to undergo authentication of Aadhaar number or does not opt for authentication of Aadhaar

number, the registration shall be granted only after physical verification of the place of business in the presence

of the said person, in the manner provided under rule 25 of CGCT rules, 2017. The proper officer may with the

approval of an officer not below the rank of Joint Commissioner, in lieu of the physical verification of the place of

business, carry-out the verification of such documents as he may deem fit;

• Where a person, other than a person notified under section 25(6D) of CGST Act, 2017, fails to undergo

authentication of Aadhaar number or does not opt for authentication of Aadhaar number, the notice in FORM

GST REG-03 may be issued not later than twenty-one days from the date of submission of the application;

• If the proper officer fails to take any action:

within a period of three working days from the date of submission of the application in cases where a person

successfully undergoes authentication of Aadhaar number or is notified under section 25(6D); or

within twenty-one days from the date of submission of the application, in cases where a person, other than

a person notified under section 25(6D), fails to undergo authentication of Aadhaar number; or

within a period of twenty-one days from the date of submission of the application in cases where a person

does not opt for authentication of Aadhaar number; or

within a period of seven working days from the date of the receipt of the clarification, information or

documents furnished by the applicant under sub-rule (2),

the application for grant of registration shall be deemed to have been approved.

• Rule 25 of CGST rules, 2017 substituted to include non-opting for Aadhaar authentication as a reason for physical

verification of business premises.

Read Notification: 62/2020

1. Aadhar authentication for GST registration:

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Goods & Services Tax

Circulars/ Notifications

• Central Board of Indirect taxes and Customs (CBIC) has notified 01 September 2020 as the appointed date for

implementation of provisions related to levy of Interest on net tax liability (‘Tax liability discharged in cash’) for a

tax period after adjusting eligible ITC, for delayed payment of GST.

• It is also clarified through press release by CBIC that no recoveries will be made for the past period as well by the

Central and State tax administrations in accordance with the decision taken at the 39th meeting of the GST

Council and notification is issued with prospective date due to technical limitations.

Read Notification: 63/2020

2. Levy of interest on net liability

3. Extension for filing GSTR-4:

The central Government has further extended the dur date of filing of GSTR-4 for the year 31sr March 2020 till 31st

October 2020 which needs to be filed by composition dealer.

Read Notification: 64/2020

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Goods & Services Tax

Circulars/ Notifications

• GSTR-2B is an auto-drafted ITC statement generated for every recipient, on the basis of the information

furnished by their suppliers, in their respective Form GSTR-1 & 5 and Form GSTR-6 filed by ISD;

• It is a static statement and will be made available for each month, on the 12th day of the succeeding month. It is

expected that GSTR-2B will help in reduction in time taken for preparing return, minimizing errors, assist

reconciliation & simplify compliance relating to filing of returns.

Key features in GSTR-2B

• It contains information on import of goods from the ICEGATE system including inward supplies of goods received

from Special Economic Zones (SEZ) Units / Developers. This is not available with the release of GSTR-2B for the

month of July and will be made available shortly;

• A summary statement which shows all the ITC available and not available under each section. The advisory given

against each section clarifies the action to be taken by the taxpayers in their respective section of GSTR-3B;

• Document level details of all invoices, credit notes, debit notes etc. is also provided both for viewing and

download.

Import data in GSTR-2A

• Two new tables have been inserted in GSTR-2A for displaying details of import of goods from overseas and

inward supplies made from SEZ units / SEZ developers. Taxpayers can now view their bill of entries data which is

received by the GST System (GSTN) from ICEGATE System (Customs);

• Currently, the system is displaying data up to 6 August 2020. Further, taxpayers may note that system currently

does not contain import information for bill of entries filed at non-computerized ports (non-EDI ports) and

imports made through courier services/post office. This will be made available shortly;

Read: PIB Press Release

1. Launch of GSTR-2B for the month of July 2020:

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Goods & Services Tax

Press Releases

1. Rectification in GSTR 1/ GSTR 3B

Rectification of error or omission in respect of the details furnished in GSTR 3B shall be made in not later than an above

-specified date – as per Section 39(9) of CGST Act 2017. However, any rectification of error or omission in respect of

the details furnished in GSTR 1 shall be made before filing GSTR 3B of the September 2020 - as per Section 37(3) of the

CGST Act 2017.

2. Issuance of credit note

Credit note in relation to supply made in FY 2019-20 shall be issued by end of September and declared the latest by

the above-mentioned date.

3. Availment of Input Tax Credit (ITC)

ITC could be availed in respect of invoices issued in FY 2019-20 or debit note (DN) relating to invoices issued in FY 2019-

20 within the date specified above – Section 16(4) of CGST Act 2017.

4. Annual re-computation of Rule 42 Reversal

The ITC in respect of inputs and input services being partially used for

The purpose of business and partially for other purposes

Affecting taxable supplies including zero-rated supplies and partly for effecting exempt supplies, then

proportionate ITC of other than business and taxable supplies including zero-rated supplies shall be reversed

according to Rule 42.

Such reversal shall be recomputed finally for the FY before the above-mentioned date and in case: -

The final amount exceeds the aggregate of the amounts determined earlier shall be reversed in GSTR 3B

or through DRC 03 along with interest starting from 1st of April of next FY till the date of payment.

The aggregate of the amounts determined earlier exceeds the aggregate of the amounts calculated finally

shall be claimed as ITC in GSTR-3B.

5. GSTR-2A Reconciliation from Feb 2020 to Sep 2020 in GSTR-3B of Sep 2020

GSTR-2A reconciliation for the period Feb 2020 to Sep 2020 must be undertaken cumulatively and total ITC availed in

the GSTR-3B from February 2020 to September 2020 cannot exceed more than 10% of eligible credit

6. Reversal of ITC for non-payment of consideration within 180 days

The registered person may check the creditors ageing as on 30th September 2020, there should not be any vendor who

has not been paid for supplies made in FY 2019-20. ITC must be reversed for supplies related to FY 2019-20 against

which payment has not been made till 30th September 2020.

1. Actions points needs to be done under GST for transactions of FY 19-20 before the due date of filing GSTR 3B of September 2020 (I.e. 20th October’ 2020) or furnishing of Annual return of FY 2019-20, whichever is earlier:

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Goods & Services Tax

Action Points before 30 Sep’ 2020

COMPLIANCE CALENDAR

Compliance Calendar

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Date Particulars

07-09-2020 Payment of TDS/TCS - For the period 1st August 2020 to 31st August 2020

07-09-2020

Payment of Equalisation Levy on online advertisement and other specified services, to be dis-

charged by Indian payers, referred to in Section 165 of Finance Act, 2016- For the period 1st Au-

gust 2020 to 31st August 2020

15-09-2020 Instalments of Advance Tax for the Assessment year 2021-22

15-09-2020 Payment and furnishing of challan-cum-statement (Form 26QC) in respect of tax deducted under

30-09-2020

30-09-2020

30-09-2020

Filing of original/ revised return for the Assessment Year 2019-20

Investment/ construction/ purchase for claiming roll over benefit/ deduction in respect of capital

The date for commencement of operation for the SEZ units for claiming tax holiday

Direct Taxes

Compliance Calendar

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Indirect Taxes

Period Form/ Return Due Date Remarks

August’ 2020

GSTR-1 11-09-2020

Taxpayers having aggregate turnover more than

Rs. 1.5 crores in preceding financial year.

August’ 2020

GSTR-3B 20-09-2020

Taxpayers having aggregate turnover more than or

equal to Rs. 5 crores in preceding financial year.

August’ 2020

GSTR-3B 22-08-2020

Taxpayers having aggregate turnover upto Rs. 5

crores in preceding financial year. (Group-A). Fur-

ther, no interest shall be payable till 27-09-2020.

August’ 2020

GSTR-3B 24-08-2020

Taxpayers having aggregate turnover upto Rs. 5

crores in preceding financial year. (Group-B). Fur-

ther, no interest shall be payable till 29-09-2020.

August’ 2020 GSTR-4 31-10-2020 The yearly return for FY 2019-20 by composition

dealers.

August’ 2020 GSTR-5 20-09-2020 Non-resident taxpayers.

August’ 2020 GSTR-6 13-09-2020 Input Service Distributors

August’ 2020 GSTR-7 10-09-2020 Tax deductors at source (TDS)

August’ 2020 GSTR-8 10-09-2020 Tax collectors at source (TCS)

FY 2018-19 Annual Return

GSTR 9 & 9C 30-09-2020

Annual return in form GSTR-9 & reconciliation

statement in form GSTR-9C.

*Group A- Chhattisgarh, Madhya Pradesh, Gujarat, Maharashtra, Karnataka, Goa, Kerala, Tamil Nadu, Telangana, Andhra

Pradesh, Daman & Diu and Dadra & Nagar Haveli, Puducherry, Andaman and Nicobar Islands, Lakshadweep.

*Group B– Himachal Pradesh, Punjab, Uttrakhand, Haryana, Rajasthan, Uttar Pradesh, Bihar, Sikkim, Arunachal Pradesh,

Nagaland, Manipur, Mizoram, Tripura, Meghalaya, Assam, West Bengal, Jharkhand, Odisha, Jammu and Kashmir,

Ladakh, Chandigarh and Delhi.

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CA. Dinesh Singhal [Partner]: [dinesh.singhal@snr.company] [+91-99534 75125]

CA. Parul Bansal [Manager]: [parul.bansal@snr.company] [+91-97109 02902]

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