How much is your goodwill and entity worth?
CA Anand Varma
Valuation intricacies and different views of capital for investors to see how secure is their investment against risk? Goodwill and Entity valuation
Goodwill of an enterprise is an important 'asset' which is relevant for investors in their decision to invest or not and to know how goodwill is quantified? A chartered accountant may think this to be his forte to provide an answer but how much is the value of goodwill of an entity and value of an entity may be difficult to answer but not impossible. It should be remembered entrepreneurs are more interested to know the values of his goodwill and entity which could be used in a buy and sell deal or just to build further upon those values, than the accounting values of goodwill and entity. This article has endeavored to deal with the more complex business valuation side whilst the accounting valuation has been dealt with briefly.
Business notion of goodwill: Value of a business is not always defined by what assets an entity owns and what it owes. If one goes by the Asset Valuation Method, value of a business is determined by adding up the value of its assets and subtracting liabilities. It tells you the value of your business if it were closed down today and its assets sold off, but doesn't take into account the ability of those assets to generate future revenue. For that reason, it may understate the true value of the business.
Example
X wants to buy a manufacturing business with assets of $500,000 and liabilities of $400,000. The net asset value of the business is $100,000.
X wants to buy a manufacturing business with assets of $500,000 and liabilities of $400,000. The net asset value of the business is $100,000.
What about goodwill?
Method 1: Net asset (asset valuation) method
This method doesn't include a value for goodwill so it may understate the true value of a business. Goodwill is the difference between the true value of a business and the value of its net assets. It can be crucial to the value of retail and service-based businesses.
For example, if you value a business such as an established retail store, where service, location and reputation are important, the value of any goodwill would have to be added to net assets to get a valuation.
Can goodwill be transferred if you buy a business? It can come from physical features such as location, or from personal factors, like the owner's reputation or their relationships with customers or suppliers, which may not be transferable.
If the business is underperforming and has no goodwill, then using the net assets valuation method could be an accurate way of determining its value.
How to quantify goodwill of an entity as a business notion?
A successful business will develop customer loyalty and an overall positive reputation in its community (superior competitiveness, innovation and managerial expertise), which will cause its market value to be greater than its book value. Difference between the value of an entity as reflected in its balance sheet and its market value (e.g., market cap) is known as its goodwill. However a business is not allowed to record goodwill that it generates for itself.
How to determine the market value of net assets of an entity that can be regarded as its market capitalisation or value, for investors to take a forward looking view from a statutory balance sheet?
The aggregate of value of business goodwill as explained above and the value of in-force (VIF) business will give the entity level market capitalisation, to capture a market view of its net assets in financial statements. Value of in-force (VIF) business is the present value of expected future shareholder profits (capital inflows) less the present value cost of holding capital required to support the in-force business (capital outflows).Cost of holding risk adjusted capital = initial risk capital minus present value of expected return on risk capital plus present value of tax plus/minus present value of increase/release of risk capital –this component is the balancing figure =required closing risk adjusted capital aligned to capital management and business plan. Added to the VIF figure the value of goodwill being the difference between the market capitalisation and net assets value (book value) gives the view of market value of net assets. This view is also called the statutory balance sheet view of capital.
"The value of in-force" has to do with the amount of current or present value of the future profits that owners and investors of an entity anticipate will be realized from its business activities over a period of time. Projecting this figure is key to entrepreneurs, since it helps to determine if the he will remain solvent over the long term and generate some sort of profit above and beyond honoring expenses and claims submitted by customers.
Since providing business activities is considered a type of in-force business, owners must project the revenue stream, operational costs and ultimately the net profit that is realized from the business endeavor. This process involves considering the present value of all the business contracts currently written and projecting what type of revenue will be generated from those up to the point of execution on those contracts including returns and customer claims. Doing so makes it easier to determine if new contracts are being written at a pace that helps to balance the payouts, effectively keeping the entity solvent. It also helps to determine if the investments held by the entity are producing a sufficient return to help support the overall business model. When this is the case, the value of in-force is considered positive and the provider is highly likely to remain in business.
Accounting notion of goodwill: Accounting goodwill is the excess value of a firm's net assets over the acquisition price and is recorded by the acquiring entity at the time of business acquisition or combination. Goodwill is not associated with a physical object that the business owns, so it is an intangible asset and is listed on a company's balance sheet. Further, accounting goodwill is not amortised but is tested for impairment on the reporting date of financial statements.
Method 2: Capitalised future earnings
This method to value an entity is another method close to that of value of in-force business but it does not take into account the value of goodwill. When you sell a business, you're selling not only its assets but also the right to all profits the business might generate. Capitalising future earnings is the most common method used to value small businesses. The method looks at the rate of return on investment (ROI) a buyer can expect to get from the business.
How it works
- Work out the average net profit of the business over the last three years using its profit-and-loss statements. Adjust the profit for any one-off expenses or other irregular items each year.
- Decide on the annual rate of return a buyer might be looking for. There are no hard and fast rules about the number to choose, except higher risk should give higher returns. Compare the business with other investment opportunities — from safe havens like term deposits, to riskier investments like shares. Also look at the rate of return that similar businesses in the same industry achieve.
- John net profits by the rate of return to determine the value of the business, then multiply by 100.
Example
John is looking at buying a bakery business with average net profits of $100,000 per annum after adjustments. John wants an annual rate of return of 20%. The capitalised earnings valuation is:
John is looking at buying a bakery business with average net profits of $100,000 per annum after adjustments. John wants an annual rate of return of 20%. The capitalised earnings valuation is:
Other two methods to value an entity are given below, but again goodwill does not find a special weightage.
Method 3: Earnings multiple
This method is often used to assess the value of entities whose shares are traded on a stock exchange and reflect market expectations. But it can also be used to value unlisted businesses. Its big advantage is its simplicity. The difficulty lies in deciding which multiple to use.
How it works
Multiply the business' earnings before interest and tax (EBIT) by your selected multiple. For example, you might value the business at twice its annual earnings — so a business with an EBIT of $200,000 might be valued at $400,000.
The multiple you choose will depend on the industry and the growth potential of the business. A service-based business might be valued at as little as one year's earnings, while an established business with sustainable profits might sell for as much as six times earnings.
Method 4: Comparable sales
Whatever other valuation method you use, you should also look at prices for recent sales of similar businesses. It makes sense to know what is happening in the market you're interested in. This is a relative value notion.
Speak to business brokers and gauge their feeling about the business' value. They might know what similar operations are selling for and how the market is placed. Check business-for-sale listings in relevant industry magazines, newspapers or websites.
2 Different views of capital –economic v. accounting capital
Problem with financial statement capital is it does not recognise various 'hidden' values such as goodwill. Accounting capital does not provide dynamic view of an ongoing, active entity. It is not forward looking. It looks backward only to previous exposure. Economic capital gives management a universal risk metric tool to quantify risk. Without a common metric in place, entities and investors will struggle to address both (i) individual risks and (ii) to understand how much economic capital (present or fair value) in total is being put at risk across the organization to support a given level of business activity linked with capital management and business plan.
Investors will find economic capital to be much more useful in addressing the risk investors carry like market volatility, uncertainty and calamity. Available economic capital is calculated as equal to market value of assets minus market (fair) value of liabilities plus depreciation allowance. Required economic capital is equal to capital required to support a business with a certain probability of default (VaR). Excess capital =available economic capital –required economic capital. Economic franchise value =pv of revenue-cost linked to barriers of entry. If barriers to entry are low, then according to the textbooks a profitable firm is likely to face many competitors, leading to erosion of franchise value. Only if barriers to entry are high will the firm be able to earn monopoly rents for a long time.
Economic significance of franchise value is such that the value represents entity's superior consumer satisfying attributes of products and services resulting into stronger revenues and returns on investment compared to other entities in the same line. It is these much desirable higher revenues and returns which provide that extra layer of market-related economic capital to improve the coverage of the risk inventory held and valued at fair value or pv, over and above (i) the required economic capital and (ii) any excess capital.
Economic capital, an aggregate of franchise value, required economic capital and any excess capital gives an economic balance sheet view to investors which can be useful in knowing if the entity is supported with enough market-consistent capital to survive in the worst case scenario. No goodwill.
Spotting franchise value
One way to help ensure your portfolio has above average results over the long-term is to purchase shares of business that possess significant franchise value. In the investment world, franchise value refers to the popularity of a particular brand or product with consumers. If you are trying to decide if a business has franchise value, ask yourself these three questions:
1 Am I willing to pay more for the brand (e.g., Hershey's) as opposed to another, cheaper brand (e.g., the generic chocolate bar)?
2 If a store didn't have the brand in which I was interested, would I walk across the street to buy the product I wanted?
3 If I started a business in direct competition with this product, what are my chances of success? Would I be able to make a dent in its market share or is the product so firmly entrenched it would be difficult to wrestle away even a small portion?
In other words, economic capital is the (a) discounted value of (i) future cash flows of future expected (pv of best estimated liability) and unexpected liability and allocated to existing capital resources at fair value within the balance sheet or (b) excess of capital over targeted financial strength. Unexpected future losses should be restricted to VaR threshold over a day, week, month, quarter or a year.
Therefore, there is an interest in establishing what is the 'correct' level of capital under given parameters so that providers of capital don't not expect to earn a risk return that is too high, since this leads to an excessive cost of products to customers of a bank or insurance or other entity, and capital is not too low either, since this leads to an unacceptable risk of insolvency.
Different views of capital
Conclusion
Aiming for consistent and higher business valuations by continuous business improvement processes and responsive competitiveness could give entity a sustainable microeconomic business model, besides strengthening the country's macroeconomic indicators like the GDP, Current Account Balance and Exchange Rates, instilling investor confidence. Economic capital helps entity a right level of risk appetite and risk tolerance aligned with entity level goals. In case of inadequate EC, entity needs to raise more debt or equity capital with specific fair valued risk inventory held.
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$ (reserve currency) has been used in this write up just to provide a common business understanding across borders.
Disclaimer: As this write up has been prepared without considering reader's objectives, financial situation or needs, you should, before acting on this note, consider its appropriateness to your circumstances and may take a professional advice.
(Author may be contacted at varma1002003@yahoo.co.in)
Appointment of key managerial person – class of company
Section 203 of the Companies Act 2013 requires appointment of whole-time key managerial personnel for the prescribed class of companies. MCA has notified that public companies having paid-up share capital of rupees one hundred crore or more and annual turnover of rupees one thousand crore or more which are engaged in multiple businesses and have appointed Chief Executive Officer for each such business shall be the class of companies for the purposes of the second proviso to sub-section (1) of section 203 of the said Act.
GOVERNMENT OF INDIA
MINISTRY OF CORPORATE AFFAIRS
NOTIFICATION
MINISTRY OF CORPORATE AFFAIRS
NOTIFICATION
New Delhi, dated 25th July, 2014
S.0.—-(E). – In exercise of the powers conferred by the second proviso to sub-section (1) of section 203 of the Companies Act, 2013 (18 of 2013), the Central Government hereby notifies that public companies having paid-up share capital of rupees one hundred crore or more and annual turnover of rupees one thousand crore or more which are engaged in multiple businesses and have appointed Chief Executive Officer for each such business shall be the class of companies for the purposes of the second proviso to sub-section (1) of section 203 of the said Act.
Explanation. – For the purposes of this notification, the paid-up share capital and the annual turnover shall be decided on the basis of the latest audited balance sheet.
[File No. 1/5/2013-CL-V]
(Amardeep Singh Bhatia) Joint Secretary to the Government of India
Circular for Input Service Distributor: Ate, drank absolutely nothing, and broke the glass worth twelve cents
CA. Pradeep Jain
CA. Preeti Parihar
Shruti Bhandari
INTRODUCTION:
There may be more than one factory registered under Central Excise and running under the same management. In order to facilitate the management, single head office is being set up for incurring expenses, availing services, easy disbursements and communication purpose. Normally, the invoices of services are being received in the name and address of the head office. Department does not allow the Cenvat credit of such input services as the invoices bear the address of head office despite fact that the same are consumed at different units of that head office. Also, sometimes common expense is being incurred by the head office which benefits all the units of that management like advertisement expenses. In such cases, besides the technical lapses like non- mention of the address of factory, there is dispute about the quantum of credit attributable to each factory. In order to overcome these problems, the concept of input service distributor has been introduced in the Cenvat Credit Rules, 2004. In such cases, the head office receives the input services in its name and further distributes the same to the factories running under its management after getting itself registered as input service distributor. The manner of distribution of credit has been laid down in the rule 7 of the Cenvat Credit Rules, 2004 which had undergone amendment in the month of February. By virtue of the said amendment, some confusion was there in the manner of interpretation which has been clarified by issuing a circular in this budget. The amendment, confusion and clarification have been discussed here in this piece of articulation.
Situation upto 28.2.2014:-
The manner of distribution of input service credit has been explained in the rule 7(d) of the Cenvat Credit Rules, 2004. The relevant portion in issue effective upto 28.2.2014 read as follows:-
"credit of service tax attributable to service used in more than one unit shall be distributed pro rata on the basis of the turnover during the relevant period of the concerned unit to the sum total of the turnover of all the units to which the service relates during the same period."
Explanation-1- For the purpose of this rule "unit" includes the premises of the provider of output service and the premises of manufacturer including the factory, whether registered or otherwise.
Explanation-2- For the purpose of this rule, the total turnover shall be determined in the same manner as determined in rule 5"Total Turnover" means sum total of the value of –
(a) All excisable goods cleared during the relevant period including exempted goods, dutiable goods and excisable goods exported;
(b) Export turnover of services determined in terms of clause (D) of sub-rule (1) above and the value of all other services, during the relevant period; and
(c) All inputs removed as such under sub-rule (5) of rule 3 against an invoice, during the period for which the claim is filed."
Explanation3. - (a)The relevant period shall be the month previous to the month during which the CENVAT credit is distributed.
(b) In case if any of its unit pays tax or duty on quarterly basis as provided in rule 6 of Service Tax Rules, 1994 or rule 8 of Central Excise Rules, 2002 then the relevant period shall be the quarter previous to the quarter during which the CENVAT credit is distributed.
(c) In case of an assessee who does not have any total turnover in the said period, the input service distributor shall distribute any credit only after the end of such relevant period wherein the total turnover of its units is available.
The effect of this provision was that if the service was used in more than one unit, it was distributed on pro rata basis of sales to total sales of all the units to which the service related. In other words, if any input service was being used in the unit 1 and 2 out of total four units, it was distributed in these two units based upon total turnover of these two units only. The situation can be explained with the help of following example:-
Suppose an Input service distributor (ISD) has four units. The turnover of the four units and credit available for distribution may be assumed as follows:-
| Amount (in Rs.) | |
| Unit A | 20 crores |
| Unit B | 30 crores |
| Unit C | 10 crores |
| Unit D | 5 crores |
| Total credit distributable | 15000 |
Suppose the above input service was consumed in unit A and B only, so according to above provision, the credit was to be distributed as follows:-
Unit A's share: Turnover of unit A/ Total turnover of unit A &B * Cenvat Credit
= 20/50 * 15000
= Rs. 6000/-
Unit B's share = 30/50 * 15000
= Rs. 9000/-.
However, if the turnover of any unit was not available during the period, the credit was to be distributed only after end of such relevant period when the turnover of that unit was available. But what if the unit was under establishment stage and turnover was not available for couple of months or even a year? In our view, the lacuna was there in the explanations to this rule, however, there was no problem with the sub-rule (d) which laid down correct manner of distribution of credit to the units which actually consumed the input service. But, the amendment was carried out in the main body of sub-rule (d) which is the reason of all the post amendment problems which are discussed herein.
The amendment: situation after 28.2.2014:-
The amendment was carried out in the main body of sub-rule (d) of rule 7 of Cenvat Credit Rules, 2004 vide notification no. 05/2014-CE (N.T.) dated 24.2.2014, effective from 1.3.2014. This notification substituted the above referred provision as follows:-
'credit of service tax attributable to service used by more than one unit shall be distributed pro rata on the basis of the turnover of such units during the relevant period to the total turnover of all its units, which are operational in the current year, during the said relevant period'
The amended provision had created the confusion amongst assessees as the Revenue officials were interpreting this provision in a way that in the case an input service is used by more than one unit, its credit will be distributed amongst such units (which actually used the input service) however, the denominator for distribution shall remain the "total turnover of all of its units". This interpretation taken by department can be explained with the help of following example:-
The situation can be explained with the help of following example:-
Suppose an Input service distributor (ISD) has four units. The turnover of the four units and credit available for distribution may be assumed as follows:-
| Amount (in Rs.) | |
| Unit A | 20 crores |
| Unit B | 30 crores |
| Unit C | 10 crores |
| Unit D | 5 crores |
| Total credit distributable | 15000 |
Suppose the input service to which the above referred credit was attributable was utilized only by unit A & B. According to amended provision, the credit is to be distributed as follows:-
Unit A's share = Turnover of A/ Total Turnover (A+B+C+D)*Cenvat Credit
= 20/65*15000
= Rs. 4615/-
Unit B's share = 30/65*15000
= Rs. 6923/-
Thus, by virtue of amended provision, total credit distributed between the two units A and B was Rs. 11538/- only and credit of Rs. 3462/- was lapsed. This lacuna was the root of problem, so it was represented to the Government to bring suitable clarification in this regard.
Clarification given vide Budget, 2014:-
Now, while announcing the budget, clarification has been issued by Board to clarify the amended rule 7(d) of the Cenvat Credit Rules, 2004. This clarification has been issued vide Circular no. 178/4/2014-ST dated 11.7.2014. In this circular, it has been clarified that in case the input service has been utilized in more than one unit, the credit will be distributed in all the units (despite fact that the service was used only in two / three units out of total four units working under ISD). This clarification has been explained in the circular at para 4 which reads as follows:-
"4. An Input Service Distributor (ISD) has a total of 4 units namely 'A', "B', 'C' and 'D', which are operational in the current year. The credit of input service pertaining to more than one unit shall be distributed as follows:-
Distribution to A = X ÷ Y * Z
X = Turnover of unit 'A' during the relevant period
Y = Total turnover of all its unit i.e. 'A'+'B'+'C'+'D' during the relevant period
Z = Total credit of service tax attributable to services used by more than one unit.
Similarly the credit shall be distributed to the other units 'B', 'C' and 'D'.
Illustration:
An ISD has a common input service credit of Rs. 12000 pertaining to more than one unit. The ISD has 4 units namely 'A', 'B', 'C' and 'D' which are operational in the current year.
| Unit | Turnover in the previous year (in Rs.) |
| A (Manufacturing excisable goods) | 25, 00,000 |
| B (Manufacturing excisable and exempted goods) | 30, 00,000 |
| C (providing exclusively exempted service) | 15,00,000 |
| D (providing taxable and exempted service) | 30, 00,000 |
| Total | 1, 00, 00,000 |
The common input service relates to units 'A', 'B' and 'C', the distribution will be as under:
(i) Distribution to 'A' = 12000 * 2500000/10000000 = 3000
(ii) Distribution to 'B' = 12000 * 3000000/10000000 = 3600
(iii) Distribution to 'C' = 12000 * 1500000/10000000 = 1800
(iv) Distribution to 'D' = 12000 * 3000000/10000000 = 3600
The distribution for the purpose of rule 7(d), will be done in this ratio in all cases, Irrespective of whether such common input services were used in all the units or in some of the units."
The analysis of above para from the circular makes it ample clear that now even if any service is being used in two units out of total three or more units, the credit will be distributed amongst all the units irrespective of the fact that the service was actually used in two units only.
Implications of Clarification:-
The implications of this clarification are explained as follows:-
- The Circular has some strange drawings. It seeks to allow the distribution of credit to all the units in case the input service is being used by more than one unit. Suppose, an ISD has seven factories (namely 1, 2, 3, etc.) and the input service is being used for only two factories (say 1 & 2 which are manufacturing only dutiable goods). Even in this case, the credit will be distributed to all the seven units.
- In the above example, say out of seven factories, the factory no. 3 and 4 are manufacturing both dutiable and exempted final products and factory no. 5 and 6 are exclusively manufacturing the exempted goods. According to this clarification, under the above given situation, the credit will be distributed to factory no. 5 and 6 also which are in fact not allowed to take and utilize the credit so distributed by ISD. In such a case, situation is worse as the input service was never utilized by these two factories, still the credit is being distributed to them and these are not allowed to utilize the credit. Thus, the assessee will lose certain amount of Cenvat credit despite fact that the input services were entirely used in manufacture of dutiable goods.
- Further, some part of credit will also be distributed to factory no. 3 and 4 which are manufacturing both dutiable and exempted goods. In such a case, though these units will be allowed to take the Cenvat Credit distributed by ISD, it will be subject to provisions of rule 6(3) of the Cenvat Credit Rules, 2004. Thus, a major part of the credit availed will get reversed. Recalling the fact that this credit which is now reversed at factory no. 3 and 4 pertains to input service which was actually utilized at factory no. 1 and 2 in manufacture of 100% dutiable goods. Here also, the assessee suffers loss of certain amount of Cenvat Credit.
- It is worth noting here that in order to avoid complicacies of rule 6 of the Cenvat Credit Rules, 2004; some manufacturers/service providers set up separate premise for manufacturing exempted goods or for providing exempted service. This clarification will complicate the situations for these manufacturers or service providers which have more than two premises (out of which one or more is providing exempted service or manufacturing exempted goods) as the ISD will be required to distribute credit to all the premises, resulting into loss of Cenvat Credit as explained in the forgoing paras.
- It is worth noting here that the definition of input service itself says that to be an input service, the service should be USED by the manufacturer or provider of output service. In the instant case, the credit will be distributed by ISD in certain cases even if the said service was not 'used' by the manufacturer or service provider. This service will not be an "input service" for such manufacturers or service providers; so now, will the department allow such credit distributed by the ISD?
Before winding:-
The clarification issued by Board seems to be suffering from certain lacunas. Also, the circular saying that the credit will be distributed in all the units despite the fact that the service was consumed in only two units; is against the very basic provision of Cenvat Credit Rules, 2004. Since it will not be an input service, its credit will ultimately be denied in the unit where it was not actually USED. Resultantly, the situation will be same as it was before the issue of this Circular. So, in our view, issuing this circular is a sheer waste of time. Remember the famous saying… "Ate, drank absolutely nothing, and broke the glass worth twelve cents"…
MUMBAI, JULY 26, 2014: THE issues before the Bench are - whether the assessee is also eligible for deduction u/s 80IA on income earned from storage facility taken on rent and transportation income earned from sale of water from jetty to party's place. And the answers go against the assessee.
Facts of the case
The assessee is a wholly owned subsidiary of Hindalco Industries Ltd. The assessee entered into an agreement with Gujarat Maritime Board for development, maintenance and operation of Jetty (Port) at Dahej, Gujarat. The assessee claimed deduction under section 80IA on account of infrastructure development of the port. The AO during the assessment proceedings observed that the assessee had claimed exempt income of Rs.17,97,712/- from sale of water, Rs.51,535/- from storage facility and Rs.44,640/- as transportation charges totaling Rs.18,93,887/-. He observed that the said income did not qualify for deduction under section 80IA because of the fact that the same was neither derived from nor had any connection with the business activity of the assessee of providing infrastructure facility. He further observed that the assessee under the agreement was entitled for doing the landing and shipping activity and only the income from landing and shipping activity was qualified for deduction under section 80IA.
On appeal, the CIT(A) observed that the similar disallowance was confirmed in the case of assessee for assessment year 2008-09 also, confirmed the above disallowance for this year. The CIT(A) held that the said storage facility was not part of the infrastructure facility of the jetty and even the assessee was not owner of the said storage facility but it belonged to M/s. Hindalco Industries Ltd., therefore, upheld the disallowance relating to income of assessee from storage facility. Hence, the present appeal.
On appeal, the Tribunal held that,
++ a perusal of the submissions reveals that so far the income from sale of water is concerned, the same had been earned by the assessee for supply of water to cargo ships for their engine cleaning and other miscellaneous purposes and the same in our view was a part of the activity of operation of the jetty. Similarly, as explained by the assessee, the miscellaneous income had been earned by the assessee from the non regular cargo of other nearby jetty which had been handled at the assessee's jetty for which the assessee had charged them for use of its jetty. Hence, in our view the claim of deduction on account of income from sale of water and miscellaneous income was justified as the same was part of operation and maintenance activity of the assessee at the said jetty;
++ since the storage facility was not a part of the infrastructure facility development by the assessee at the port at Dahej, hence in our view, the assessee was not entitled to claim any deduction in respect of income earned on account of storage facility;
++ so far so, the transportation charges are concerned, the said income had been earned by the assessee for arranging the transportation from the jetty to party's place. The same, in our view, cannot be said to be a part of infrastructure facility development at the jetty.
(See 2014-TIOL-477-ITAT-MUM)
Some Helpful Tips for Filing Income Tax Returns
Income-tax return is a legal document and it should be filed by the assessee with due care and caution. There should be no corrections or overwriting and it should be properly signed and verified by the person authorized to do so under the provisions of the Income-tax Act. The following important points may be taken care of while filling up the return forms:
1. ITR Applicable- Each assessee has to identify the correct ITR Form applicable in its case before filing the return of income.
2. No enclosures to the return- Rule 12(2) of the I.T Rules provides that the return of income and return of fringe benefits required to be furnished in Form No. ITR-1, ITR-2, ITR-3, ITR-4, ITR-4S ITR-5, ITR-6, or ITR-8 shall not be accompanied by a statement showing the computation of tax payable on the basis of return, or proof of tax, if any, claimed deducted or collected at source or the advance tax or tax on self assessment, if any, claimed to have been paid or any document or copy of any account or form or report of audit required to be attached with the return of income or return of fringe benefits under any provisions of the Act.
3. For timely delivery of refunds, ensure correct address and account number on your Return of Income – From 1.10.07 onwards, all income tax refunds in Bangalore, Chennai, Delhi, Kolkata and Mumbai will be delivered by the Refund Banker directly at the communication address mentioned on the Return of Income. Taxpayers are requested to fill in the correct address(available during working hours for delivery) to ensure speedy delivery of refunds. In the case of taxpayers who opt for refunds through ECS, it will be credited directly to the bank account for which correct MICR code/ Bank Account Number has to be furnished on the Return.
4. Manner of filing the new Forms
These Forms can be submitted in the following manner:
(i) furnishing the return in a paper form;
(ii) furnishing the return electronically under digital signature;
(iii) transmitting the data in the return electronically and thereafter submitting the verification of the return in Form ITR-V;
(iv) furnishing a bar-coded return in a paper form:
Mandatory E-Filing of Income Tax Return
- E-filing of Income Tax return with digital signature is mandatory for Individuals, HUF and firms requiring statutory audit u/s 44AB of the Income Tax Act, 1961.
- E-filing of Income Tax return with digital signature is mandatory for all Companies irrespective of Income.
- A person, other than a company and a person required to furnish the return in Form ITR-7 ] if his or its total income, or the total income in respect of which he is or it is assessable under the Act during the previous year, exceed [five lakh rupees], shall e-file their Income Tax return either with or without digital signature.
- Individual and HUF having assets (including financial interest in any entity) located outside India; or are signing authority in any account located outside India have to e-file their Income Tax return either with or without digital signature.
- If Assessee claims any relief of tax under section 90 or 90A or deduction of tax under section 91 of the Act than Assessee have to e-file their Income Tax return either with or without digital signature.
- All the Assessee who are required to file ITR-5 and not covered by tax audit provisions have to e-file their Income Tax return either with or without digital signature.
- In addition to above all the Assessees who are required to file furnish a report of audit specified under sub-clause (iv), (v), (vi) or (via) of clause (23C) of section 10, section 10A, section 10AA, clause (b) of sub-section (1) of section 12A, section 44AB, section 44DA, section 50B, section 80-IA, section 80-IB, section 80-IC, section 80-ID, section 80JJAA, section 80LA, section 92E, section 115JB or section 115VW or to give a notice under clause (a) of sub-section (2) of section 11 of the Act have to e-file their Income Tax return either with or without digital signature.
5. Filling out acknowledgement- Where the return is furnished in paper format, acknowledgement slip attached with the return should be duly filled in. The new forms are not required to be filed in duplicate.
6. Intimation of processing under section 143(1) – The acknowledgement of the return is deemed to be the intima-tion of processing under section 143(1). No separate intimation will be sent to the taxpayer unless there is a demand or refund.
7. Filing your return through Tax Return Preparers (TRPs)
If you are an individual or an HUF assessee and you are not required to get your accounts audited (called 'eligible person') under the provisions of the Income Tax Act, then you can use the services of a Tax Return Preparer (TRP). However, if the 'eligible person' is not a resident in India during the previous year relevant to such assessment year, he can not avail of the services of a TRP.
If you are filing your returns through a TRP then you should ensure that:
i) You are eligible to file return of Income under this Scheme;
ii) You give your consent to any Tax Return Preparer to prepare your return of income for any assessment year;
iii) You verify that the facts mentioned in the return are true and correct before you sign the return;
iv) You certify the amount which has been paid by you under this Scheme to the Tax Return Preparer for preparing and furnishing of the return of income; and
v) You take a receipt of the payment made to the Tax Return Preparer and produce the same before the Resource Centre or Assessing Officer, if required,
Incentive to Tax Return Preparers
The Tax Return Preparer shall charge a fee of two hundred and fifty rupees for any assessment year from the eligible person for preparing and furnishing his return of income for that assessment year:
Provided that he will charge no fees for preparing and furnishing the return for any eligible assessment year if the amount disbursable to him as per the scheme notified by the government for that eligible assessment year exceeds two hundred and fifty rupees. If the amount disbursable is less than two hundred and fifty rupees, we can charge the difference between rupees two hundred fifty and the amount disbursable.
8. Verification
The verification must be signed by the authorized person before furnishing the return and the name and designation of the person signing the return should also be written. Any person making false statement is liable to be prosecuted under section 277 of the Act.
WHO CAN VERIFY AND SIGN THE INCOME TAX RETURN?
a) Individual : The individual filing his Income Tax Return has to sign the return. In case the individual is mentally incapable, then the return may be signed by his Guardian or by any other person competent to act on his behalf.
In case the individual is absent from India or because of any other reason he is not able to sign and verify his return of income, then any person duly empowered by him through valid Power of Attorney may sign on his behalf. In such a case, a certified copy of the Power of Attorney must accompany the return.
b) Hindu Undivided Family : By the Karta or where he is absent from India or is mentally incapacitated from attending to his affairs, by any other adult member of such family.
c) Company : In this case by the following :-
1) Resident : Managing Director or, where there is no Managing Director or he is not able to sign and verify the return due to any unavoidable reason, by any director thereof.
2) Non-Resident : The return may be signed and verified by a person holding a valid Power of Attorney from the Company, which should be attached to the return.
3) Wound up/taken over by the Govt. : The return should be signed and verified by the Liquidator or the Principal Officer as the case may be.
d) Firm : Managing Partner, or where there is no Managing Partner or due to some unavoidable reasons, he is not able to sign and verify the return, by any partner thereof not being a minor.
e) Local Authority : By the Principal Officer.
f) Association of Persons : By any member of the Association or the Principal Officer thereof.
9. WHERE TO FILE THE INCOME TAX RETURNS?
An existing assessee must file his Income-Tax Return with the Assessing Officer who had previously assessed him or with the Assessing Officer where his case stands transferred. A new assessee should file the Return with the Assessing Officer having territorial jurisdiction over the area where he resides or his principal place of business is situated or with the Assessing Officer having special jurisdiction over specific assessees or classes of income. For example, where the major source of income of an assessee is the income from contract business, the IT Return should be filed with the assessing officer having jurisdiction over the contractor circles. A doctor or C.A. or an Advocate should file the returns in professional circles if any specified.
The return may be delivered at the counter in the concerned Range/Circle or it may be sent by registered post. The return is attached with two acknowledgement forms which should be duly filled in by the assessee. One copy of the acknowledgement form is to be returned by the official at the counter duly signed, stamped, numbered and dated in support of having received the return. In case of any doubt or problem, the taxpayer should contact the Public Relations Officer for guidance and help.
(Post is been updated on 15.07.2014 with revised Rule 12 of Income Tax Rules)
Why & for whom Income Tax return Filing before 31st July is mandatory?
CA Umesh Sharma
Karniti: Why & for whom Income Tax return Filing before 31st July is mandatory? Arjuna (Fictional Character): Krishna, 31st July 2014 is near and many taxpayers are hurrying up for filing income tax returns. What are the points to be considered before filing income tax returns?
Krishna (Fictional Character):Arjuna, for the financial year 2013-14, taxpayers who are not liable for tax audit under Income Tax Act, i.e. Salaried persons, pensioners, businessmen having turnover upto Rs.1 crore, professionals having gross receipts upto Rs.25 lakhs, persons having income from house property and other sources should file return upto 31st July 2014. There are many intricacies which should be followed by taxpayers.
Arjuna: Krishna,How can the taxpayers file returns?
Krishna:Arjuna, return filing has become very easy. The taxpayer should get registered on the website of the Income Tax Department www.incometaxindiaefiling.gov.in through valid mobile number and email. The taxpayer should fill the e-return form available on the website and upload the same.
After uploading the return, signed copy of the acknowledgement is to be sent to CPC, Bangalore within 120 days. Otherwise a digital signature option is also available. E-filing of returns is compulsory for assessees having income above Rs.5 lakhs. Assessees having income below Rs.5 lakhs have the option of either efiling the return or manually submitting it to the local income tax department.
Arjuna:Krishna,what are the major changes in the forms of return to be filed for financial year 2013-14 which needs to be take care off by these asseseees?
Krishna:Arjuna,the taxpayer should select proper form of return applicable to him based on his sources of income. Some of the major changes for year 2013-14are as follows :
- All salaries taxpayers will now have to give details of LTA (Leave Travel Allowance) and HRA (House Rent Allowance),other allowances and perquisites separately.
- If there is more than one owner of the house then while mentioning details in the schedule of Income from House Property the percentage of co-owners alongwith with their PAN will have to be given.
- Now onwards Income Tax Refund will be given directly in the bank account of the taxpayer through ECS. Therefore at most care should be taken while mentioning Bank Account Number and IFSC Code in the income tax returns.
We have discussed this in earlier conversations also, same may be referred.
Arjuna:Krishna, What care should be taken by salaried persons while filing income tax returns?
Krishna: Arjuna, Salaried persons unnecessarily take tension. They should not really worry as Form 16 issued by the employer contains all the details of income, deductions, tax deducted, etc. They should just confirm that Form 16 and Form 26AS match and file the return accordingly. The real problem arises only when any income other than salary or any deduction has not been included in Form 16 such as interest on saving bank account, FDR, rent from house property, capital gains, LIC payments, etc has not been included in Form 16. To avoid last minute rush and additional payment of tax, complete information of income and deductions should be given to the employer beforehand, so that proper TDS will be deducted and there will be less difficulty while filing returns.
Arjuna:Krishna, please explain briefly what care should be taken by businessmen while filing income tax returns?
Krishna: Arjuna,you asked a very complicated question as every businessman has to prepare Profit and loss account and Balance Sheet as per the nature of his business or profession. The businessman maydeterminehis profit/loss by comparing current year's actual financials with the previous years. Further as on 31st March, depreciation, stock, accounts of debtors and creditors, etc. have to be accounted and reconciled. Also, the figures have to be matched with other tax returns like vat, service tax, etc. Form 26AS is also required to be matched. The most important thing is that it is mandatory for businessmen having turnover upto 1 crore to show minimum 8% profit, otherwise tax audit provisions will be applicable.And yes, it is very important to file Loss return before 31st July 2014, otherwise loss cannot be carried forward to next year.
Arjuna: Krishna, does this mean that the return needs to file on time?
Krishna: Arjuna,taxpayer may face trouble if the return is not filed in time. Along with interest on tax payable, additional interest for late filing of return u/s 234A will also be required to be paid. Loss cannot be carried forward as given above. Further, if any mistake is noticed a belated return cannot be revised. Also, in case of refund interest will not be received for the period of delay. It means interest will be received from the date of filing of return. This will result in hardship to the taxpayer. Apart from this, if return is filed after 31st March 2015, penalty of Rs.5000 may be levied. Return should be filed every year as efiling of return is permissible for only two previous years due to which there can be technical difficulties. Many taxpayers file returns of previous years all at once at the time of applying for bank loan. This may create problems in the loan proposal, hence regular and timely filing of returns is beneficial.
Arjuna: Krishna, Why many taxpayers are so lethargic towards filing of returns?
Krishna: Oh Arjuna, Compliance of simple law is also difficult, be it any law. Like one become restless while waiting at the signal for one minute also.Everyone is desperate for the green signal to come so that we can go and out of this many people break the signal rules and run away. In the same way, inspite of the fact that the taxpayer is aware of the 31st July due date for filing returns since years, there is hurry and rush at the eleventh hour. Due to this, there is stress and return filing becomes burdensome. If proper information regarding income and tax is provided to the department through return, the department also avoids giving trouble by sending notices. Otherwise, legal proceedings between the taxpayer and department initiatewhich creates problem for everyone. In today's era of information technology and computerization, it is difficult to find a hideout for tax evaders. The only option available to the taxpayer is timely and correct payment of tax and filing of returns, if wants to live in peace of law.
Dear Taxguru lovers, your comments please.
Applicability & procedure of Service Tax under reverse charge
CA Navin Jain
1) Introduced in the Finance Act, 1994 under Service Tax Rules in 2002.
2) An explanation to Section 65(105) was added wherein concept of import of services was launched.
3) This explanation to Section 65(105) was removed in year 2006 and Section 66A was inserted.
4) Rule 2(1)(d) of the Service tax rules, 1994 prescribed the cases of deemed service providers.
5) Notification no. 15/2012-ST dated 17.3.2012 has been issued, Applicable from 01.04.2012 – Supersession Notification no. 36/2014
6) Notification No. 30/2012-Service Tax Dated- 20.06.2012 , applicable from 01.07.2012 supersession, Notification no. 15/2012-ST dated 17.3.2012, & 36/2014
7) Supply of manpower and security services added by notification 45-46, dated 07.08.2012
8) Service by director of a company to the said company added by notification 46-47, dated 07.08.2012
9) Service by director to Body Corporate added by dated 11.07.2014
10) Service by Recovery Agent to Bank, Financial Institution and NBFC added by dated 11.07.2014
Key Points
- Further service receiver can not claim general exemption limit of 10 Lakh rupees. So he has to pay even on few rupees of service received.
- In case of associates enterprises point of taxation will be earlier of date of debit of invoice in books or date of payment
- As per Rule 7 point of taxation will be date of payment.
- If payment is not made within 6 months (3 months from 01.10.2014) of the date of Invoice, Rule-7 is not applicable. The point of taxation will be determined as per general rule. ( i.e. Rule 3 point of taxation will be earlier of three event i.e. raising of invoice, providing of service or receipt of payment)
- For the purpose of import of services, separate rules namely "Place of Provision of Services Rules, 2012" have been framed.
- Three services have been notified for which both service recipient and service provider i.e. partial reverse charge mechanism, have been made liable for paying the service tax (a) Hiring of motor vehicle for passengers( without abatement) (b) Supply of Manpower and security services (c) Works contract
- Service tax payable under reverse charge cannot adjust with input credit of services.
- CENVAT credit shall be available only after the payment of value of service and service tax to the service provider. From 11.07.2014 CENVAT Credit of service tax paid under full reverse charge shall be available to the assessee immediately on payment of such service tax even if no payment has been made to service provider however under partial reverse charge, cenvat credit shall be available only after the payment of value of service and service tax to the service provider.
- Service recipient is allowed to take the credit of the service tax paid by him under reverse charge method on the basis of challan. For this purpose, rule 9(1)(e) is being amended.
List of Services under Reverse Charges
| Sl.No. | Description of a service | Percentage of service tax payable by the person providing service | Percentage of service tax payable by the person receiving the service |
| 1 | services provided or agreed to be provided by an insurance agent to any person carrying on insurance business | Nil | 100% |
| 2 | services provided or agreed to be provided by a goods transport agency in respect of transportation of goods by road | Nil | 100% |
| 3 | services provided or agreed to be provided by way of sponsorship | Nil | 100% |
| 4 | services provided or agreed to be provided by an arbitral tribunal | Nil | 100% |
| 5 | services provided or agreed to be provided by individual advocate | Nil | 100% |
| 6 | services provided or agreed to be provided by way of support service by Government or local authority | Nil | 100% |
| 7 | (a) in respect of services provided or agreed to be provided by way of renting or hiring any motor vehicle designed to carry passenger (With abatement) b) in respect of services provided or agreed to be provided by way of renting or hiring any motor vehicle designed to carry passenger on non abated value. (Without Abatement) From 11.07.2014 change in Without Abatement Scheme | NIL 60% 50% | 100% 40% 50% |
| 8 | services provided or agreed to be provided by way of works contract | 50% | 50% |
| 9 | any taxable services provided or agreed to be provided by any person who is located in a non-taxable territory and received by any person located in the taxable territory(IMPORT OF SERVICES) | Nil | 100% |
| 10 | Service provided or agreed to be provided by way of Supply of manpower and security services (Inserted through notification 45-46/2012 dated 07.08.2012 | 25% | 75% |
| 11 | Service provided or agreed to be provided by a director of a company to the said company (Inserted through notification 46-47/2012 dated 07.08.2012 | Nil | 100% |
| 12 | Service Provided by Recovery Agent to banking company or a financial institution or a non-banking financial company (Applicable from 11.07.2014) | NIL | 100% |
| 13 | Service provided or agreed to be provided by a director to Body Corporate (Applicable from 11.07.2014) | NIL | 100% |
The reverse charge is applicable if service receiver /service provider satisfy few condition .In other case service provider has to pay tax on full amount of service
| Sl.No. | Description of a service | SERVICE PROVIDER | SERVICE RECEIVER |
| 1 | services provided by an insurance agent to any person carrying on insurance business | ANY | ANY |
| 2 | services provided or agreed to be provided by a goods transport agency in respect of transportation of goods by road | where the consignor or the consignee is,— (a) any factory registered under or governed by the Factories Act, 1948 (63 of 1948); (b) any society registered under the Societies Registration Act, 1860 (21 of 1860) or under any other law for the time being in force in any part of India; (c) any co-operative society established by or under any law; (d) any dealer of excisable goods, who is registered under the Central Excise Act, 1944 (1 of 1944) or the rules (e) anybody corporate established, by or under any law; or (f) any partnership firm whether registered or not under any law including association of persons; | |
| 3 | services provided or agreed to be provided by way of sponsorship | any | body corporate/partnership firm |
| 4 | services provided or agreed to be provided by an arbitral tribunal | Arbitral tribunal | Business entity with a turnover more than rupees ten lakh in the preceding financial year; |
| 5 | Legal Services provided By ADVOCATE (Whether individual of Firm) to any Business Entity | individual or firm | Business entity with a turnover more than rupees ten lakh in the preceding financial year; |
| 6 | services provided or agreed to be provided by way of support service by Government or local authority | Government /Local authority | Business entity |
| 7 | (a) services provided or agreed to be provided by way of renting or hiring any motor vehicle designed to carry passenger on abated value. | Individual (prop ) /Partnership firm (registered or unregistered) /HUF | any company formed or registered under the Companies Act, 1956 (1 of 1956) or a business entity registered as body corporate located in the taxable territory; |
| (b) services provided or agreed to be provided by way of renting or hiring any motor vehicle designed to carry passenger on non abated value. | |||
| 8 | Service provided or agreed to be provided by way of Supply of manpower and security services | ||
| 9 | services provided or agreed to be provided by way of works contract | ||
| 10 | any taxable services provided or agreed to be provided by any person who is located in a non-taxable territory and received by any person located in the taxable territory | any | any |
| 11 | provided or agreed to be provided by a director of a company to the said company | Director (individual) | Company |
| 12 | provided or agreed to be provided by a director to Body Corporate | Director | Body Corporate |
| 13 | Service Provided by Recovery Agent to banking company or a financial institution or a non-banking financial company | any | Banking company or a financial institution or a non-banking financial company |
(Author may be contacted on Email:- cajainnavin@gmail.com)
Impact Analysis of Second Amendment to MGT Rules
Shampita Das
The Ministry of Corporate Affairs (MCA) came out with its latest Notification dated 24th July, 2014, being the second amendment to the Companies (Management and Administration) Rules, 2014 ('MGT Rule').
Below we present in a tabular format the details of the change alongwith its impact and our analysis on the same.
Change and Impact of the Notification
| Sl. No. | Section / MGT Rule No. | Change | Impact Analysis |
| Section 89 read with Rule 9 (3) | Rule 9 deals with 'Declaration in respect of beneficial interest in any shares'. Change: After Rule 9 (3) the following shall be inserted: "Provided that nothing contained in this rule shall apply in relation to a trust which is created, to set up a Mutual Fund or Venture Capital Fund or such other fund as may be approved by the Securities and Exchange Board of India" | Rule 9 requires every person whose name is registered in the register of members as a holder of those shares but who does not hold the beneficial interest in such shares to disclose to the company to this effect. The declaration requirement was also applicable to every beneficial holder of shares whose names are not on the company's register of members. The amendment seeks to exempt trusts which are created to set up Mutual Funds or Venture Capital Funds from the requirement of such declaration. This means that if such trusts are either registered but not beneficial holder or beneficial but not registered holder from the requirement of this Rule. | |
| Section 93 read with Rule 13 | Rule 13 deals with 'Return of changes in shareholding position of promoters and top ten shareholders', as provided below: Every listed company shall file with the Registrar, a return in Form No.MGT.10 along with the fee with respect to changes relating to either increase or decrease of two percent or more in the shareholding position of promoters and top ten shareholders of the company in each case, either value or volume of the shares, within fifteen days of such change. Change: The words "either value or volume of the shares" shall be omitted Explanation.- For the purpose of this sub-rule, the expression "change" means increase or decrease by two percent or more in the shareholding of each of the promoters and each of the top ten shareholders of the company. Change: Explanation Omitted | Sure enough this provision has already created a lot of confusion with its language. The Act provided that only a change in the number of shares (i.e. volume) of the promoters and top 10 shareholders were required to be filed with the RoC within 15 days of change. Confusion was whether even a one share change was also to be reported? The Rules clarified the confusion by prescribing a change limit of 2% for reporting. However the Rule also created its own version of law and provided that every change i.e. increase or decrease of 2% shareholding 'either in value or volume' was to be reported. Thus the Rules additionally laid down the requirement of reporting a 2% change in the value of shareholding as well. This amendment seeks to restore the provision of the Act and companies would now be required to disclose changes w.r.t. only the number of shares.The omission of the Explanation does not make much of a difference as the same can be derived from the Rule itself. Another point worth noting here is that while they were onto amending the said Rule, the MCA could have as well clarified and prescribed a mode for ascertainment of the change of 2% i.e. whether a series of events bringing about the 'change' is to be reported and if yes, what would be the base date from which the change is to be calculated. | |
| Section 115 read with Rule 23 | Rule 23 deals with the compliances w.r.t. Special Notice. Rule 23 (1) is provided below: (1) A special notice required to be given to the company shall be signed, either individually or collectively by such number of members holding not less than one percent of total voting power or holding shares on which an aggregate sum of not less than five lakh rupees has been paid up on the date of the notice. Change: The words '"not less than five lakh rupees" shall be substituted with the words "not more than five lakh rupees" | This amendment, which clearly follows the language of Section 115 of the Act, is somewhat weird. Prior to the amendment, the Rule suggested to correct the wrong language used in the Act, by providing as follows: Members, either singly or in aggregate, holding atleast 1% of the total voting power or atleastRs. 5 lakh worth of shares were allowed to issue special notice to the company. Post the amendment the Rule read as: Members, either singly or in aggregate, holding atleast 1% of the total voting power or not more thanRs. 5 lakh worth of shares shall be allowed to issue special notice to the company. Does this mean that if a member holds more than Rs. 5 lakh worth of shares, he/shecannot serve a special notice on the company? Orin case of joint serving of notices, if the collective value of shares is more than Rs. 5 lakhs they will not be allowed to serve the special notice? The whole intent of putting up limits was to discourage members from sending frivolous notices to companies and to allow members having substantial shareholding to serve such sensitive notices. With this amendment we are back to square one. | |
| Section 120 read with Rule 27 | Rule 27 provides for 'Maintenance and inspection of document in electronic form'. Rule 27 (1) is provided below: (1) Every listed company or a company having not less than one thousand shareholders, debenture holders and other security holders, shall maintain its records, as required to be maintained under the Act or rules made there under, in electronic form. Explanation.- For the purposes of this sub-rule, it is hereby clarified that in case of existing companies, data shall be converted from physical mode to electronic mode within six months from the date of notification of provisions of section 120 of the Act. Change: In sub-rule (1) and in the Explanation, the word "shall", shall be substituted with the word "may". | Prior to the amendment, every listed company and every company having 1000 shareholders were mandatorily required to maintain its records (meaning any register, index, agreement, memorandum, minutes or any other document) in electronic form. This also included mandatory conversion of existing records from physical mode to electronic mode within 30th September, 2014 i.e. 6 months from the date of commencement. This had created a huge responsibility on the companies to convert its existing data into electronic form. To make things worse, no base period from which such conversion was to be undertaken, meaning that companies in existence for over 100 years were required to convert its data for those 100 years into electronic form. With the amendment (which is also in line with Section 120 of the Act), the necessity of such maintenance and conversion has been made optional for such companies. On one hand this might be seen as a good sign since maintenance of records in e-form should be a facility allowed to companies. However, the same should not impose unnecessary burden. On the other hand, this was done to avoid wastage of paper and to promote e-governance. |
(Author is Associate at Vinod Kothari & Company and can be reached at shampita@vinodkothari.com)
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