Sunday, April 13, 2014

[aaykarbhavan] Business standard updates and legal digest




Why are company secretaries upset ?


SUDIPTO DEY

Barely days after the new company law regime has come into effect on April 1, there has been large scale protests by company secretaries ( CS) outside Shastri Bhavan ( that houses the Ministry of Corporate Affairs) and the Institute of Company Secretaries of India ( ICSI), the statutory body for training and certifying company secretaries.

Subsequently, over the last 10 days senior officials from ICSI and the MCA have been huddled in meetings to sort out the misgivings.

The Companies Act, 2013, limits the role of company secretaries ( CS) to 7,000- odd companies, putting at threat the livelihood of thousands of CS professionals in the country. The new rules mandate the appointment of a company secretary only for listed companies and public companies with a paid- up capital of 10 crore or more. There is no specific requirement for a private company under the new legal framework to appoint a company secretary.

According to ICSI estimates, of the nine lakh- odd active companies in India, around 93 per cent are private. According to R Sridharan, president, ICSI, the thrust of the new company law regime is on corporate governance and compliance. " Leaving out a vast majority of private companies from the ambit of secretarial audit goes against the spirit of the Act," says Sridharan. Moreover, company secretaries should be seen as an extended arm of the regulator, he adds. There are around four lakh registered company secretaries in the country and around 2,000 fresh professionals get registered every year.

What has taken the CS community by surprise is the divergence in the draft Act – issued towards the end of 2013- and the final notified rules that came out last week of March 2014. The draft rule had proposed that every listed company and " every other company" having a paid- up share capital of 5 crore or more should have whole- time key managerial personnel (KMP). Company secretaries are part of KMP, along with managing director or CEO, a whole- time director and the chief financial officer. The MCA has raised concerns over overlap in the scopes of secretarial audit and financial audit to limit the role of company secretaries. However ICSI's stand has been that secretarial audit relates to audit of compliances of applicable laws, while any financial audit would involve audit of financial transactions. Typically, financial audits fall under the ambit of chartered accountants.

The new law has done away with the need for pre- certification of some e- forms by a practicing professional. The ICSI's contention has been that pre- certification would help improve compliance and governance.

Corporate lawyers note that the Ministry would have to amend the rules if they were to make it mandatory on certain class of private companies to have company secretaries.

The law ministry would have to take a call on any such amendment in the rules, a Ministry official said.

RULES OF CONTENTION

KEYMANAGERIAL PERSONNEL

KMPs need to be appointed in every listed company and every public company having paid up share capital of 10 cr or more

SECRETARIAL AUDIT

Besides listed companies, the rules prescribe such audit for (a) public company having a paid- up share capital of 50 cr or more; or (b) having a turnover of 250 cr or more

ANNUAL RETURN

Annual return of companies with paid- up share capital of 10 cr or more or turnover of 50 cr or more to be certified by company secretary Extracts of annual return to be attached with the board report need not be certified by a company secretary

PRE- CERTIFICATION OF E- FORMS

Certain forms which required precertification according to Companies Act, 1956, do not require pre- certification by a practising professional; Pre- certification required only in respect of 14 forms

COMPANIES ACT, 2013

 

Minority shareholders can block related- party deals


RAJESH BHAYANI

Mumbai, 13 April

The new Companies Act rules have given a lot of powers to minority shareholders, but the one creating ripples in the corporate sector is that promoters, who are majority shareholders, cannot vote in special resolutions in cases of related- party transactions.

The new rules under Section 188 say any related- party transaction that is not done in the ordinary course of business and is not at an arm's length will need approval of minority shareholders by way of a special resolution. But, shareholders who are related or interested parties in the transaction will not be able to vote in resolutions relating to payment of brand fees or management fees to majority shareholders.

The section further says all related- party approvals will now be scrutinised by audit committees, comprising a majority of independent directors.

Related- party transactions include sale or purchase of goods, services and property, appointment in an office of profit in a company or group company, underwriting subscriptions, etc. The definition of 'related party' has also been widened to include holding companies, subsidiaries and several key managerial persons and executives, besides relatives of directors. Also, thresholds have been prescribed to determine transactions that will be treated as related- party ones. The transactions are linked with turnover and net worth and appointments to salary levels.

Amit Tandon, managing director of Institutional Investor Advisory Services ( IIAS), a proxy shareholder advisory firm, says the new provisions strengthen the hands of minority shareholders and will improve corporate governance.

Earlier, in select cases, the Centre's approval was necessary for special resolutions relating to appointment of directors and key managerial personnel.

Yogesh Sharma, partner (Assurance), Grant Thornton India, says: " Under the previous Companies Act, minority shareholders' approval or consent was not necessary for entering into related- party transactions. As a result, a majority of shareholders could go for transactions with themselves or related parties as they deemed appropriate." There will now be the much- needed checks and balances to protect minority shareholders, especially in companies where promoters continue to hold a majority of shares and even subsidiaries of multinational companies where the foreign parent holds a majority of shares.

Turn to Page 7 >

Corporate law experts welcome change in Companies Act rules, but warn against abuse of power to harass promoters even in genuine cases

What are related- party transactions?

|Sale, purchase or supply of goods, or materials associate company |Directors, key management personnel ( including relatives) |Firms/ companies where directors/ relatives have interests |Appointments of senior management- level and functional heads

What's the threshold to qualify as related- party transaction?

|If paid- up share capital of a company equals or exceeds 1 crore |If related- party transactions exceed 5% of annual turnover, or 20% of net worth — whichever is higher

What is an office of profit in related- party deals?

|Remuneration exceeding 10 lakh

 


Click here to read more...Turn to Page 7 >

Click: Article continued from…Minority shareholders can


Minority shareholders can block special resolutions


But there is a flip side, too. Many experts say the rules could open the doors to many minority shareholders " greenmailing' promoters for supporting or not supporting certain decisions. Tandon says "in many companies, smaller shareholders might greenmail promoters by asking for some favours or contracts against securing their votes in favour of the promoter when a special resolution comes up for voting." Grant Thornton India's Sharma gives an example of other possible difficulties in implementing the rules. " In the case of awholly- owned subsidiary, the rules provide that a special resolution passed by the parent entity is enough for entering into transactions between the parent entity and the wholly- owned subsidiary. However, it is not clear by whom and how the transactions of such whollyowned subsidiaries with say, a sister concern or an associate, will be approved." Similarly, there might be cases of subsidiaries where a 99 per cent stake is owned by the single parent company. Even in such cases, the parent would not be able to approve the transactions and have to depend on minority shareholders, who together own only one per cent shares.

Sai Venkateshwaran, partner & head (Accounting Advisory Services), KPMG India, says the changes in the Act are supportive of small shareholders but these could lead to abuse. " It could also lead to situations where majority shareholders find themselves unable to undertake genuine business transactions for want of minority shareholders' approval, even if the terms are reasonable. This could potentially cause hardship and disrupt business transactions."

>FROM PAGE 1

RBI relaxes some import/ forex rules


The Reserve Bank of India (RBI) has liberalised the procedure for facilitating the import of rough diamonds (termed roughs in the trade).

Till now, advance payment without any limit and without abank guarantee or standby letter of credit could be made only to notified mining companies by an importer, other than a public sector company or a department or undertaking of the Union or state governments. Henceforth, RBI will not notify the names of foreign mining companies from which such an importer may import roughs by way of advance payments and without any limit or bank guarantee or standby letter of credit. However, banks remitting the advance payments must adhere to certain conditions. RBI says banks should undertake the transactions on their commercial judgment and after being satisfied about the genuineness of the transaction. The foreign mining company should have the recommendation of the Gems and Jewellery Export Promotion Council. The importer should be a recognised processor of roughs, with agood record. Advance payments should be strictly as in the sale contract and made directly to the account of the company concerned — that is, to the ultimate beneficiary, not through numbered accounts or otherwise.

Also, due caution is to be exercised to ensure the remittance is not permitted for import of what are termed 'conflict diamonds' – they must have the Kimberly Certification, a scheme established by the United Nations to prevent diamond sales from financing war and/ or human rights abuses. The Know Your Customer and due- diligence exercise should be done by the banks as the rules prescribe. Banks should follow- up on the filing of the bill of entry and other documents evidencing the import of roughs.

In the case of an importer entity in the public sector or a department or undertaking of the central or state governments, banks may permit an advance remittance of at least $100,000, subject to the above conditions and a specific waiver of bank guarantee from the Union ministry of finance.

Other easing Giving partial effect to its first bi- monthly monetary policy statement for 2014- 15, RBI has now allowed all resident individuals and companies with actual or anticipated foreign exchange exposure to book forward contracts up to $250,000 on the basis of a simple declaration, without further documentation. The existing facilities for small and medium enterprises having direct and/ or indirect exposure to forex risk, permitting these to book or cancel or roll over forward contracts without having to produce the related documents, to manage their exposures effectively subject to specified conditions, remain unchanged.

RBI has also delegated the powers of compounding i. e. settling a dispute by agreeing on an amount less than the claim, to its regional offices in cases of delay in reporting inward remittance for issue of shares, in filing form FC ( GPR) after issue of shares, refund of share application money beyond 180 days, mode of receipt of funds, violation of pricing guidelines for issue, issue of ineligible instruments such as non- convertible debentures, partly paid shares, shares with optionality clause, issue of shares without approval of RBI or the Foreign Exchange Promotion Board, respectively, wherever required.

email: tncr@ sify. com

EXIM MATTERS

TN C RAJAGOPALAN

 

Howbeneficial are mergers for shareholders?


CLIFFORD ALVARES

If there's a quick way to expand a company's scale of operations, widen its product portfolio, expand into new geographies and add to its technological capabilities, it's through mergers and acquisitions (M& As). However, while companies are able to gain and expand their balance sheets, shareholders might not always be able to make money from such deals.

If the past is an indication, M& As might not always turn out as anticipated. Experts say shareholders must always watch for the price and strategic intention. They reckon in the coming years, mergers, domestic and foreign, will increase; so should the scrutiny of such deals.

Says Mehraboon Irani, head ( private client group), Nirmal Bang: " Not all mergers are profitable and not all will be profitable. But some will add a lot of value. Broadly, it depends on the price and the strategic intention of the company merging." Experts say some mergers have fared exceedingly well. Before the Ranbaxy deal, Sun Pharma made 16 acquisitions; the company has built a record of successful acquisitions and, through the years, managed to increase shareholder value. The market capitalisation of the company has zoomed from 6,027 crore to 1.18 lakh crore in the past 10 years, as it pursued both organic and inorganic routes for growth.

Daiichi Sankyo's acquisition of Ranbaxy was looked at with circumspection. Analysts told investors they should exit the stock through the open offer. However, this isn't true of Sun Pharma's acquisition of Ranbaxy. Sun has acquired a 6,000- crore enterprise for 19,200 crore in an all- stock deal; both are big players in the generics space. As their businesses are complementary, Sun Pharma can derive huge synergies in product portfolio, research and development and raw material sourcing. After the acquisition, the Sun Pharma stock has surged seven per cent to 628 at present. Experts say in 2008, Sintex had a one- year forward valuation discount of about 25 times to its earnings. But after the company acquired entities abroad at higher valuations, its valuation multiple fell — the stock is trading at a price/ earnings ratio of just four.

In 2008, the Tatas made strategic acquisitions such as Corus and JLR, within a span of a year. While one turned out to be an exceptional acquisition, the other is struggling.

Rikesh Parikh, vicepresident, market strategy, Motilal Oswal, says, "Everybody was expecting Corus to do well for Tata Steel and JLR to be a drag on Tata Motors. But it has turned out the other way round." The Hindalco- Novelis merger is yet to yield desired results. The Hindalco stock has seen compounded gains of only 7.4 per cent per annum since the acquisition in May 2007, similar to the BSE Sensex's gains of 7.2 per cent during the same period.

Experts say one should always keep track of the factors that influence an acquisition and analyse how it will strategically fit a company's broader expansion plans. A case in point is Tech Mahindra's acquisition of the erstwhile Satyam. Being largely telecom- focused software company, Tech Mahindra had to expand into enterprise solution software. Though the acquisition wasn't yielding the desired results initially, the Mahindras were slowly able to integrate operations. Tech Mahindra has since gained 192 per cent since June 2013. Tech Mahindra paid 2,900 crore for the Satyam acquisition.

Analysts say Mahindra & Mahindra has a reputation of deriving the best synergies. The Mahindras acquired Punjab Tractors, Gujarat Tractors and Ssangyong, gradually emerging as the prominent tractor manufacturer in the world. The group is now filling gaps in its automobile portfolio, having acquired Kinetic Motors in the twowheeler segment and Ssangyong in the upper- end sports utility vehicle space.

The price a company pays for the acquisition is crucial. And, the return on investment is among the most crucial aspects of a merger. Says Parikh: " Any merger has to be at the right price. Sometimes, when companies run after acquisitions and acquire it at aggressive pricing, it tends to hurt the company in the long run and shareholder value is lost." Motherson Sumi has been successful in making strategic acquisitions and integrating these. The company has gained substantially, from a string of good acquisitions in the past few years. Revenues surged from 2,801 crore ( consolidated) in FY09 to 25,312 crore in FY13 due to a string of strategic acquisitions. Currently, it is valued at 22,730 crore, against 2,387 crore in March 2009, a rise of 56 per cent per annum compounded, as against the Sensexs 18 per cent.

Last, the sector plays a crucial role. Experts say in the pharmaceuticals and fast- moving consumer goods segments, the price for acquisitions could be higher, as one pays for the brand or technology.

Says Irani: " It always makes sense to buy or merge a company when the economic conditions are not that optimistic and the new management can institute a shift in the company's operations." An M& A might deliver higher growth for a company, especially if it is being pursued with a clear vision and is costcompetitive.

A lot of Indian companies have proven to be quite adept at acquisitions. But in case the price is steep and sector is faring well, acquisitions might see shareholder returns decline.

DID MERGERS PAY OFF?

A fewcompanies stand out in market cap gains due to acquisitions

Acquisition month M- cap then* M- cap now* % CAGR SensexCAGR (%) Hindalco- Novelis May 2007 17,817.49 29,441.33 7.44 7.24 Tata Steel- Corus January 2007 26,930.91 40,480.03 5.99 7.06 Tata Motors- JLR June 2008 16,448.40 1,38,657.30 42.66 9.11 Tech Mahindra- Satyam# June 2013 13,638.03 39,859.66 192.27 17.11 Motherson Sumi- VisioCorp, etc March 2009 2,387.18 22,730.97 56.94 18.53

*in cr, # Tech Mahindra gains are not annualised; Sensex CAGR is for the same period as companies Data compiled by BS research Bureau

Always watch the price paid for an acquisition and the strategic intention of a merger, say experts

 

Consumer forum can order corrective retrospective action


When there is a dispute between a consumer and a financial institution, it becomes difficult to quantify the loss, since interest, delayed payment charges and penalties keep changing.

And, there is a considerable time lag between the date of the dispute and the decision on the complaint. In such a case, the only remedy is to correct the disputed entry and make the consequential changes. This is what the consumer court ordered Standard Chartered Bank to do in a 13- year- old dispute.

Hutokshi Tata had a ' Finance Against Securities in Time' account with the foreign bank. This account entitled Hutokshi to get an overdraft facility against shares and securities deposited with the bank. The overdraft limit is a percentage of the value of the shares deposited and fluctuates according to the stock market.

When Hutokshi got her bank account statement, she noticed an unexplained debit entry of 1.35 lakh, made without her knowledge/ consent and without even any intimation. This debit resulted in her account going into overdraft mode, attracting heavy interest.

Hutokshi made enquiries but the bank was unable to give a proper response. Later, the bank clarified that it was a payment made to a share broker under instructions from its collection manager. As this did not make any sense, Hutokshi's husband took up the issue with the bank. It ultimately turned out that about two years ago, certain shares had been sold under the instructions of Hutokshi. To enable the purchaser to get these shares transferred to his name, the bank was required to send the transfer application with two powers of attorney ( PoA) – one from Hutokshi in favour of the bank, and the other from the bank in favour of its official appointed as the authorised signatory.

When the purchaser tried to get the shares transferred to his name, the transfer was rejected.

To complicate matters, the reason for rejection was not properly communicated by the share transfer agents who made an error in punching the correct data code.

After this mistake was corrected, it was found the shares could not be transferred because the transfer application was not accompanied by the PoA given by Hutokshi in favour of the bank. Though the bank was asked to rectify its mistake, it ignored the letter. Ultimately, purchaser had these shares auctioned by the stock exchange. When the auction took place, the rate was much higher and the bank was asked to pay the auction price of 1.35 lakh. The bank, in turn, surreptitiously debited Hutokshi's account to make this payment. To cover its own lapse, the bank filed Hutokshi's PoA a day after the shares were auctioned.

Hutokshi requested for a reversal of the debit, which had occurred due to the bank's negligence in sending the transfer form along with only one PA and omitting to send the PoA given by Hutokshi to the bank. The bank tried to pass the buck to the share transfer agent for punching the wrong rejection code. Hutokshi's pleas fell on deaf ears, and the bank started capitalising on its own negligence by imposing penalty and interest at 18.9 per cent, compounded on a daily basis. Consequently, the debit balance kept increasing rapidly. To recover its dues, the bank sold all Hutokshi's shares, but claimed dues were still outstanding, and recovered money from her husbands account.

Hutokshi filed a complaint before the district forum. After a 10- year struggle, the forum upheld the complaint and directed the bank to recredit 1.35 lakh and make the consequential corrections to rectify the interest wrongly charged. The forum also awarded a compensation of 10,000 and 2,000 as costs.

The bank appealed to the Maharashtra State Commission. By an order dated March 10, the Commission observed the bank could not take advantage of an error committed by the share transfer agent for punching the wrong rejection code when this mistake had subsequently been corrected. The Commission held the bank was responsible for causing loss by failing to lodge the PoA. The order of the district forum was upheld and the bank's appeal dismissed.

This order will help consumers redress their grievance when a wrong entry results in serious losses over a period of time which one cannot quantify.

The author is a consumer activist

JEHANGIR GAI

A bank cannot take advantage of an error committed by the share transfer agent for punching the wrong rejection code when this mistake had subsequently been corrected

 


One fire doesn't lead to insolvency

A ship carrying phosphorus from Frankfurt to Mumbai caught fire in 1983. The embers of litigation over insurance died down in the Supreme Court last week after 30 years. The ship was abandoned because the cost of its repairs was higher than the insured value. The purchaser of the goods, Metal Powder Co of Madurai, Tamil Nadu, asked Oriental Insurance Co to pay compensation for non- delivery of the consignment. The insurer repudiated its liability as the ship was abandoned by its owners and according to 'Institute Cargo Clauses', loss due to insolvency was excluded. The Madurai firm sued the insurance company and the trial court ordered payment with interest. The insurer moved the Madras High Court, which held that due to insolvency, the firm was not entitled to the amount. On appeal, the Supreme Court set aside the high court verdict. It said that the fact that the owner of the ship abandoned it did not mean that it was insolvent. The insurer cannot say that the ship owner has become insolvent due to the abandonment of the ship, without any court decision on bankruptcy. "Insolvency or bankruptcy is certainly not a matter of individual perception and opinion," the judgment said, and remarked that such an argument was apparently put forward by the insurance company merely to invoke the exclusionary clause.

>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>> Govt is ' owner' of requisitioned vehicle

The Supreme Court held last week that when a motor vehicle requisitioned by the government for public purpose meets with an accident and kills a person, it is not the registered owner, but the government which is liable to compensate the dependants. In this case, Purnya Kala Devi vs State of Assam, the Gauhati High Court ruled that the registered owner, the insurer or driver or any of them was liable to pay. The widow and four children appealed to the Supreme Court. It held that the definition of ' owner' in the Motor Vehicles Act included aperson " in possession of the vehicle either under an agreement of lease, hypothecation or hire purchase". The court emphasised that the intention of the lawmakers was that a person who is in " control or possession" of the vehicle should be deemed to be the owner for purpose of compensation.

>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>> Cheque in advance payment protected

A cheque issued as advance payment for purchase of goods, if it bounces, cannot be cause for filing criminal case under Section 138 of the Negotiable Instruments Act. In this case, Indus Airways Ltd vs Magnum Aviation Ltd, the airways issued post- dated cheques to the other company as advance payment towards orders for spare parts. Later the deal was cancelled and the payment was stopped. The seller company filed a complaint against the airways and a Delhi magistrate issued summons to the purchasers. On appeal, the Delhi High Court ruled against the purchaser ruling that the post- dated cheques were issued against a liability. Quashing the judgment, the Supreme Court stated last week that the cheques were not issued against a liability. " If a cheque is issued as advance payment for purchase of goods and for any reason the order is not carried out either because of its cancellation or otherwise the cheque cannot be said to have been drawn for an existing debt or liability," the judgment clarified.

>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>> Refunding dirty money can't buy immunity

Charges of corruption in a bank fraud case cannot be quashed merely because the amount involved has been returned by the offender to the bank in a private settlement. Even if there was a compromise between the two parties, a charge under the Prevention of Corruption Act is a serious matter and must go on, the Supreme Court stated last week in the case, Gopakumar vs CBI. The accused, along with a branch manager of Indian Overseas Bank, had allegedly committed several frauds on the bank. They were charged under the Act. Gopakumar returned the amounts received from the bank through various shady deals in a settlement. Since he was still not discharged from the case, he moved the Kerala High Court. It dismissed his plea. The Supreme Court also dismissed his appeal. It said that the offences are not private in nature and are serious involving corrupt practices. Moreover, though the bank accepted its lost money, it did not exonerate the accused person from criminal liability.

>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>> Challenge to foreign award rejected

The Supreme Court has dismissed the appeal of Sakuma Exports Ltd against the ruling of the Bombay High Court which had stated that it has no jurisdiction to interfere in an arbitration award in the dispute with Louis Dreyfus Commodities Suisse S. A. The Indian company, which imports and exports sugar, ordered 2700 mt of Brazilian white sugar from the Swiss firm. Disputes arose, which were referred to an arbitration tribunal constituted by the Refined Sugar Association, London. When the award went against the Indian firm, it challenged it in the high court. The court stated that it had no jurisdiction under the Arbitration and Conciliation Act. An appeal was moved in the Supreme Court. It pointed out that the terms of the contract clearly referred to the London association for resolution of disputes. " There is no manner of doubt that the parties have not only accepted English law as the law governing the contract but the disputes and the arbitration shall also be governed by the law of England. The seat of arbitration also will be England," the judgment said.

>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>> Higher duty on opal glassware

The Supreme Court has held that the glassware manufactured by M/ s La Opala R G Ltd, though made of glass, cannot be considered as a ' type of glass' eligible for lower central excise duty under a Jharkhand government notification. The company manufactures glass and glassware made of opal glass in its Madhupur unit. The authorities asked it to pay 4 to 12 per cent tax on its inter- state sales. The company claimed alower duty according to the notification. As it was rejected the company moved the high court and got a favourable order. The state appealed to the Supreme Court. Allowing the appeal, the court after referring to various dictionaries to discover the meaning of glass varieties, upheld the demand of the revenue authorities. Glassware is generally ornamental in nature.

BRIEF CASEN [1] M J ANTONY

A weekly selection of key court orders

 

CSR expenditure not a tax- deductible expense


The revised draft of the Direct Taxes Code 2013 (' DTC 2013') is a welcome step, as it has incorporated amajority of recommendations made by the Standing Committee on Finance (' SCF') on the previous version of DTC.

However, the revised version in certain critical areas is against the general objective and intention behind introduction of DTC. CSR is one such domain where the lawmakers have disappointed the taxpayers.

The newly introduced Companies' Act 2013 provides a broad list of CSR activities, which includes women empowerment, preferment of education and employment, orphanages and old age homes, preservation and protection of wildlife, etc. Every company, which has a net worth of at least 500 crore, or a turnover of at least 1,000 crore or net profit of at least 5 crore is, henceforth, mandatorily required to spend at least two per cent of the average net profits of the company in the immediately three preceding years towards CSR activities.

The Finance Ministry, while introducing the revised draft, has made clear that it is not in support of giving tax allowances to businesses for their social welfare expenditure since it is an application of income and tax deduction, which would imply foregoing one third of government tax revenue.

This is despite the recommendation proposed by the SCF to allow tax deduction for such CSR expenditure.

The current Indian socio- economic scenario demands a significant expenditure on CSR activities by business houses. The absence of tax incentive on the same will only impediment the voluntary spend by businesses, and will also lead to dissatisfaction amongst companies.

NEERU AHUJA Partner, Deloitte Haskins & Sells

CSR

No provision for merger of LLPs
The revised DTC contains inter alia M& A provisions, which are similar to the current tax provisions and has provided further clarity on certain aspects introduced by the old version.

One key provision is the taxation of indirect transfers when shares of foreign entities change hands.

DTC- 2013 has clarified that if the Indian assets/ interest represent 20 per cent of the fair market value of all the assets owned by the foreign entity, the foreign entity would be subject to tax in India.

DTC- 2013 continues to provide tax neutrality to mergers and demerges subject to satisfaction of certain conditions. It has further modified the definition of business reorganisations to facilitate nonresidents.

DTC- 2013, however, does not contain provisions relating to the merger of Limited Liability Partnerships ( LLP). This is likely to gain rapid preference once there is more clarity on tax provisions. General Anti Avoidance Rules contain a broad set of provisions that have the effect of invalidating arrangements under certain circumstances.

This law gives a free hand to the tax department to challenge any restructuring transaction, thereby opening the doors to the possibility of a host of litigation.

DTC provides a window of opportunity to an assessee to seek an advance ruling on whether a transaction is impermissible or not.

Other provisions pertain to taxation of controlled foreign companies, which focus on taxing the undistributed profits of a foreign company situated in a low tax jurisdiction, but controlled by residents.

ZULFIQAR SHIVJI Partner and Head, Transaction Advisory & Support, BDO India

M& A

 


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CS A Rengarajan
9381011200

CS Benevolent Fund is a collective effort towards extending the much needed financial support to the community of Company Secretaries in times of distress  Let us lend support and join for noble cause.



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