India Tax Konnect - May 2014
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India Tax Konnect - May 2014

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KPMG in India Tax Konnect - May 2014 deals with recent tax developments. ...

KPMG in India Tax Konnect - May 2014 deals with recent tax developments.

This report highlights the developments on the tax and regulatory front and its implications on the way you do business in India.

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India Tax Konnect - May 2014 India Tax Konnect - May 2014 Document Transcript

  • MAY 2014 IndiaTax Konnect Editorial In its April policy review, the Reserve Bank of India (RBI) has maintained the existing interest rates. However, it has expressed concern about the impact of a below-average monsoon and the El Nino effect on food output, which in turn could affect inflation in FY14. These factors have already had some effect, as wholesale price index (WPI)-based inflation increased to 5.7 per cent in March, from 4.7 per cent in February. Additionally, consumer price index (CPI)-based inflation also increased from 8 per cent in to 8.3 per cent in the same period, largely as a result of an increase in vegetable, food, fuel and manufacturing prices. These increases in inflation have further weakened the case of industries pitching for reduced interest rates, and so the RBI is not expected to loosen the monetary policy in the near future.1 As reported in the news, India has signed its first batch of Advance Pricing Agreement (APA) with five Multinational Corporations (MNCs) fixing their tax liability in cross- border transactions over the APA term.These agreements cover a range of international transactions, including interest payments, corporate guarantees, non-binding investment advisory services and contract manufacturing.These companies are engaged in different industrial sectors including pharmaceuticals, telecom, exploration and financial services. The Central Board of DirectTaxes has been able to conclude the first set of APAs within one year, against the internationally accepted norm of at least two years.2 As reported in the news, to fasten the process of identifying tax evaders, the Income Tax department has decided to set up a major data centre of classified information on the lines of the existing two such centres on e-filing andTDS information.The new office which has been named Centralised Processing Cell-Compliance Management (CPC- CM) will have its base in the national capital and a dedicated workforce, drawn from the department, will man it.The CPC-CM is an ambitious project of the Central Board of Direct Taxes (CBDT) aimed at enabling the I-T department to use technical data to check cases of non-compliance and non-filers of taxes.The project has been planned under the business intelligence project initiated by the CBDT to enable the taxman move from physical verification of a taxpayer to a smart approach of data-based monitoring and checking.3 On the judicial front, the LucknowTribunal in the case of Ama Medical & Diagnostic Centre observed that the jurisdictional High Court in the case ofVector Shipping had only made a simple passing reference to the decision of the Special Bench in the case of Merilyn Shipping; therefore it could not be said that the ratio laid down by Merilyn Shipping had been approved by the jurisdictional High Court. Further, theTribunal, relying on the decisions of Gujarat High Court in the case of Sikandarkhan N.Tunvar and Calcutta High Court in the case of Crescent Exports, held that the disallowance under Section 40(a)(ia) also applied to amounts paid at any time during the year. We at KPMG in India would like to keep you informed of the developments on the tax and regulatory front and its implications on the way you do business in India.We would be delighted to receive your suggestions on ways to make this publication more relevant. 1 Times of India, 17 April 2014 2 EconomicTimes, dated 1 April 2014 3 BusinessToday, dated 25 April 2014 Contents Corporate tax 2 Transfer pricing 4 Indirect tax 5 Personal tax 7
  • 2 Corporate tax Decisions Disallowance under Section 40(a)(ia) of theAct would also cover amounts paid at any time during the year During the original assessment, the Assessing Officer (AO) had disallowed payment of INR3.314 million as AMC paid toWipro G.E. Medical Services (Wipro) on the grounds of non-deduction of tax under Section 40(a)(ia) of the Act.The matter travelled up to theTribunal, which set aside the issue, remitting the matter to the AO’s file.The AO was directed to decide whether the contract between the taxpayer and Wipro was a work contract or whether it was a service contract because a service/work contract agreement was not furnished before theTribunal.The maintenance service agreement was filed before the AO with the contention that it was a mere service contract to which Section 194C was not attracted.The AO rejected the contentions and disallowed the payment made toWipro under Section 40(a)(ia) of the Act.The Commissioner of Income-tax (Appeal) [CIT(A)], solely relying on the special bench decision in Merilyn Shipping &Transports [2012] 136 ITD 23 (Visakhapatnam) (SB) ruled in the favour of the taxpayer and deleted the addition made by AO. Aggrieved by the order of CIT(A), the revenue filed an appeal before the LucknowTribunal. Before theTribunal, the taxpayer relied on the decision of Allahabad High Court in the case of Vector Shipping Services P. Ltd [2013] 218Taxman 93 (All) and argued that theTribunal was bound to follow the decision of the jurisdictional High Court.TheTribunal observed that the jurisdictional High Court inVector Shipping had only made a simple passing reference to the decision of the Special Bench in the case of Merilyn Shipping, and hence it could not be said that the ratio laid down by Merilyn Shipping had been approved by the jurisdictional High Court. Further, theTribunal, relying on the decision of Gujarat High Court in the case of CIT v. Sikandarkhan N.Tunvar [2013] 357 ITR 312 (Guj) and the decision of Calcutta High Court in the case of CIT v. Crescent Exports [2013] 262 CTR 525, held that the disallowance under Section 40(a)(ia) also applied to amounts paid at any time during the year.TheTribunal also referred to the circular No. 10/DV/2013 dated 16 December 2013. DCIT v. Ama Medical & Diagnostic Centre (ITA No.119/ LKW/2013) Provisions of Section 14A not applicable to ChapterVI-A deductions The taxpayer was a cooperative society engaged in procuring, processing and manufacturing milk and milk products and supplying them. During the assessment proceedings, the AO observed that the taxpayer had claimed deduction under Section 80P(2)(d) of the Income-tax Act, 1961 (the Act) on account of interest receipts amounting to INR22.8 million and dividend receipts amounting to INR8.244 million.The taxpayer had also debited interest expense of INR76.4 million.The AO disallowed the claim for interest expense to the extent of INR1.821 million, under Section 14A of the Act.The CIT(A) allowed the taxpayer’s claim and deleted the addition of INR 1.821 million made by the AO.TheTribunal also affirmed the CIT(A)’s view and dismissed the tax department’s appeal. The High Court observed that deductions provided under ChapterVI-A could not be compared with the exempted income, which did not form part of the total income as provided in Sections 10 to 13A under Chapter III of the Act. The High Court further observed that Section 14A was introduced retrospectively with effect from April 1, 1962 vide Finance Act, 2001 to prevent any expenditure in relation to exempted income from being allowed as a deduction. However, there was a clear absence of any reference to the income on which deduction under ChapterVI-A was provided. Relying on the Delhi High Court’s decision in the case of CIT v. Kribhco [TS-522-HC-2012(DEL)] the High Court held that the provisions of Section 14A would not apply to ChapterVI-A deductions. CIT v. Banaskantha District Co. Op. Milk Producers Union Ltd. (Tax Appeal No. 271 of 2014) (Guj) Second proviso to Section 40(a)(ia), which provides relief to payer when recipient has paid tax, operates prospectively from 1April 2013 and not retrospectively The taxpayer, a functional industrial estate was to create basic infrastructure facility and let them out to sea food exporters.The taxpayer was promoted by the Sea Food Export Association of India, Sea Food Exporters and Marine Products Infrastructure Development Co-operation (P) Ltd (MIDCON), a subsidiary of Marine Product Export Development Authority (MPEDA) to promote sea food processing units.The taxpayer entered into an agreement with the Sea Food Export Association of India on 3 May 2006, whereby the taxpayer had to pay 20 per cent of gross revenue to them as a royalty. During AY 2008-09, the taxpayer had claimed a deduction of INR6.2 million of the royalty paid to the Sea Food Export Association; however, it had not deducted tax at source from the payment. It was claimed that the recipient i.e. Sea Food Export Association of India, had, however, paid tax in respect of the amount received from the taxpayer, and therefore the amount could not be disallowed under Section 40(a)(ia) of the Act. Referring to second proviso to Section 40(a)(ia), it was submitted that when the taxpayer was not deemed to be an ‘assessee in default’ under proviso to Section 201(1), it should be deemed that the taxpayer had deducted and paid the tax on the sum on the date of furnishing of return of income by
  • 3 the recipient of the amount. Further, the taxpayer argued that, though the provision came into effect from 1 April 2013, it would operate retrospectively; therefore, the proviso would be applicable for the subject AY 2008-09 as well. The CochinTribunal observed that the Kerala High Court, in the case of Prudential Logistics AndTransports v. ITO (ITA No.1 of 2014 dated 13 January 2014), while examining the provisions in second proviso to Section 40(a)(ia) of the Act has held that the benefits conferred by proviso to Section 40(a)(ia) was not available for AY 2007-08. Relying on the above mentioned High Court decision, theTribunal held that the second proviso to Section 40(a)(ia), which provides relief to the payer when the recipient has paid tax operates prospectively from 1 April 2013 and not retrospectively, and hence it cannot be made applicable to AY 2008-2009. Sea Food Park India Limited v. DCIT (ITA No. 762/Coch/2013) Section 80HHC deduction claim cannot be made ignoring deduction already claimed and allowed under Section 80IA in view of Section 80IA(9) of theAct The taxpayer filed its return of income for AY 2001-02 claiming deduction of INR1.654 million under Section 80IA and of INR5.275 million under Section 80HHC of the Act, thereby declaring total income nil.The AO held that by introduction of sub-section (9) to Section 80IA, double deductions had been barred by statute. According to him, the amount of deduction claimed and allowed under Section 80IA had to be reduced from profit of industrial undertaking for the purpose deduction under Section 80HHC in the present case. Accordingly, the AO ordered for re-computation of Section 80HHC deduction. The CIT(A) confirmed the Order of the AO.TheTribunal, relying on the decision of the BangaloreTribunal in the case of Irfan Sheriff v. CIT [2006] 7 SOT 57 (Bang), ruled in favour of the taxpayer. The Gujarat High Court noted that Section 80IA(9) could be divided into two clear parts.The first part pertained to non-allowability of deductions under any other provision contained in Part-C of ChapterVI, to the extent of profits and gains of an enterprise or undertaking with respect to which deduction under section 80IA was claimed and allowed, and the second part provided that, in any case, such deduction should not exceed the profits and gains of eligible business of an undertaking or enterprise. After referring to the provisions of Section 80IA(9), the High Court held that a deduction under Section 80HHC could not be made ignoring deduction already claimed and allowed under Section 80IA. Restricting its application only to limiting maximum permissible deduction under Section 80HHC to profits and gains of eligible business would render sub-section (9) of Section 80IA redundant, purposeless and otiose. It further held that merely because Section 80IA(9) does not contain non-obstante clause does not mean that it can have no effect on Section 80HHC deduction. It also held that the CBDT Circular No. 772 does not restrict the scope of Section 80IA(9), it only prevents claims of double deductions.Thus, the High Court upheld the view already taken by the Delhi High Court in the case of Great Eastern Exports v. CIT [2011] 332 ITR 14 (Del), Kerala High Court in the case of Olam Exports (India) Ltd. v. CIT [2011] 332 ITR 40 (Ker) and Punjab and Haryana High Court in the case of Broadway Overseas Ltd. v. CIT [2014] 41 taxmann. com 75 (P&H) and rejected the contrary decision of the Bombay High Court in the case of Associated Capsules P. Ltd. v. DCIT [2011] 332 ITR 42 (Bom) and Karnataka High Court in the case of CIT v. Millipore India P. Ltd. [2012] 341 ITR 219 (Kar). CIT v. Atul Intermediates (Tax Appeal No. 508 of 2007) CBDT lays down Standard Operating Procedure for verification / correction of tax-demand The CBDT has issued instructions to AOs laying down Standard Operating Procedure (SOP) for verification and correction of tax demands. By virtue of this SOP, taxpayers can get their outstanding tax demand reduced/deleted by applying for rectification along with documentary evidence of tax-demand already paid. In the case of individuals/HUFs, the SOP makes special provision for dealing with tax demands up to INR1 lakh.The taxpayers committing mistakes while furnishing tax credit claims in return of income, may file rectification request correcting their claims. Press note No.402/92/200
  • 4 Transfer pricing Decisions India signs its first set ofAPA in one year since introduction of theAPA programme The APA program was introduced in India by the Finance Act, 2012 as a method of proactive dispute resolution and took off operationally on 1 July 2012. Although the introduction of APA was perceived as a positive step taken by the Government of India as a measure to curb the unprecedented litigation which had greatly affected investor sentiment, many taxpayers were apprehensive of the practical challenges associated therewith. Amidst the prevailing uncertainty, Indian taxpayers filed over 140 APA applications in 2013 with KPMG in India handling over 40 of these applications. India has signed its first batch of APAs with five Multinational Corporations (MNCs) fixing their tax liability in cross-border transactions over the APA term. Per press reports, these agreements cover a range of international transactions, including interest payments, corporate guarantees, non-binding investment advisory services and contract manufacturing.These companies are engaged in different industrial sectors including pharmaceuticals, telecom, exploration and financial services.The Central Board of Direct Taxes has been able to conclude the first set of APAs within one year, against the internationally accepted norm of at least two years. The APA program is an important step towards providing certainty to taxpayers. Generally, an APA is valid upto 5 years and the Income-tax Act, provides for renewal, revision or cancellation of an APA under certain circumstances. During the five year period, the taxpayer is required to file an annual report to confirm compliance with the terms of the APA.The tax authorities shall accordingly conduct a limited audit of the taxpayer to ensure compliance with the terms of the APA. The Indian APA program has been introduced and designed to bring in positive changes in the Indian transfer pricing litigation system which was being perceived internationally as highly aggressive.The highlight of the APA regime is the ethical and fair approach of the Indian APA authority. Since APA has the potential to reduce transfer pricing litigation and aid international transactions, the investor confidence would be regained and the Indian economy would be benefitted. EconomicTimes, Newspaper publication, dated 1 April 2014
  • 5 Indirect tax Service tax - decisions Eligibility of declaration made under theVoluntary Compliance Encouragement Scheme where subject matter for past period is pending adjudication In the instant case, the issue was whether the declaration made by the taxpayer under theVoluntary Compliance Encouragement Scheme (the Scheme) for a particular period (subject period) can be rejected on the grounds that subject matter of declaration, for the period prior to the subject period, is pending before theTribunal. The Delhi High Court held that in terms of the Scheme, the subject matter of declaration should not be pending adjudication for the period for which the declaration is made under the Scheme. Any pendency in relation to the subject matter pertaining to the period prior to the subject period cannot be grounds for rejecting the declaration made by the taxpayer. Frankfinn Aviation Services Pvt Ltd v. Assistant Commissioner, Designated Authority,VCES, ServiceTax [2014-VIL-89-DEL-ST] Service tax applicability on activities facilitating sale of pre-owned/ used cars belonging to the clients In the instant case, the issue was whether the activity of selling pre-owned/ used cars belonging to the clients of the taxpayer would be liable to Service tax under the category of ‘Business Auxiliary Service’ and accordingly, the difference between the sale price and purchase price of old cars has to be treated as remuneration for providing the service.The period of dispute was 1 October 2006 to 30 September 2011. The revenue contended that since the registration of car remains in the name of the person who has handed over the old car (i.e. the owner/ seller) to the appellant, sale takes place only between the owner and buyer of the old car, and that the appellant is only acting as an intermediary. TheTribunal observed that: • In view of the Kerala High Court judgment in the case of Premsankar K GV Sunil Krishnan [2014-4-KHC-895], for considering a transaction to be a sale transaction or not, what is required to be seen is not the aspect of registration but whether the price has been received and property has been delivered or not. • In the instant case, the taxpayer had purchased the old car from the seller/owner of the old car by getting the delivery and paying the required price, and the taxpayer subsequently sold the old car.This amounts to transaction of purchase and sale of old vehicles. • Refurbishing of vehicle, repair and other activities undertaken was a value addition by the taxpayer to get maximum return and was undertaken neither for the seller nor the buyer.Therefore, no service element was involved in this transaction and hence, not liable to Service tax. Sai Service Station Ltd v. CCE & ST (TS-101-Tribunal-2014-ST) Leviability of Service tax on services received byAirline Company from foreign based CRS companies In the instant case, the issue was whether services received by the taxpayer from foreign based Computer Reservation System (CRS) companies would be liable to Service tax under the category of ‘Online information and database access or retrieval services’ under reverse charge mechanism. The foreign based CRS companies facilitated sale of flight seats of taxpayer through an online computer system.The CRS software accesses the taxpayer’s database and displays information of flight details, availability of seats, etc. on real time basis to the taxpayer and to the travel agents.The payments were made to CRS companies by the taxpayer. The MumbaiTribunal made the following observations: • The taxpayer is not only transmitting data to the CRS companies but is also retrieving/ accessing the data with regard to booking/ cancellation of air tickets and passenger details. It is by accessing the data from the computer system of CRS companies, the taxpayer is able to generate Passenger Name Record (PNR) and Passenger Manifest.Therefore, such services are classifiable under the category of ‘Online information and database access or retrieval services’. • The travel agents are the agents of the taxpayer and to enable them to access the taxpayer data, the taxpayer has entered into agreement with the CRS companies. Therefore, the CRS companies provide access to the data to the travel agents on behalf of the taxpayer. • The beneficiary of the information may be the travel agent but the service is rendered to the taxpayer by the CRS companies.Therefore, the taxpayer are the recipient of services though the beneficiary may be the travel agent. • The service provider (viz. CRS companies) and their own group entities in India are distinct and different legal entities in terms of the provisions of Service tax law.The group entities in India are not a branch office or agency of the foreign service provider. Therefore, the group entities of CRS companies in India cannot be made liable to pay Service tax on services provided by the CRS companies to the taxpayer. Accordingly, it was held that the taxpayer, being the service recipient in India, is liable to pay Service tax under reverse charge mechanism on services received from the CRS companies. Jet Airways (I) Ltd v. CST (2014-TIOL-473-CESTAT MUM)
  • 6 Central Excise - Decisions Credit can be availed on the basis of an endorsed Bill of Entry In the instant case, the import documents of the consignment were filled in the name of Unit 1 of the taxpayer. However, the consignment was meant for their Unit 2.The Unit 1 has accordingly endorsed the bill of entry (BOE) and the consignment was received directly at Unit 2 after imports. On the basis of the endorsed BOE, Unit 2 claimed the CENVAT Credit. However, the Central Excise authorities had denied the credit on the grounds that credit cannot be availed on the basis of an endorsed BOE, as the same is not a valid document. The MumbaiTribunal held that since there is no dispute on the payment of CVD and the receipt of goods at Unit 2, credit can be availed at Unit 2 on the basis of an endorsed BOE. Advanced EnzymeTechnologies Limited v. CCE [2014-TIOL- 438-CESTAT-MUM] Entire credit may be transferred in case of shifting of factory premises, irrespective of whether such credit is represented by the transfer of goods In the instant case, the entire operations of Unit 1 of the taxpayer had been transferred to their Unit 2. The taxpayer had reversed the CENVAT credit at Unit 1 to the extent it relates to inputs which were transferred to Unit 2 and claimed the same as CENVAT credit at Unit 2. The taxpayer still had outstanding credit lying in their account and subsequently transferred the same to Unit 2 when they surrendered the Central Excise registration of Unit 1. The Central Excise authorities denied the transferred credit availed at Unit 2 on the grounds that the taxpayer can avail credit only if the inputs and capital goods are also transferred when the factory is transferred from one place to another and in as much as in the present case at the time of transfer of balance credit there were no inputs/capital goods available, the transfer the credit is not proper. The MumbaiTribunal held that Rule 10 of the CENVAT Credit Rules, 2004 nowhere stipulates that the credit that can be transferred should be attributable to the inputs or capital goods that are transferred. Accordingly, even if excess credit is available in the books of accounts the same can be transferred. Kirloskar Oil Engines Limited v. CCE (2014-TIOL-489-CESTAT- MUM) VAT Notifications/Circulars/Press Releases Karnataka With effect from 28 February 2014, the following key amendments have been made in the KarnatakaValue Added Tax (Amendment) Act, 2014: • The threshold limit for obtaining registration and for cancellation of registration has been increased from INR5,00,000 to INR7,50,000; • Works Contractors are not required to be mandatorily registered; • The tax rate of liquor including beer, fenny, liqueur and wine has been increased from nil to 5.5 per cent. Maharashtra With effect from 1 April 2014, Annexures J1 (dealer-wise information of Sales) and J2 (dealer-wise information of Purchases) are required to be filed along with the periodic returns. Trade Circular No. 9T of 2014 Dated 25th March, 2014 Chhattisgarh The period of completion of assessment for the calendar year 2012, which is not completed by 31 March 2014, has been extended up to 30 June 2014. Notification No. F-10/56/2014/CT/V (55) Dated 1st April, 2014 Tamil Nadu With effect from 1 April 2014, every registered dealer whose taxable turnover in the preceding year exceeds INR20 million is required to pay tax electronically. Notification No. G.O.Ms No. 30 Dated 25th March 2014 Decisions In absence of bifurcation of cost price and tax on invoice, whether deduction of tax not available In the instant case, the issue was whether benefit of deduction of tax from the total value of the bills was available, when separate bifurcation towards cost price of goods and the tax payable thereon, have not been specified in the bill. At the time of verification of the books of accounts of the taxpayer by the authorities, it was found that during the period from April 2007 to March 2008, the taxpayer did not mention VAT separately in the tax invoice and accordingly, tax demand was raised on the entire sales turnover. The taxpayer argued that he had complied with the prescribed requirements by affixing a stamp on the invoices that selling price includesVAT at 12.5 per cent.The taxpayer further argued that he has separately mentioned the cost price of goods sold and the tax component in its books of accounts. The Karnataka High Court observed that the value of goods, the rate of tax on the said goods and the amount of tax was not mentioned on the invoice but the taxpayer had merely affixed a stamp at the bottom stating that the tax was collected at 12.5 per cent.Thus, it was held that mere mention of value of goods and tax amount in a separate column, in the books of account cannot be given due weightage. Accordingly, the order of the Revisional authority was upheld and appeal was dismissed. Mahadevi Stores v. Additional Commissioner of Commercial Taxes (TS-48-HC-2014(KAR)-VAT)
  • 7 Personal tax Employees’ Provident Fund Organisation issues new circulars to secure proper compliance in respect of InternationalWorkers Recently, the Employees’ Provident Fund Organisation (EPFO) has issued two circulars for securing proper compliance in respect of InternationalWorkers. The two circulars issued by EPFO pertain to: • Reconciliation of InternationalWorkers data with the office of Foreigners Regional Registration Office (FRRO) • Introduction of a revised application form for obtaining a ‘Certificate of Coverage’ (COC) under Social Security Agreements (SSA) with various countries. These circulars are a continuation of EPFO’s effort to tighten its enforcement machinery and to identify the Indian employees who qualify as IWs and to monitor non-compliance in respect of expatriate employees under the EPF Act. The changes in the COC application form will help the Provident Fund authorities in identifying Indian employees who will be considered as IWs. Since the employers have to identify whether an outbound employee will be considered an Indian worker or an International worker, therefore companies will need to exercise greater vigilance on their international assignments to ensure IWs meet the necessary compliances under the EPF Act. www.epfindia.com
  • Contact us: GirishVanvari Co-Head ofTax T: +91 (22) 3090 1910 E: gvanvari@kpmg.com Hiten Kotak Co-Head ofTax T: +91 (22) 3090 2702 E: hiten@kpmg.com Punit Shah Co-Head ofTax T: +91 (22) 3090 2681 E: punitshah@kpmg.com The information contained herein is of a general nature and is not intended to address the circumstances of any particular individual or entity. Although we endeavour to provide accurate and timely information, there can be no guarantee that such information is accurate as of the date it is received or that it will continue to be accurate in the future. No one should act on such information without appropriate professional advice after a thorough examination of the particular situation. © 2014 KPMG, an Indian Registered Partnership and a member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (“KPMG International”), a Swiss entity. All rights reserved. The KPMG name, logo and “cutting through complexity“ are registered trademarks or trademarks of KPMG International. Printed in India Ahmedabad Commerce House V 9th Floor, 902 & 903, Near Vodafone House, Corporate Road, Prahlad Nagar Ahmedabad - 380 051. Tel: +91 79 4040 2200 Fax: +91 79 4040 2244 Bangalore Maruthi Info-Tech Centre 11-12/1, Inner Ring Road Koramangala, Bangalore 560 071 Tel: +91 80 3980 6000 Fax: +91 80 3980 6999 Chandigarh SCO 22-23 (Ist Floor) Sector 8C, Madhya Marg Chandigarh 160 009 Tel: +91 172 393 5777/781 Fax: +91 172 393 5780 Chennai No.10, Mahatma Gandhi Road Nungambakkam Chennai 600 034 Tel: +91 44 3914 5000 Fax: +91 44 3914 5999 Delhi Building No.10, 8th Floor DLF Cyber City, Phase II Gurgaon, Haryana 122 002 Tel: +91 124 307 4000 Fax: +91 124 254 9101 Hyderabad 8-2-618/2 Reliance Humsafar, 4th Floor, Road No.11, Banjara Hills Hyderabad 500 034 Tel: +91 40 3046 5000 Fax: +91 40 3046 5299 Kochi 4/F, Palal Towers M. G. Road, Ravipuram, Kochi 682 016 Tel: +91 484 302 7000 Fax: +91 484 302 7001 Kolkata Unit No. 603 – 604, 6th Floor, Tower – 1, Godrej Waterside, Sector - V, Salt Lake, Kolkata - 700 091 Tel: +91 33 4403 4000 Fax: +91 33 4403 4199 Mumbai Lodha Excelus, Apollo Mills N. M. Joshi Marg Mahalaxmi, Mumbai 400 011 Tel: +91 22 3989 6000 Fax: +91 22 3983 6000 Pune 703, Godrej Castlemaine Bund Garden Pune 411 001 Tel: +91 20 3058 5764/65 Fax: +91 20 3058 5775 KPMG in India www.kpmg.com/in Latest insights and updates are now available on the KPMG India app. Scan the QR code below to download the app on your smart device. Google Play | App Store