MCA

TAX

BULLETIN

Manohar
Chowdhry &

Associates

NOVEMBER 2014
Chartered
Accountants

No.27, Subramaniam
Street,
Abiramapuram,
Chennai - 600018.

Phone: 044 4290 3300

Web: www.mca.co.in

Foreword
It is said that while the west is a litigious society, India is a Lawmakers
society. The numerous and complex Income -tax Law in our country
coupled with too many amendments makes Income -tax Act as one of the
challenging Laws of our Country. The global giants, Vodafones and
Nokias have been grounded in this country with mind boggling
interpretations from the Tax department. It is quite an arduous task to
keep track of all the changes that the Income Tax act is witnessing day by
day. Needless to mention that as a practitioner, we need to be abreast of
all the developments that are taking place.
Realizing the importance of the subject, our Tax team at the Head Office
has conceived the idea of bringing out an exclusive periodical Tax
Bulletin to cater to the needs of the Partners, Managers, Students and
other Staff. The Tax team has made an attempt in this Bulletin by
covering important areas, namely, case law updates, live cases handled
in the form of case studies, important updates from CBDT etc., in a
reader friendly manner. The result of this work is a beautiful Rainbow.
I am sure each of us would benefit from this compilation for our day to
day work.
We appreciate and thank the HO-Tax team for their remarkable efforts.
CA Jharna Director Taxation is leading by example with qualitative
support from team managers CA Sandhyaarti, CA Dimple, CA Sinduja
and CA Ashish. Despite hectic professional commitments, all the
Managers have devoted their time and efforts in bringing out this
bulletin. We wish you all the best and take the sharing consistently to
the next level.
G R Hari
Chief Executive Partner
Manohar Chowdhry & Associates

INDEX FOR CONTENTS

S.No.

Contents

Pg. No.

1.

Article on Section 115QA

46

2.

New arenas on taxationForeign tax credit

717

3.

Spotlight Circular & Notifications

18

4.

Legal Update Landmark Judgments

1920

5.

Case Study on Section 54 & 254 (2)

2124

6.

Current Affairs

2526

Analysis of Section 115 Q A

Introduction:

Section 115QA:
Notwithstanding anything contained in any other provision of this Act, in
addition to the income-tax chargeable in respect of the total income of a domestic
company for any assessment year, any amount of distributed income by the
company on buy-back of shares (not being shares listed on a recognized stock
exchange) from a shareholder shall be charged to tax and such company shall be
liable to pay additional income-tax at the rate of twenty per cent on the distributed
income .

Intent of the Section:

On distribution of dividend by a company, the company is liable to pay

Dividend Distribution Tax @ 15% u/s 115-O and the same is exempt in the
hands of Shareholders u/s 10 (34).

In order to avoid DDT @ 15%, Unlisted Companies (mainly foreign subsidiaries

through the DTAA entered with India) started the practice of distributing
dividends indirectly through BUYBACK of shares.

The gains arising from the sale of such shares was not taxable in the hands of
shareholders also as per Section 10(38).

Hence , both shareholders and company did not pay tax on such buy back.

To curb this practice, Finance Act, 2013 inserted Chapter XII-DA.

This Section is applicable only when unlisted shares of a domestic company are
bought back.

Scope and Tax Implication

Section 115 QA overrides all the sections of the Act and charges tax over and
above the tax on total income of the unlisted domestic companies.
The main purpose behind the introduction of the section was to curtail the
practice of tax avoidance by FOREIGN SUBSIDIARIES. But, when the section
was inserted, the applicability was restricted to unlisted DOMESTIC companies.

This section imposes tax @ 20% on Distributed Income in the hands of the
company.

Distributed Income = Consideration paid on buyback Amount received on

issue of shares

6
Computation of Distributed Income is based on Amount Received on
Issue of Shares and not based on Consideration Received. Hence, if the
shares were issued for consideration other than cash, then this section will
not come into play. This gives rise to a question, if the shares issued for
consideration other than cash, are bought back, what will be the tax
implication.
Further in order to avoid double taxation of the same transaction, section 10(34A)
was introduced which states that Any income arising to an Assessee, being a shareholder, on account of buy back of shares (not being listed on a recognized stock exchange) by the company as referred to in section 115 QA.

Example:
Issue Price to Mr. X Rs.10/Premium on issue- Rs.20/Therefore, Amount received by the company on issue Rs. 30/Mr. X transfers the shares to Mr. B @ Rs.20/The Company buys back the shares from Mr. B @ Rs.40/- Here,

Distribute Income = Rs. 40 Rs.30 = Rs. 10.

But, the gain of Mr. B is Rs. 20/- which is more than distributed income (Rs.10/-).
Now, only distributed income will be exempt u/s 10( 34A) and the extra gain of Rs.10/
will be taxable in the hands of shareholders.

Implication on Section 46A:

Before the introduction of section 115 Q A, taxability of gain on buyback was dealt
with by section 46A.
On introduction of section 115 Q A, the applicability of section 46A is confined to
LISTED DOMESTIC COMPANIES.

Conclusion:
Section 115 Q A is rightly introduced to keep a check on the tax avoidance by the
foreign companies and it is essential that foreign companies making use of resources
of our country must contribute to the government's resources. However, provisions of
section 115 Q A operates beyond the trouble sought to be remedied and effect of it is
felt exterior to its intendment; Legislature could have made suitable changes in the
existing section 2 (22) to provide the solution for the above problem.

Foreign Tax Credit

Double Taxation arises when the same income of a person is taxed by two
different countries which is commonly referred to as Juridical double taxation or
when two different persons are taxed in respect of the same income which is
commonly referred to as Economic double taxation.
In order to avoid such double taxation and provide relief, OECD and US Model
Conventions proposed the following methods:
> A treaty exists between both the countries (Section 90 of Income Tax Act, 1961Bilateral Relief)

Exemption Method; (or)

Credit Method

as mentioned in the Double Taxation Avoidance Agreement( DTAA).

> No such treaty exists between the countries (Section 91(1) of Income Tax Act,
1961- Unilateral Relief)
1. Exemption Method

Under the exemption method, Country Resident (R) does not tax on
the income, which according to the convention may be taxed in Country
Source (S). Country R gives away the right to tax the income in favour of
Country S. The main feature of the principle of exemption is that the
Country R gives away its right to tax the income in favour of Country S.

Variants of exemption method:

The principles of exemption may be applied by two methods as under :

Full exemption: The income which may be taxed in Country S is not

taken into account at all by Country R for the purpose of computing the
tax liability.

Exemption with progression: The income which may be taxed in

Country S is not taxed by Country R, but Country R retains the right
to take such foreign income into consideration for the purpose of
determining the tax to be imposed on the rest of the income.

2. Credit Method:
Foreign Tax Credit:

Foreign Tax Credit is a non-refundable tax credit for income taxes paid
to a foreign government as a result of foreign income tax withholdings.
The foreign tax credit is available to a resident who either worked in a
foreign country or has investment income from a foreign source.
This credit is available only for juridical double taxation.

Under the principle of credit, Country R would determine the

residents worldwide income (including the foreign sourced income)
and compute the tax liability thereon. From the tax
liability computed above, Country R would grant a deduction in
respect of foreign tax paid on the foreign sourced income.

The main feature of the credit method is that country R retains the
right to tax the foreign income but it allows credit for the taxes paid in
Country S. The amount of credit in such a scenario would again be
limited to the lesser of tax paid in the Country S and tax payable on
such income in Country R.

9
While computing Foreign Tax Credit, the following points should be taken care of:

In case the resident receives income from more than one foreign country,
the credit has to be computed only country-wise. (Based on the
pronouncement of The Honble Mumbai High Court in the case of CIT
vs. Bombay Burmah Trading Corp. Ltd.(2003) 259 ITR 423)

If the assessee has claimed Chapter VI A deductions on the doubly taxed

income or such foreign income was exempt from tax in India, then credit
can be availed only on proportionate basis and not on the gross income
received.( Based on the judgement of High Court of Andhra Pradesh, in
the case of Commissioner of Income-tax vs. M. A. Mois (210 ITR 284),
the case highlighted the fact that, mere receipt of foreign income will not
be the base for claiming Foreign Tax Credit. In order to claim credit,
such income should be subjected to tax in India).

Other Important Variants of Credit Method:

UTC refers to the credit that may be given, in Country R, for the tax paid on
the underlying profits out of which the dividend is paid by a company in Country
S. In other words, where a Company resident in India declares dividend and a
foreign company receiving dividend either directly or indirectly holds 10/25
percent of the voting power or issued capital of the Indian Company, then in such
situation the foreign company receiving dividend gets credit for tax paid on such
profits out of which dividend is declared. Application of concept of UTC can arise
only if there is a specific provision to that effect in the tax treaty. Few DTAAs with
India contain UTC provisions, viz, DTAAs executed with China, Australia,
Ireland, Japan, Malaysia, Mauritius, Singapore, Spain, UK, United Mexican
States, USA.

10
Particulars
Total income earned by X Inc

Underlying tax
credit available
1,00,000

Corporate Tax payable on income (1,00,000 x 20%)

20,000

Amount distributed as dividend

80,000

Withholding tax on dividend @ 10%

Income for the parent company

8,000
1,00,000

Tax on the same @ 34%

34,000

Underlying tax credit [A]

20,000

Credit for withholding tax on dividend [B]

8,000

Total credit available [A + B]

28,000

Balance Tax payable in India

6,000

Issues :
The tax treaties entered into by India do not prescribe specific guidelines on the approach to be adopted while computing the tax credit.
A few practical issues that taxpayers have to grapple with are discussed below:

11
Interpretation of expression in accordance with the provisions
of the convention
Taxation by Country S is not in accordance with the conventions if Country
S and Country R have differing interpretation of facts or the provisions of the
convention/agreement. Thus, if, as per the convention, an income is taxable only in
country R and not in Country S, Country R is not required to allow a credit for
taxes paid in Country S.

Further, it is inferred that an item of income over which Country S has the
right to tax is regarded as taxed in accordance with the convention even if
country S grants exemption under its domestic Law.

Interpretation of the expression may be taxed

View that whether the term may be taxed has been used in DTAA, the
resident state alongwith the source state has a right to tax the income for the
following reasons:

OECD & Indian Tax Authorities have clarified by way of notification

no. 91/2008 that wherever the expression may be taxed has been used
in the DTAA, such income shall be included in the total income
chargeable to tax in India in accordance with the provisions of the act
and relief shall be granted in accordance with the method for elimination
or avoidance of double taxation provided in DTAA.

12

Would avoid litigation with tax authorities

Tax payers would also not lose anything as they will get credit of taxes, if
any paid in Country S.

> In cases where tax has been withheld in country S on gross basis,
whether ordinary tax credit should be claimed on net income basis/gross
basis
Paragraph 63 of the commentary of the OECD Model convention on
Article 23 states that the maximum deduction is normally computed
as the tax on net income, i.e., on the income from country S less allowable deductions (specified or proportional) connected with such income.

> Inclusion of Surcharge in computing FTC

The Bangalore Tribunal in the case of Infosys Technologies Ltd held
that while computing the Indian tax in doubly taxed income, tax
should include surcharge and a credit in India for Foreign tax was
available only after first computing the Indian tax including
surcharge.

13
> Availability of tax credit for DDT paid u/s 115-O of the

Act
DDT is neither a withholding tax on dividend income nor a tax on the
profits of the company from which dividend is declared. DTAA provides that tax credits is available on income tax or UTC. Therefore, tax
credits can be availed if country R considers DDT as income tax or
UTC. Further Indian tax law considers DDT as additional income tax
and should be considered for tax credit.

> Exchange rate for the purpose of FTC

The treatise by Klaus Vogel on Double Taxations Conventions

suggests that the foreign taxes (as expressed in the foreign currency)
have to be converted into the local currency by applying the exchange
rate as prevailing on the date on which such foreign taxes are paid.
There could be several situations that may arise in Indian context.

Therefore, a conflict may be that the exchange rate prevailing on the

date on which the Indian resident derives income should be taken or the
rate as used for offering the income to tax should be taken.

> Tax credit available if the tax paid in foreign country

According to Klaus Vogel on Double Taxation Convention credit is

available for only that amount which was actually paid as tax after the
reductions allowed by DTAA & Laws of Country S. In certain cases, if
any tax collected is returned to tax payer in the form of subsidy, then
credit is restricted to the tax remaining after the deduction of such
subsidy (Brazilian Law). to the tax remaining after the deduction of
such
subsidy. (Brazilian Law)

14
> Further, credit is available for any taxes paid as a requirement of

assessment, at source.

Advance tax can be computed after claiming credit (Ref: Hyderabad

Tribunal P I Industries)

> Impact of Loss in Country R in computing the extent of FTC

In situations when the tax payers income is reduced or incurs loss after
offsetting Country S income against Country R loss, then no FTC on
NIL tax liability or FTC is restricted to the extent of the tax liability in
the Country R on such doubly taxed income, available after
offsetting of losses. (Ref: Mumbai Tribunal JCIT v. Digital
Equipment India Ltd)

> Timing Mismatch

From OECD Commentary on Article 23 & Mumbai Tribunal in JCIT

v. Petroleum India International (supra) it follows that relief must be
provided by Country R regardless of when the tax is levied and paid by
country S.

> Residential status on tie breaker rule and availability of FTC

Where a person is a resident of two countries as per the local laws of

each country, for eg: India USA treaty, that applying the tie breaker
rule in tax treaty between the two countries person becomes resident of
one country, then country R will provide FTC for the taxes paid in
Country S and Country S will not allow credit although tax is paid
even in Country S.

15
>

Credit on taxes paid abroad is available even when MAT provisions are
applicable.

>

There are other issues relating to documentation, investment linked

incentives, apportionment of expenses between Indian and overseas
operation, computation of UTC and tax sparing benefit.

Tax Sparing:
The concept of tax sparing credit means if income earned in Country S is
exempted under the domestic laws (say, section 10 of the Act), the actual tax
payment in Country S may be Nil and yet, the tax payer would get credit of
an amount of tax which would have been paid in Country S had there been
no such exemption in the domestic tax laws.
Tax sparing can be illustrated by a simple example. E.g. the income tax
treaty between Canada and India provides for a tax rate of up to 15 percent
on interest. India exempts tax on interest payable by Government on moneys
borrowed by it from sources outside India under section 10(15)(iv) of the Act.
The tax treaty between Canada and India provides that where a Canadian
resident receives interest from a resident of India, Canada shall grant a
foreign tax credit equal to the amount of tax payable in India by the
Canadian resident. Further, the treaty provides that the term tax payable in
India shall, with respect to a company which is a resident of Canada, be
deemed to include any amount which would have been payable as Indian tax
but for a deduction allowed in computing the taxable income or an exemption
or reduction of tax granted for that year under section 10(15)(iv) (the
tax-sparing provision).

16
Particulars

Canada
(Source Country)

India (Resident Country)

Interest Income
2,00,000
Tax Rate

Particulars
Tax Payable in Canada

Less: Foreign Tax Credit

2,00,000

15% but exemption under

40%
section 10(15)(iv)

No Tax Sparing
Credit

Tax Sparing Credit

80,000

80,000

(30,000)

80,000

50,000

(15% of 2,00,000)
Canadian Tax Payable

17
Checklist for claiming FTC:

Identify doubly taxed income and ensure that the same income is being taxed
by two jurisdictions;

Identify the jurisdictions which have taxed the income;

Determine the tax residency of the taxpayer in order to decide the residence
state and source state;

Evaluate whether FTC is to be determined as per section 90 or 91 of the Act.

In other words, whether there is tax treaty entered into between the two
jurisdictions;

Identify the principle and method prescribed in the tax treaty for granting
FTC;

Check for rules / jurisprudence / guidance from the Indian tax authorities for
claiming FTC;

Evaluate the Impact of UTC or tax sparing mechanisms;

Consider impact of losses incurred in home jurisdictions or foreign

jurisdictions;

Compute tax liability on doubly taxed income under the Act by including
surcharge in the tax rate;

Compute FTC for each jurisdiction separately;

Depending upon the applicable tax treaty, FTC should be computed on paid
or payable basis;

Maintain appropriate documentation like withholding certificate from the

payer, document evidencing payment of tax in Country S, etc.

Circulars and Notifications

18

Circular no. 14/2014 dated 08/10/2014 Clarification regarding

allowbility of deduction U/s 10A and 10AA on transfer of Technical
man-power in the case of software industry.

Circular no. 15/2014 dated 17/10/2014 - Approval of Long Term Bonds

and rate of Interest for the purpose of Section 194LC.

Notification no. 37/38 & 2014 dated 27/08/2014 Agricultural

extension project - RKK TRAITSRCACS notified u/s 35CCC

Notification no. 39/41 & 2014 dated

29/08/2014- Agricultural
extension project - RKK 4S CAMPAIGN RKK MORE PULSE
PORJECT notified u/s 35CCC. (RALLIS KISAN KUTUMBA RKK)

Notification no. 43/2014 dated 16/09/2014 Substitution of words

Installed on or after 1st day of April 2014 relating to Tangible assets in
New Appendix I in part A under Machinery and Plant.

Notification no. 45/2014 dated 23/09/2014 Notified the tolerable

limit for determination of Arms length price for transfer pricing
U/s 92C.

Notification no. 46/2014 dated 24/09/2014 Substitution or alteration

in rule 28AA in sub rule (4) and sub rule (5) for No deduction/collection
of Tax or deduction/ collection at a lower rate.

Notification no. 49/2014 dated 17/10/2014- Appointing New

Additional commissioner of Income Tax and Joint commissioner of
Income Tax in New Delhi.

19

Landmark Judgments
PriceWaterhouse Coopers Pvt. Ltd vs. CIT [2012]
348 ITR 306(SC):
Imposition of penalty would be unwarranted in a case where the
Assessee had committed an inadvertent and bona fide error and had not
intended to or attempted to either conceal its B income or furnish
inaccurate particulars.
ACIT v. M/S A.R. Enterprises (350 ITR 489) (Civil Application
No.2688 of 2006) (dated. 14.01.2013)(SC) :
Though TDS and advance tax was paid by the Assessee, such
income was undisclosed income u/s 158B(b). It cannot be stated that
the payment of advance tax per se is tantamount to disclosure of the
income because it would be contrary to the very purpose of filing of the
return. This depends upon the time when the search is conducted.

Sundaram Finance Ltd v. ACIT ( 349 ITR 356) (SC) :

The taxing authorities cannot ignore the legal character of the
transaction which is the source of the receipt while determining whether
the receipt was taxable or not. The disputed sales tax liability collected
from the customers was part of the business turnover and constituted
income.

20

Recent Judgements Circulated During The Month

Of October 2014
S.No.

Name of the Case Law

Section
Reference

05-10-2014

Kamal Kant Vs CIT, ITA

Section 271(1)(c)

09-10-2014

CIT Vs Smt.Karpagam

Section 54F

17-10-2014

CIT Vs M/s Valiant Glassworks pvt ltd

Section 80HHC

20-10-2014

DCIT Vs Shri Rajeev G , Kalathil , ITA

Section 198

21-10-2014

DCIT Vs Century Textiles and Industries Ltd, ITA

Section 10(B)

27-10-2014

DCIT Vs Shri Harnamsingh Kulbirsingh Maker

Section 194A

30-10-2014

ACIT Vs Amarjeet Singh Sethi , ITA

Form 3CD

30-10-2014

DCIT Vs Dr. B.V.Rao Institute of Poultry

Section 12 A

management & Technology , ITA

21
CASE STUDY ON SECTION 54 & SECTION 254(2)

Facts of the case:

The Assessee purchased a plot of land in the year 1971, and a building was
constructed, out of own funds.

Later, in the impugned assessment year, the Assessee entered into an

agreement with a developer to convert the above property (Land and Building
together) into multi-storey residential apartment.

As per the agreement, the builder shall build residential apartments and hand
over the owner 50% of the constructed area.

A Supplementary Agreement was drafted when the construction was in

progress wherein the owner expressed her decision to dispose off her share of
50% of the super built area to the developer at an agreed consideration as full
and final settlement.

Subsequently, the Assessee purchased a residential property for Rs. 70,00,000

and claimed deduction u/s. 54 of the Income Tax Act, 1961.

Assessment Proceedings:
The Assessing officer disallowed the claim made by the Assessee u/s 54
on the ground that the transferred property is not a residential unit but a vacant
piece of land; hence sale of land is taxable.

Appellate Proceedings:

22

Aggrieved by the assessment order, the Assessee preferred an appeal

with the Learned CIT (A). The CIT (A) considered the facts in favour of the
Assessee and allowed the deduction claimed by Assessee.
The department went on appeal to the ITAT against the order passed by the
Learned CIT(A).

Held by the ITAT as follows:

The development agreement specifically states that the multi-storied

apartments are to be constructed after demolition of the old building.
This clearly shows that the intention of the Assessee was to sell the
plot and not the building. Similarly, the intention of the developer
was to develop multi-storied residential apartments and not to
acquire an old building.

In support of his claim, the assessing officer relied on the following

cases:
CIT vs. Union Co. Motors Ltd., (283 ITR 445) (Mad), where
it was held that if house was demolished prior to sale, then transfer
would be construed as transfer of vacant land.
ITA No. 3329 & 91/Mds/2004, where it was held that where
building has been demolished before sale of land it was the case of sale of
vacant land only, while passing the assessment order.

23

Hence,

the

ITAT

held

that

the

above

transaction

is

nothing but sale of land which, can by no scope of imagination be considered

as sale of residential house property warranting deduction u/s 54 of the Income Tax Act, 1961. Consequently the appeal was allowed in favour of the
department.

Miscellaneous Petition filed by the Assessee

Contention of the Assessee:

The said property was assessed to Property tax levied by the Corporation of Madras and
water tax by CMWSSB and the same has been given to the Learned Assessing Officer
during the course of assessment proceedings and the same was observed by the Learned
AO.

Further, the agreement entered between the Assessee and the developer, clearly states
that the said property comprises of land and house, the clear description was in detail
given in Schedule A of the agreement entered between the parties.

From the above, the Assessee tried to prove there was a residential unit at the time of
entering into an agreement with the developer, and even prior to that the said property
was assessed to the property taxes levied by the corporation of Madras as a residential
unit.

Held by the ITAT on filing Misc. Petition

The contention of the Assessee that there was a building in the land under
question, which was not considered by the ITAT previously was held to be
incorrect.

24

Hence the ITAT held that the Miscellaneous Petition filed by the
respondent was merely for the purpose for reviewing the order
previously passed, which is beyond the powers of the ITAT
mentioned in section 254(2) of the Income Tax Act, 1961.

As the Assessee had failed to point out any mistake apparent from
record warranting rectification, the miscellaneous petition was
dismissed.
Aggrieved by the order of the Tribunal, the Assessee has gone on

appeal to the High Court. The case is now pending before the Madras
High Court.

25

CURRENT AFFAIRS
NATIONAL AFFAIRS:
1. World Bank announces Indian Development update report on 27th October,
2014. The report said that India's GDP is likely to grow by 5.6 percent in
the financial year (FY) 2014-15 and GDP growth is likely to rise further to
6.4 percent in FY 2015-16 and 7 percent in FY 2016-17.
2. Union Government of India disclosed the names of Black Money Account
Holders in an affidavit to Supreme Court on 27/10/2014. The names
revealed by the government were:
Pradip Burman, one of Dabur India promoters

Bullion trader Pankaj Chimanlal Lodhya

Goa-based mining company Timblo Pvt Ltd and its five directors
Radha Satish Timblo, Chetan S Timblo, Rohan S Timblo, Anna C
Timblo and Malika R Timblob.

3. BJP won the Assembly election of Haryana and Maharashtra. BJP created
history in Haryana by securing a clear majority on its own for the first
time. BJP selects Devendra Fadnavis as new Maharashtra CM.

STATE AFFAIRS:

O.Panneerselvam sworn-in as Chief Minister of Tamil Nadu on

29 September 2014 due to resignation of J Jayalalithaa as CM as she was
convicted in the 18 year old disproportionate assets case of over 66 crore
rupees by Bangalore Special Court.

26

Former CM J Jayalalithaa has been granted Bail on 17/10/2014 by Supreme

court up to 16/12/2014. However on October 7 bail was refused by the
Karnataka High Court, which held that there were no grounds for grant of bail
to the AIADMK leader.

Sandeep Saxena Appointed As Tamil Nadu Chief Electoral Officer on

27/10/2014. Saxena succeeds Praveen Kumar, who has had a four-year stint in
the elections department.

Private dairies have hiked Milk price in Tamil Nadu. Which is followed by The
Tamil Nadu government announcing a hike in Aavin (Tamil Nadu Co-operative
Milk Producers Federation) milk price by Rs 10 per litre. The hike, which comes
after a gap of three years, will come into effect from November 1.

Neyvelis Rs. 4,910 crore tuticorin Power project nears completion

BUSINESS AFFAIRS:

Telecom Giant Soft Bank of Japan pledged to make an investment of 10 billion

US Dollars in Indias IT and communication sector in coming years. Apart from
this, SoftBank Group and Snapdeal on 28 October 2014 also announced
definitive agreements under which SoftBank Group will become the largest
investor in Snapdeal, through a total investment of 627 million US dollar.

Government ordered merger of NSEL with its holding FTIL. The merger was
recommended by commodity market regulator Forward Markets Commission
(FMC) and was also a long-standing demand of investors affected by the fraud
at NSEL.
The Ministry of Corporate Affairs (MCA) has included donations to the Swach
Bharat Kosh and the Clean Ganga Fund set up by the Central government as
part of corporate social responsibility (CSR) vide notification dated 24/10/2014.

As donations made to eligible funds qualify for certain tax breaks, we are
eagerly looking forward for a notification on inclusion of Swach Bharat
Kosh and the Clean Ganga Fund from the Central Board of Direct Taxes
(CBDT).