tax and cost

8/18/2019 tax and cost

1/44

CONFERENCE ON GST

Distance to GST – Has the Budget 2012 shortened it?

Rohan Shah

Economic Laws Practice

02nd June 2012


2/44

Background to theintroduction of theNegative List


3/44

Current Tax Cost in ndia

Intra-State

Ex. Duty – 12%

Edu. Cess – 3%

VAT– 5%/12.5%

Imports

Customs Dutyas!" – 1#%

CVD – 12%

Ed. Cess – 3%

Ser$!"e ro$!der

Ser$. Tax – 12.3&%

'a"tory

(eta!)erDea)er

To)) *anu+a"turer

,oods Transporter

Ser$. Tax-12.3&%

Interstate pur"ase

CST

Sto"0 trans+er

o tax

"tro! – #.5 to 5%

Inter-St

ate

Ex. Duty – 12%

Edu. Cess – 3%

CST – 2%

o"a) pur"ase

VAT – 5%/12.5%

ter

Ser$!"e ro$!der

Ser$. Tax – 12.3&%

o"a) pur"aseVAT – 5%/12.5%

ter

Ser$!"e ro$!derSer$. Tax – 12.3&%

Central Levy State Levy

VAT rate may range from 12.5-15% depending on the State

-Credit not fungible between State and Centre;

reulting in a !a!ading impa!t of ta"e

- Cumulati#e burden of $ndire!t Ta"e in $ndia 2&%

to ''% (appro".)


4/44

4

Excise dut!

Ser"ice tax

#$T %State Sa&es tax'#$T %State Sa&es tax'

Centra& Sa&es tax

Entr! tax

Octroi

$ddn&( dut! o) CustomsExcise dut!

Ser"ice tax

No Credit

Current Taxes and Credits

Current Taxes and Credits


5/44

Constitutiona& Framewor*(((

Taxes levied by Central Government and State Government(s)

Authority to levy a tax is derived from theConstitution of India Which allocates power to levy various taxes between the Centreand State

Article 265 of the Constitution which states that "No tax shall belevied or collected except by the authority of law”

Article 246 of the Indian Constitution, distributes legislativepowers including taxation, between the Parliament of India andthe State Legislature

Schedule VII enumerates use of three lists;List - I Where the parliament is competent to make lawsList - II Where only the state legislature can make laws

List - III Where both the Parliament and the State Legislature canmake laws upon concurrently

5


6/44

(((Constitutiona& Framewor*

+nion List State List Concurrent List

* Income Tax

* Custom Duty

* Excise Duty

* Corporation Tax

* Service tax

* Central Sales Tax

* Stamp duty in respect

of bills of exchange,cheques, promissory

notes, etc

* Taxes on lands and

buildings

* Excise duty on

alcoholic liquor etc

* Entry tax

* Sales Tax

* Tolls

* Luxury Tax

* Stamp duty in respect

of documents other

than those specified in

the provisions of List I

* Stamp duties other

than duties or fees

collected by means of

judicial stamps, but

not including rates ofstamp duty

6

The !ontant blurring of ta"ing +uridi!tion between the Centre and the

State ha ne!eitated multiple Contitutional !hallenge


7/44

Constitutiona& $mendment ,i&&

Introduction of Article 246A in the Constitution:

“Parliament and the Legislature of every State, have powerto make laws with respect to goods

and services tax imposed by the Union or by that State

respectively.

Provided that Parliament has exclusive power to make lawswith respect to goods and services tax where the supply of

goods, or of services, or both takes place in the course ofinter-State trade or commerce.”


8/44

8

Goods Vs. Services

Lines between the taxation of Goods & Services is constantly blurringDuality of Charge

Sr.

No.

Activity Customs

duty

Central /

State Excise

duty

Service

tax

VAT / CST

1. Intellectual Property

Services

2. Import of Designs, Technical

Know etc..

3. Works Contract

4. Construction Services

5. Manufacture of Products

liable to State Excise

-ua&it! o) char.e / re ne.ati"e &ist


9/44

Discrimination between manufacturers, service providers and traders

Non-uniform application of exemptions, credit provisions, etc.Cascading impact of taxes

Multiple causes of irrecoverable tax costs

Accumulation of credits

Non-transferability – lack of fungibilityInverted duty structures

Rate structure - no uniformity

no clear basis on which effective rates determined

Non availability of creditsBasis of levy of Service Tax was uncertain and variable

Rendition / performance

Consumption / use

Receipt

Other pain points in the currentsystem


10/44

GST regarded as panacea to address allpain points


11/44

Rationale for negative list


12/44

Rationa&e )or Ne.ati"e List

First Concept Paper for Public Debate (August 2011)

“There are advantages in moving towards negative list at an earliertime in order to gain useful experience in its implementation andminimize the impact of the mammoth changes that GST mayusher”

Revised Concept Paper on Taxation of Services based onNegative List (November 2011)“Introduction of Negative List at an earlier stage will pave the wayfor the smooth transition to the GST, and significantly ease the

challenges arising out of implementing the GST.”


13/44

Rationa&e )or Ne.ati"e List

FM’s speech (2012):

“At the end of June this year, this tax will attain adulthood by completing18 years. It is therefore time to shift gears and accelerate ahead.However, service tax needs to confront two important challenges tosustain the journey. These are:

The share of services in taxes remains far below its potential. There is aneed to widen the tax base and strengthen its enforcement;

Service Tax law is complex and sometimes avoidably different fromCentral Excise. We need to bring the two as close as possible in the lightof our eventual goal of transition to GST.”


14/44

Negative list


15/44

Enactment o) Finance $ct 2012

Provisions in Finance Bill enacted as Finance Act,

2012 on May 28, 2012

Negative list provisions to come into force from a date

to be notified

The Legislative scheme for the levy of Service Tax

stands overhauled


16/44

$roach / Se&ecti"e #s Ne.ati"e List

Sele!ti#e Approa!h

selected services are taxable

Negative List –all

services are taxable


17/44

17

Ser"ice Tax net widened

17


18/44

Potentia& Re"enue mact

Effective percentage of entire service sector that is covered

under the tax net = 20-25% (First Concept Paper)

Estimated net revenue gain consequent to changes in the UnionBudget 2012-13, relating to Indirect Taxes, estimated at Rs.45,940 crore (Budget Speech 2012-13)Service tax changes – Rs. 18,660 crore additional revenue


19/44

Chan.e in ro"isions / Finance $ct

Section 34 5 -e)initions

Section 34$ 5 C&assi)ication

Section 33 / Char.in. Section

Section 33$ / Char.in. Section incase o) imort o) ser"ices

Section 34, 5 -e)inition

Section 33, / Char.in. Section

Section 33F 5 C&assi)ication

Section 33C / P&ace o) Pro"ision

Section 33- / Ne.ati"e List

Section 33E / -ec&ared Ser"ices

Section 36$ / Rate and #a&ue

,ollowing pro#iion will !eae to

e"it from a date to be notified

,ollowing pro#iion will !ome into

for!e from a date to be notified

Section 37 / Pa!ment o) Ser"ice tax

Section 33C / P&ace o) Pro"ision

Current Pro"isions under

Finance $ct

Pro"isions under Finance $ct


20/44

Char.in. Section

Old charging provision (Section66)

“There shall be levied a tax(hereinafter referred to as theservice tax) at the rate of twelve

per cent. of the value of taxableservices referred to in sub-clauses [ ] of clause (105) ofsection 65 and collected in suchmanner as may be prescribed.”

New charging provision (Section66B)

“There shall be levied a tax(hereinafter referred to as theservice tax) at the rate of twelve

per cent. on the value of allservices, other than thoseservices specified in thenegative list, provided or agreedto be provided in the taxableterritory by one person toanother and collected in suchmanner as may be prescribed.”


21/44

8Ser"ice9

Means Includes But shall not include

- Any activity

- Carrie

d out

by a

perso

n for

anoth

er

- For

consi

derati

on

-Includes a declared service

1.ight to ue immo#able property2.Contru!tion of a !omple" building!i#il tru!ture or a part thereof; in!ludinga !omple" or building intended for ale toa buyer wholly or partly e"!ept where!onideration i re!ei#ed prior !ompletion/.Temporary tranfer or permitting the

ue or en+oyment of any intelle!tualproperty right'.$nformation te!hnology oftwareer#i!e5.0bligation to refrain from an a!t or totolerate an a!t or a ituation or to do ana!t.Ser#i!e in relation to leae or hire ofgood and hire pur!hae trana!tion.3"e!ution of 4or Contra!t&.Ser#i!e portion in the er#ing of foodor other arti!le of human !onumption

-any activity that constitutes merely a

transfer in title of goods or immovable

property by way of sale, gift or in any

other manner;

-such transfer, delivery or supply of any

goods which is deemed to be a sale

within the meaning of clause (29A) of

Article 366 of the Constitution;

- a transaction in money or actionable

claim;

- any service provided by an employee to

an employer in the course of or in relation

to his employment;- fees taken in any Court or a tribunal

established under any law for the time

being in force

- by a Constitutional authority under the

Indian Constitution or a member of an

Indian Legislature or a local self-government in that capacity


22/44

Country Definition of service

Canada(Section 123(1) of

the Excise Tax Act)

Service means anything other than Property,

Money, and

Anything that is supplied to an employer by a person who is

or agrees to become an employee of the employer in the

course of or in relation to the office or employment of that

person.”New Zealand

(Section 2 of the

GST Act)

Services has been defined to mean “Anything which is not goods

or money”

Singapore

(Section 10 of the

GST Act )

‘Supply of services’ means “anything which is not a supply of

goods but is done for a consideration (including, if so done, the

granting, assignment or surrender of any right)”

United Kingdom

(Section 5 of the

Value Added Tax

Act, 1994 )

‘Supply of services’ is defined as “anything which is not a supply

of goods but is done for a consideration (including, if so done, the

granting, assignment or surrender of any right) is a supply of

services.”

-e)inition o) 8Ser"ice9 / other :urisdictions


23/44

Ne.ati"e List o) Ser"ices(((

Sr(No(

-escrition o) ser"ices which are not &ia;&e to Ser"ice Tax

1. Ser#i!e by 6o#ernment or a lo!al authority (e"!luding !ertain pe!ifieder#i!e)

2. Ser#i!e by the eer#e 7an of $ndia

/. Ser#i!e by a foreign diplomati! miion lo!ated in $ndia

'. Ser#i!e relating to agri!ulture (only !ertain pe!ified er#i!e !o#ered)5. Trading of good

. Any pro!e amounting to manufa!ture or produ!tion of good. 89ro!eamounting to manufa!ture or produ!tion of good: ha been defined to a apro!e on whi!h dutie of e"!ie are le#iable under e!tion / of the C3 A!t1'' or any pro!e amounting to manufa!ture of al!oholi! li


24/44

(((Ne.ati"e List o) Ser"ices(((

Sr(No(

-escrition o) ser"ices which are not &ia;&e to Ser"ice Tax

. 7etting gambling or lottery. The term =betting or gambling> ha beenpe!ifi!ally defined.

1?. Admiion to entertainment e#ent or a!!e to amuement fa!ilitie.

11. Tranmiion or ditribution of ele!tri!ity by an ele!tri!ity tranmiion orditribution utility. The term =ele!tri!ity tranmiion or ditribution utility> habeen pe!ifi!ally defined.

12. Ser#i!e by way of pre-!hool edu!ation higher e!ondary !hooledu!ation edu!ation a a part of a !urri!ulum for obtaining a ha been pe!ifi!ally defined.

1'. Ser#i!e by way of e"tending depoit loan or ad#an!e in o far a the!onideration i repreented by way of interet or di!ount or inter e ale orpur!hae of foreign !urren!y amongt ban or authoried dealer of foreigne"!hange or amongt ban and u!h dealer


25/44

(((Ne.ati"e List o) Ser"ices

Sr.

No.

Description of services which are not liable to Service Tax

15. Ser#i!e of tranportation of paenger with or without a!!ompaniedbelonging by a tage !arriage; railway in a !la other than firt !la oran air-!onditioned !oa!h; metro monorail or tramway; inland waterway;publi! tranport other than predominantly for tourim purpoe in a #eel ofle than fifteen tonne net; and metered !ab radio ta"i or auto ri!haw

1. Ser#i!e by way of tranportation of good by road by an air!raft or a #eelfrom a pla!e outide $ndia to the firt !utom or by inland waterway(ub+e!t to !ertain e"!eption)

1. ,uneral burial !rematorium or mortuary er#i!e in!luding tranportation ofthe de!eaed.


26/44

Sr.

No.

Description of service in respect of which exemption from payment of Service Tax

is granted

1. Ser#i!e pro#ided to the @nited ation or a pe!ified international organiBation

2. ealth !are er#i!e by a !lini!al etablihment an authoried medi!al pra!titionerD

3. Ser#i!e by a #eterinary !lini! in relation to health !are of animal or bird

4. Ser#i!e by an entity regitered under Se!tion 12AA of the $T A!t ie !haritable a!ti#itie.

5. Ser#i!e of-

(a) renting of pre!in!t of a religiou pla!e meant for general publi!; or

(b)!ondu!t of any religiou !eremony.

6. Ser#i!e pro#ided to any peron other than a buine entity by -(a)an indi#idual a an ad#o!ate; or

(b)a peron repreented on and a arbitral tribunal.

7. Ser#i!e of te!hni!al teting or analyi of newly de#eloped drug in!luding #a!!ine

and herbal remedie on human parti!ipant by a !lini!al reear!h organiBation...

8. Ser#i!e by way of training or !oa!hing in re!reational a!ti#itie relating to art !ulture

or port.

Exemted Ser"ices(((


27/44

Sr(

No(

-escrition o) ser"ice in resect o) which exemtion )rom a!ment o) Ser"ice Tax

is .ranted

. Ser#i!e pro#ided-(a) to an edu!ational intitution by way of !atering under any !entrally aited mid day

meal !heme ponored by 6o#ernment; (b) to or by an intitution in relation to

edu!ational er#i!e where the edu!ational er#i!e are e"empt from the le#y of Ser#i!e

Ta" by way of tranportation of tudent or taff (!) to or by an intitution in relation to

edu!ational er#i!e where the edu!ational er#i!e are e"empted from the le#y of

er#i!e ta" by way of er#i!e in relation to admiion to u!h edu!ation.

1?. Ser#i!e pro#ided to a re!ognied port body by-

(a) an indi#idual a a player referee umpire !oa!h or manager for parti!ipation in a

tournament or !hampionhip organiBed by a re!ogniBed port body;

(b) another re!ognied port body;

11. Ser#i!e by way of ponorhip of tournament or !hampionhip organied-

(a) by a national port federation or it affiliated federationD(b) by Ao!iation of $ndian @ni#eritie $nter-@ni#erity Sport 7oard S!hool 6ame

,ederation of $ndia All $ndia Sport Coun!il for the Eeaf 9aralympi! Committee of $ndia

Spe!ial 0lympi! 7harat;

(!) by Central Ci#il Ser#i!e Cultural and Sport 7oard;

(d) a part of national game by $ndian 0lympi! Ao!iation; or

(e) under 9an!hayat Fu#a Greeda Aur Ghel Abhiyaan (9FGGA) S!heme;

(((Exemted Ser"ices(((


28/44

Sr.No.

Description of service in respect of which exemption from payment of Service Taxis granted

12. Services provided to the Government or local authority by way of erection, construction,maintenance, repair, alteration, renovation or restoration of -

(a) a civil structure .. meant predominantly for a non-industrial or non-commercial use;

(b) a historical monument, archaeological site or remains of national importance...

(c) a structure meant predominantly for use as (i) an educational, (ii) a clinical, or (iii) anart or cultural establishment;

(d) canal, dam or other irrigation works;(e) pipeline, conduit or plant for (i) drinking water supply (ii) water treatment (iii)seweragetreatment or disposal; or

(f) a residential complex predominantly meant for self-use or the use of their employeesor other persons specified in theExplanation1 to clause 44 of section 65 B of the saidFinance Act;

13. Services provided by way of erection, construction, maintenance, repair, alteration,renovation or restoration of,-

(a) road, bridge, tunnel, or terminal for road transportation for use by general public;

(b) building owned by an entity registered under section 12AA of the Income tax Act,

1961(43 of 1961) and meant predominantly for religious use by general public;

(c) pollution control or effluent treatment plant, except located as a part of a factory; or (d)

electric crematorium;



29/44

Sr.

No.


is granted

14 Services by way of erection or construction of original works pertaining to,-(a) airport, port or railways;

(b) single residential unit otherwise as a part of a residential complex;

(c) low- cost houses up to a carpet area of 60 square metres per house in a housing

project approved by competent authority empowered under the ‘Scheme of Affordable

Housing in Partnership’ framed by the Ministry of Housing and Urban Poverty Alleviation,

Government of India;(d) post- harvest storage infrastructure for agricultural produce including a cold storages

for such purposes; or

(e) mechanised food grain handling system, machinery or equipment for units processing

agricultural produce as food stuff excluding alcoholic beverages;

15. Temporary transfer or permitting the use or enjoyment of a copyright covered under

clause (a) or (b) of sub-section (1) of section 13 of the Indian Copyright Act, 1957 (14 of

1957), relating to original literary, dramatic, musical, artistic works or cinematograph

films;

16 Services by a performing artist in folk or classical art forms of (i) music, or (ii) dance, or

(iii) theatre, excluding services provided by such artist as a brand ambassador

17. Services by way of collecting or providing news by an independent journalist, Press Trustof India or United News of India.



30/44

Sr.

No.


is granted

18. Services by way of renting of a hotel, inn, guest house, club, campsite or other

commercial places meant for residential or lodging purposes, having declared tariff of a

room below rupees one thousand per day or equivalent;

19. Services provided in relation to serving of food or beverages by a restaurant, eating joint

or a mess, other than those having the facility of air-conditioning or central air-heating in

any part of the establishment, at any time during the year and which has a license toserve alcoholic beverages;

20. Services by way of transportation by rail or a vessel from one port in India to another of

the 9 specified varieties of goods.

21. Services provided by a goods transport agency by way of transportation of fruits,

vegetables, eggs, milk, food grains or pulses, or where gross amount charged on a

consignment transported in a single goods carriage does not exceed Rs. 1,500; orwhere gross amount charged for transportation of all such goods for a single consignee

in the goods carriage does not exceed Rs. 750

22. Renting of motor vehicles to State transport undertaking meant to carry more than twelve

passengers and to a goods transport agency, a means of transportation of goods.



31/44

Sr.

No.


is granted

23. Transport of passengers by-•air embarking or terminating in an airport located in the state of Arunachal Pradesh,

Assam, Manipur, Meghalaya, Mizoram, Nagaland, Sikkim, or Tripura or at Baghdogra

located in West Bengal; or

•a contract carriage for the transportation of passengers, excluding tourism, conducted

tour, charter or hire

24. Services by way of motor vehicle parking to general public excluding leasing of space toan entity for providing such parking facility

25. Services provided to the Government or a local authority by way of -

(a) repair of a ship, boat or vessel;

(b) effluents and sewerage treatment;

(c) waste collection or disposal;

(d) storage, treatment or testing of water for drinking purposes; or

(e) transport of water by pipeline or conduit for drinking purposes

26. Services of general insurance business provided under specified schemes

27. Services provided by an incubatee up to total business turnover of Rs. 50 lakh in an FY,

subject to the following conditions: (a) total business turnover had not exceeded Rs. 50

lakh in the preceding FY and(b) 3 years has not lapsed from the date of entering into agreement as an incubatee



32/44

Sr.

No.


is granted

28. Service by an unincorporated body or an entity registered as a society to own members

by way of reimbursement of charges or share of contribution

(a) as a trade union;

(b) for the provision of exempt services by the entity to third persons; or

(c) up to an amount of Rs. 5000 per month per member for sourcing of goods or services

from a third person for common use of its members in a housing society or residentialcomplex

29. Services by the following persons in respective capacities -

(a) a sub-broker or an authorised person to a stock broker;

(b) an authorised person to a member of a commodity exchange;

(c) a mutual fund agent or distributor to mutual fund or asset management company for

distribution or marketing of mutual fund;(d) a selling or marketing agent of lottery tickets to a distributer or a selling agent;

(e) a selling agent or a distributer of SIM cards or recharge coupon vouchers; or

(f) a business facilitator or a business correspondent to a banking company or an

insurance company in a rural area;



33/44

Sr.

No.


is granted

30. Carrying out an intermediate production process as job work in relation to specified

goods

31. Services by an organiser to any person in respect of a business exhibition held outside

India

32. Services by way of making telephone calls from:

(a) departmentally run public telephones;

(b) guaranteed public telephones operating only for local calls; or

(c) free telephone at airport and hospitals where no bills are being issued

33. Services by way of slaughtering of bovine animals

34. Services received from a service provider located in a non- taxable territory by: (a) theGovernment, a local authority or an individual in relation to any purpose other than

industry, business or commerce; or

(b) an entity registered under section 12AA of the Income tax Act, 1961 (43 of 1961) for

the purposes of providing charitable activities.

(((Exemted Ser"ices


34/44

Princi&es o) c&assi)ication

Concept of ‘composite service’ under Section 65A has been replacedby ‘bundled service’Reference to a service shall not include reference to a service used inproviding such main service

For services capable of differential treatment for any reason based on itsdescription, the most specific description to be preferred over a moregeneral description

In case of a bundled service, i.e. when provision of one service iscombined with element(s) of other service(s), taxability is to bedetermined as under:If various elements of such service are naturally bundled in the ordinarycourse of business, it shall be treated as provision of the single service which

gives such bundle itsessential characterIf various elements of such service are not naturally bundled in the ordinarycourse of business, it shall be treated as provision of the single service whichresults in thehighest liability of Service Tax

What is naturally bundled will be the subject matterof interpretation


35/44

-ua&it! o) taxes ost ne.ati"e &ist

Renting of immovable property serviceStamp duty vis-à-vis Service Tax

Supply of softwareVAT and Service tax

Works Contract / Construction servicesDiffering schemes of abatements under VAT Laws and Service Tax law

Original Works, Contract value = Rs. 100/-Service Tax @12.36% on Rs. 40/- (abatement of 60%)

VAT @ 14.5% on Rs. 75/- (abatement of 25% under VAT Laws)

Effective value of contract subjected to Indirect Taxes is Rs.115/- asagainst an actual realization of Rs. 100/-

Taxing impact further aggravated for other than Original Works onaccount of the Service tax abatement being only 40%, thereforeeffective value of contract subject to Indirect Taxes is Rs.135/-

Credits of Excise Duty paid on goods not available on account ofconditions of the abatement scheme


36/44

Transactions new&! &ia;&e<

Non-compete fees

Financial transactions for consideration – derivatives, hedges

Sale of business (slump sale transactions)

License fees / Assignment fees

Revenue share arrangements with agencies like AAI, NHAI,MMRDA

Directors fees to non-executive directors

Ever evolving tax footprint


37/44

-ichotom! ;etween tax )ootrint and credit )ootrint

While the tax footprint has risen exponentially the credit footprint isnarrow and remains fragmented in silosThe scope of the term ‘input service’ was narrowed in 2011, toeliminate services availed for businesses and restricted to only forproviding taxable output service, and / or used in or in relation tomanufacture

Flexibility for distribution of credit has been restricted for Input ServiceDistributors

No concept of First Stage Dealer to pass through Service Tax credits

The net impact is that the cascading of taxes will rise and the sunkcosts in unutilisable credits will escalate

The potential approaches to addressing this problem could beEnlarge the scope of input services

Grant refund of unutilisable credit

Offer fungible reflective credits – unutilised CENVAT credit can bemade available fungibly as VAT credit


38/44

!oods and "ervice #ax$!"#%

= ; d


39/44

=e! taxes su;sumed

Dual GST

&"# #'BE

()*"E+ ',#

Li* & GST > d &


40/44

Li*e&! GST >ode&Li*e&! GST >ode&

CentralGST

StateGSTStateGST

CentralSalesTax

Import

GST

StateGST

IGST

>i&estones ? Si.na&s o) GST


41/44

41

Issue 201

1

201

2

Emerging Position

Expanded scopeof ST

Negative ist introduced

!utomatic refunds Ne" scheme noti#ed

Pace of suppyrues Introduced for Pu$icde$ate

Time of suppyrues %POT &ues'

Noti#ed in 2011(!mendments to removeteething di)cuties

IT Infrastructure *!dministrativestructure

+ST Net"or, to $eoperationa from !ugust2012 * Singe formsnoti#ed for CE- and ST

-raft egisations

%Centre . States'

No -raft egisations




42/44

42


Issue 2011 201

2

Emerging Position

Transition date To $e decided post discussion"ith States

Constitutionaamendments

Introduced in the o, Sa$ha(referred to StandingCommittee

-raft egisation i to $e introduced

!ignment ofCE- and ST

rates "ithproposed C+STrate

&ate of CE- . CE increasedto 12 3 expected rate of

C+ST is 4 to 10

&eduction innum$er of CE-

exemptions

&eduction in num$er ofexemptions from CE-


43/44

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 endeavor 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 onsuch information without appropriate professional advice after a thorough examination of the particular situation.

The greater the timegap $et"een the

introduction ofnegative ist and the

introduction of +ST(the greater the $urden

for industry and


44/44

Humbai15?2 A 4ing Ealamal Tower ariman 9oint Humbai '?? ?21

9honeI J 1 22 / ??? ,a"I J 1 22 / 12 3mailI mumbaiKelp-in.!om

Delhi'?5-'? 'th ,loor 4orld Trade Centre 7arahamba Lane ew Eelhi 11? ??1

9honeI J 1 11 '152 &'?? ,a"I J 1 11 '152 &'?' 3mailI delhiKelp-in.!om

Ahmedabad&?1 Abhi+eet $$$ Hithaali Si" oad 3llibridge Ahmedabad-/&? ??

9honeI J1 ?5 ''&? M & ,a"I J1 ?5 ''&2 3mailI ahmedabadKelp-in.!om

PuneSuyog ,uion th ,loor o.1 Ehole 9atil oad r. uby all Clini! 9une '11 ??1

tax and cost

Documents