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8/6/2019 KPMG DTC Impact Financial
1/25
2010 KPMG India Private Limited, an Indian private limited company and a member firm of the KPMG network of independent member firms affiliated with KPMG International, aSwiss cooperative. All rights reserved.
1
Direct Taxes Code Bill 2010Direct Taxes Code Bill 2010
Financial ServicesFinancial Services -- Sectoral Analysis / ImpactSectoral Analysis / Impact
September 2010September 2010
TAXTAX
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2010 KPMG India Private Limited, an Indian private limited company and a member firm of the KPMG network of independent member firms affiliated with KPMG International, aSwiss cooperative. All rights reserved.
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2010 KPMG India Private Limited, an Indian private limited company and a member firm of the KPMG network of independent member firms affiliated with KPMG International, aSwiss cooperative. All rights reserved.
Contents
1. Background
4. Mutual Fund
6. Bank / Non-banking financial company
5. Insurance
3. Venture Capital Fund / Venture Capital Company
7. Key provisions for offshore funds
2. Key tax rates under DTC
8. Foreign Institutional Investors
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2010 KPMG India Private Limited, an Indian private limited company and a member firm of the KPMG network of independent member firms affiliated with KPMG International, aSwiss cooperative. All rights reserved.
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Background
DTC 2009 unveiled in August 2009
The Government received over 1,600 representations on DTC 2009
Revised Discussion Paper released in June 2010 on 11 specific issues
DTC 2010 tabled in the Lok Sabha on 30 August 2010
After clearance from the Parliamentary Standing Committee, the Bill may be passed in
the Winter Session
The DTC 2010 to be effective from FY commencing 1 April 2012
Impact / Issues
DTC effective from April 1, 2012
Room to make representations on key issues prior to enactment
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2010 KPMG India Private Limited, an Indian private limited company and a member firm of the KPMG network of independent member firms affiliated with KPMG International, aSwiss cooperative. All rights reserved.
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NilNilDividends on which DDT hasbeen paid
15 percent15 percentDDT
20 percent18 percentMAT
Normal rate - 30 percent
Branch profit tax - 15 percent
Interest income * 20 percent
Fees for technical services /Royalties * 20 percent
Normal rate - 40 percentIncome tax - ForeignCompany
30 percent30 percentIncome Tax - Indian Company
DTC 2010Current Income-tax headlinerates
Category
Key Tax Rates ... Corporate tax
* In case the non-resident does not have a PE in India
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Key tax rates ... Capital gains tax
15%
Exempt
Currentheadline rate
Deduction allowed for 100% of gains
(Effectively exempt)
LTCG (more than 1 year)
Deduction allowed for 50% of gains Balance taxable at normal rates (30%)
STCG (1 year or less)
DTC 2010Gain on transfer of Equity Shares / Units ofEquity Oriented Fund on which STT is paid
20% (10% incertain cases, ifindexation notavailed)
Currentheadline rate
Taxable at normal rates (30%) - Indexationavailable
If held for more than 1 year from end of financial yearin which asset is acquired
DTC 2010Gain on transfer of other InvestmentAssets
Impact / Issues Statement of objects and reasons provides that in respect of equity share and equity-oriented mutual fund unit,
higher deduction of 100% is allowed if such securities are transferred after 1 year from end of the financial yearin which it is acquired. There is an apparent anomaly with the language of the provision.
Whether indexation available for transfer of equity shares on which STT has not been paid? As per the Discussion Paper prior to this, As there will be a shift from nil rate of tax on listed equity shares and
units equity oriented funds held for more than one year, an appropriate transition regime will be provided,if required.- Possibility of deduction from capital gains being phased out over a period?
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2010 KPMG India Private Limited, an Indian private limited company and a member firm of the KPMG network of independent member firms affiliated with KPMG International, aSwiss cooperative. All rights reserved.
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Venture Capital Funds / Companies
Income of VCF / VCC from investment in unlisted VCU engaged in certain specified businesses
exempt from tax.
Income received by investor from the above stated VCF / VCC taxable as if it were income received
by the investor had he made investments directly in the VCU.
Above VCF / VCC are not subject to distribution tax on distribution of income to investors.
Income of VCF from investment in companies not engaged in specified businesses to be governed by
normal trust taxation provisions.
The trust taxation provisions have been substantially simplified to provide for one-level taxation.
Concept of determinate / indeterminate / maximum marginal rate taxation removed.
Income of VCC from investment in companies not engaged in specified businesses to be governed by
normal corporate tax provisions.
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2010 KPMG India Private Limited, an Indian private limited company and a member firm of the KPMG network of independent member firms affiliated with KPMG International, aSwiss cooperative. All rights reserved.
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Venture Capital Funds / Companies
Specified businesses defined to mean (a) nano-technology; (b) information technology relating to hardware
and software development; (c) seed research and development; (d) bio-technology; (e) research and
development of new chemical entities in the pharmaceutical sector; (f) production of bio-fuels; (g) dairy and
poultry; (h) building and operating composite hotel cum convention centre with seating capacity of morethan three thousand; (i) development of infrastructural facility; or (j) any other business as may be
prescribed;
Infrastructure facility means the following facilities, (a) a road including toll road, a bridge or a rail system;
(b) a highway project including housing or other activities being an integral part of the highway project; (c) a
water supply project, water treatment system, irrigation project, sanitation and sewerage system or solid
waste management system; and (d) a port, airport, inland waterway or inland port;
Impact / Issues
Provisions under DTC largely similar to the current Income-tax Act. Simplification of trust taxation
provisions would come as a relief for domestic funds. Certain current issues continue e.g. no exemption available for income from VCU which is listed
subsequently, investment in preferential allotments of listed company, interest from deposits;
applicability of MAT to VCC; no exemption from TDS on interest to exempt VCF / VCC; etc.
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2010 KPMG India Private Limited, an Indian private limited company and a member firm of the KPMG network of independent member firms affiliated with KPMG International, aSwiss cooperative. All rights reserved.
8
Mutual Funds
Income received by the mutual fund is exempt from tax
No withholding tax is applicable on payments to mutual fund
Distribution Tax
In case of equity oriented mutual fund* 5%
In case of non-equity oriented mutual fund - Nil
Withholding tax
In case of equity oriented mutual fund Nil
In case of non-equity oriented mutual fund withholding tax applicable
o 10% where deductee is a resident individual / HUF; and
o 20% for other deductees (including non-residents)
o Exemption from withholding tax paid to resident unit-holders provided the deductee is not a company
and the aggregate amount of payment to unit-holder does not exceed INR 10,000.
* Equity-oriented mutual fund defined to mean a fund where more than 65% of total proceeds are investedby way of equity shares in domestic companies.
Taximplications
for MutualFunds
ImplicationsParticulars
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2010 KPMG India Private Limited, an Indian private limited company and a member firm of the KPMG network of independent member firms affiliated with KPMG International, aSwiss cooperative. All rights reserved.
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Mutual Funds
Income received from Mutual Fund
In case of equity oriented mutual funds exempt
In case of non-equity oriented mutual funds taxable at applicable rates
STT applicable on transactions in units of equity oriented mutual funds
Capital Gains No special tax rates provided, taxation at normal rates
In case of transactions in units of equity oriented mutual funds where STT is paid
o In case of units held for more than one year 100% deduction allowed
oIn case of units held for one year or less 50% deduction allowed
In case of non equity oriented mutual funds
o Indexation available in case of units held for more than one year from the end of the financial year inwhich it was acquired
Taximplications
for Investorsin MutualFunds
ImplicationsParticulars
Impact / Issues
Proposed provisions dilute the current tax arbitrage available to investors in non-equity oriented
mutual funds vis--vis fixed income instruments directly.
5% DDT on equity oriented mutual funds an additional cost.
Current definition of equity oriented mutual fund continues .. Not widened to include FoFs, investment
in derivatives / non-domestic companies, etc.
Compliance obligation for mutual funds to increase.
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2010 KPMG India Private Limited, an Indian private limited company and a member firm of the KPMG network of independent member firms affiliated with KPMG International, aSwiss cooperative. All rights reserved.
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Insurance
Insurance premium (including re-insurance premium) accrued from or payable by anyresident or non-resident deemed to accrue in India if in respect of insurance covering anyrisk in India
Re-insurance
No withholding tax in case payments eligible for deduction (as mentioned in next slide)
In case of other payments, Life insurance company required to withhold taxes on
payments to resident policyholders at specified rates except where Policyholder is not a company; and
Aggregate amount of payments during the financial year does not exceed Rs. 10,000
Withholding taxobligation for
life insurance
Life Insurance company liable to pay distribution tax @ 5% on income computed inprescribed manner
No tax deduction available to life insurance company for taxes paid
Approved equity oriented life insurance scheme defined as life insurance policies where more than65% of premium are invested in equity and such scheme are approved by Board
Introduction ofapprovedequity orientedlife insurancescheme
Life Insurance Tax regime changed.. Only profits determined in Shareholders A/ctaxable, subject to certain adjustments
Concessional tax rate of 12.5%* removed Taxable at corporate tax rate of 30%
Other than Life Insurance -
Profits of other life insurance business to be profits as disclosed in annual accounts furnished underthe Insurance Act, subject to certain adjustments
Tax rate reduced marginally on account of surcharge and education cess
Taxation ofInsurance
business
ImplicationsParticulars
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2010 KPMG India Private Limited, an Indian private limited company and a member firm of the KPMG network of independent member firms affiliated with KPMG International, aSwiss cooperative. All rights reserved.
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Insurance
Deduction / exemption available in case income arising from following policies:
Where sum is received on completion of original period of contract and premium paid / payable for anyof years does not exceed 5% of actual capital sum assured
Where sums are received under an approved equity oriented life insurance scheme and distributiontax is paid by the life insurer; and
Where sums are received on death of insured person
In case other than above, premiums paid eligible for deduction to the extent not claimedearlier and included in income
Taxability ofsums received
underinsurancepolicy
Separate deduction upto an aggregate limit of INR. 50,000 (including contribution forchildren education) proposed for life insurance policy where premium paid during the termof the policy does not exceed 5% of actual capital sum assured and health insurancepolicies
Contribution to pension funds may be permitted as a deduction in the aggregate limit ofINR 100,000 if the annuity plan is approved by the CBDT
Deduction forpremium paidin hands ofpolicy-holders
ImplicationsParticulars
Impact / Issues There is no grandfathering provision for existing policies.
There is no specific exemption provided for commuted portion of pension received from
approved pension funds [10(23AAB) funds].
Compliance obligations for insurance companies to increase.
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Banks / NBFCs
Interest on bad or doubtful debts of any financial institution (including NBFC)shall be included in total income of the financial year in which interest iscredited to profit and loss account of, or is actually received, whichever isearlier
Interest on bad anddoubtful debts
Deduction towards provision for bad debts subject to following conditions:
amount should be in accordance with prudential guidelines of RBI
amount should be debited to profit & loss account
Deduction capped at 1% of aggregate average advances
Debit balance, if any, on last day of financial year in the provision for doubtfuldebts allowed as a deduction provided the balance has been transferred toprofit & loss account
Deduction of provisionfor doubtful debt/ bad
debts for financialinstitutions (includingbanks and NBFC)
ImplicationsParticulars
Impact / Issues
NBFC and Housing finance public company eligible for deduction Definition of aggregate average advances not available
No clarity on the allowability of the claim with respect to the provision for bad and doubtful debts
made beyond the limits prescribed by RBI
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2010 KPMG India Private Limited, an Indian private limited company and a member firm of the KPMG network of independent member firms affiliated with KPMG International, aSwiss cooperative. All rights reserved.
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Banks / NBFCs
In respect of a financial lease (as defined), a business capital asset is deemedto be owned by a lessee
Lessee to be allowed the depreciation on the assets procured on finance lease
and payment of lease rent to be treated as payment of principal and interest
Financial lease
New provision inserted on broken-period income
As per the provisions, income accruing from a debt instrument, transferred at
any time during a financial year, should not be less than amount of broken-period income from the instrument
Broken-period income is defined as income for the period commencing fromdate of acquisition of debt instrument or beginning of the financial year,whichever is later, and ending on the date of sale of security
Broken-period income to be calculated as if the income from such securitieshad accrued from day to day and been apportioned accordingly for brokenperiod
Broken-period income
ImplicationsParticulars
Impact / Issues
No corresponding provision for purchaser to claim broken-period interest as an expense.
Certainty on allowability of depreciation to lessee in case of financial lease.
Finance lease defined to provide clarity on the lease arrangement.
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Banks / NBFCs
DDT at 15% on amount of dividend declared, distributed or paid by a domesticcompany
In computing DDT, amount of dividend declared by a company to be reducedby dividend received from another company if:
Dividend is received from a subsidiary; and
Subsidiary has paid DDT on such dividend
Dividend DistributionTax
Branches of foreign banks and other permanent establishments required topay additional branch profits tax of 15%
Branch profits calculated as income attributable, directly or indirectly, to thepermanent establishment included in the total income of the foreign companyas reduced by amount of income-tax payable on such attributable income
Liability to be discharged by payment of pre-paid taxes.
Branch Profits Tax
ImplicationsParticulars
Impact / Issues
Branch Profits Tax
Tax levied on profits of branch level irrespective of remittance to head office
Tax Treaty not to have preferential status in respect of levy of branch profits tax
DDT
Significant relaxation for intermediate holding companies as existing provision requirement that recipient
company should not be a subsidiary of any other company done away with
No clarity on the availability of Multi-level DDT credit
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2010 KPMG India Private Limited, an Indian private limited company and a member firm of the KPMG network of independent member firms affiliated with KPMG International, aSwiss cooperative. All rights reserved.
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Banks / NBFCs
Lower of following allowed as a deduction:
Expenses attributable to business in India
0.5% of total sales / receipts of business in India
Nature of expenses covered is similar to provision of section 44C of theIncome-tax Act, 1961
Head officeexpenditure incurred
by a non-resident
ImplicationsParticulars
Impact / Issues
Current requirement of restricting deduction to a percentage of adjusted total income withdrawn Even loss making banks can claim deduction
As deduction is linked to percentage of sale / receipt vis--vis earlier deduction based on adjusted
total income - may adversely affect where India is significant income contributor
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Company regarded as resident if place of effective management at anytime in the year is in India
Place of effective management means
Place where Board of directors / executive directors make their decisions; or If Board routinely approves commercial and strategic decisions of executive
directors / officers, place where such executive directors / officers performtheir functions
Residency ofForeign Cos.
Key tax provisions for Offshore Funds
Impact / Issues
Residency for non-corporate entities continues to be based on control and management test
Expression at any time very wide Meaning of the expressions routinely / commercial and strategic decisions impact on Indian groups
having overseas subsidiaries to be considered
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Transfer of capital asset situated in India
Income deemed to accrue in India, if it accrues, directly or indirectly, through orfrom inter alia transfer of the capital asset situated in India (same as current law)
Income of a non-resident not deemed to accrue in India from transfer outside
India, of share / interest in a foreign company unless at any time in 12 monthspreceding thee transfer, the fair value of the assets in India, represent at least50% of the fair market value of all assets owned by the company
If income is deemed to accrue / arise in India as above, proportionate gainstaxable in India
Offshore Leverage
Interest income deemed to accrue in India if it is accrued from / payable by anon-resident and used for inter alia earning income from any source in India
Such interest will not be deemed to accrue or arise in India if such interest hasnot been claimed by the non-resident as a deduction from his tax baseschargeable in India
Extra-territorial
operation
Key tax provisions for Offshore Funds
Impact / Issues No consideration to the quantum of interest in the offshore company (whether even 1% stake transfer in offshore company
leads to an indirect transfer?)
Meaning of the expressions interest in a foreign company / owned directly and indirectly by the Company
Guidelines awaited on FMV methodology, which are critical in determining applicability of this provision
Provision can be overridden by a favorable tax treaty
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Tax Treaties entered into under the Act deemed to have been enteredunder the Code
Code or DTC, whichever is beneficial to apply, except in the following
cases Where GAAR is invoked
Where Branch Profit tax is levied
Where CFC rules are triggered
Tax Treaty v/s
DTC
Key tax provisions for Offshore Funds
Impact / Issues
Ambiguity in the initial DTC draft removed by clearly specifying that past Treaties continue .. However, effectiveness to be
considered in light of anti-abuse provisions.
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Powers given to Commissioner for invoking GAAR
Onus on the tax payer to prove that obtaining tax benefit was not the mainpurpose
GAAR can be invoked with respect to an impermissible avoidancearrangement guidelines and conditions for invoking GAAR to beprescribed
Impermissible avoidance arrangement means an arrangement whosemain purpose is to obtain tax benefit and satisfying any of the below:
Creates rights / obligations not at arms length;
Leads to misuse or abuse of beneficial provisions; or Lack commercial substance;
Lacks bonafide intent;
GAAR to override provisions of Tax Treaty
GAAR
Key tax provisions for Offshore Funds
Impact / Issues GAAR to override tax treaties: Sustainability of tax treaty protection with Mauritius, Cyprus, etc. in absence of appropriate
substance / commercial rationale, etc.?
To watch out for CBDT guidelines on GAARs
Effectiveness of DRP route for resolving GAARs related disputes
Availability of AAR mechanism?
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GAARs invoked -Is main purpose
Arrangement of taxbenefit?
(impermissibleavoidance
arrangement)Deemed connectedperson as same,
etc
Treat the arrangementas void
Disregardaccommodating
parties/ Treat partiesas one and the same
Re-allocateincome, expenses,
relief, etc
Disregard/ combine/ re-characterize
the arrangement
Re-characterizeEquity -Debt,
Income, expenses,relief, etc
Rights / Obligationsnot at arms-length
Misuse /Abuse of DTC
Lacks commercial/
economic
substance
Is not for bonafidepurposes
Key tax provisions for Offshore Funds
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PE defined : Relevant for Business Connection and Branch Profit tax
PE includes :
Fixed place PE,
Service PE (no time threshold specified), Construction / Installation / Assembly / Supervisory PE (no time threshold
specified),
Substantial Equipment PE (no time threshold specified) and
Agency PE (excludes independent agents)
PE
Key tax provisions for Offshore Funds
Impact / Issues
Non-specification of time thresholds : Impact thereof
No exclusions for preparatory and auxiliary activities
No definition for Independent Agent
Provision of Services in India resulting in Service PE : Taxability on a gross basis vs. net basis
PE definition in Treaties to over-ride Business Connection test
Branch Profit Tax not subject to treaty protection; hence, treaty definition of PE not relevant for Branch Profit Tax
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CFC provisions introduced
Total income of a resident to include income attributable (on a net income basis) to a CFC
CFC means a foreign company
that is a resident of a territory with lower rate of taxation (where taxes paid are less than 50
percent of taxes on such profits as computed under the DTC) whose shares are not listed on recognized stock of that country
that is individually or collectively controlled by persons resident in India
that is not engaged in any active trade or business (Active trade or business not to includeincome from sale of goods or supply of services to any associated enterprise); and
that has specified income exceeding INR 2.5 million
CFC provisions to override provisions of Tax Treaty.
Income attributable to a CFC to be computed as per Specified Formula.
Resident assessee to furnish details of investments and interest in entities outside India.
Wealth tax to be levied on resident assessee
CFC
Key tax provisions for Offshore Funds
Impact / Issues
Applicability of CFC regime to Indian financial services groups having offshore AMCs and entities controlled by such AMCs?
Applicability of CFC regime to downstream investment subsidiaries of overseas operating companies?
Applicability of CFC regime to non-corporate overseas entities?
Computation of profits of the CFC for measuring lower rate of taxation could pose complexities
Credit / deduction in India for Foreign Taxes paid by CFC?
Gains on sale of CFCs shares to be taxed without offsetting prior years taxes paid due to application of CFC
Set-off between profits and losses of different CFCs?
Double taxation on account of applicability of TP and CFC provisions?
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Foreign Institutional Investors
No Specific Code prescribed for FIIs Governed by normal tax provisions applicable to foreign
companies
Income of FIIs from transfer of securities is capital gains and not business income
The term securities includes derivatives No withholding tax applicable on capital gains .. Withholding tax applicable on other income
Capital loss allowed to be indefinitely carried forward for set-off
STT continues
Other provisions relevant to offshore funds apply
Impact / Issues
Treatment as capital gains to impact FIIs based out of jurisdictions where Treaty does not provide
for a capital gains tax exemption.
Re-instatement of concessions on capital gains tax on listed equity shares is a relief
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Venture Capital UndertakingVCU
Venture Capital FundVCF
Venture Capital CompanyVCC
Transfer PricingTP
Securities Transaction TaxSTT
Short-term Capital GainSTCG
Permanent EstablishmentPE
Non-Banking Finance CompanyNBFC
Minimum Alternate TaxMAT
Long-term Capital GainLTCG
Foreign Institutional InvestorsFII
Financial YearFY
Direct Taxes Code Bill 2010DTC
Dispute Resolution PanelDRP
Central Board of Direct TaxesCBDT
Dividend Distribution TaxDDT
AAR Authority for Advance Rulings
CFC Controlled Foreign Companies
GAAR General Anti Avoidance Rules
Glossary
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Mumbai
Lodha Excelus, 1st Floor,
Apollo Mills Compound,N.M. Joshi Marg, Mahalakshmi,
Mumbai 400 011
Tel +9122 39896000
Fax +91 22 39836000
New Delhi
Building No.10, Tower B,
8th
Floor, DLF Cyber City,Phase II
Gurgaon 122002 Haryana
Tel +91 124 3074000
Fax +91 124 2549101
Bangalore
Maruthi InfoTech Centre
11/1 and 12/1, East Wing, II Floor,
Koramangala,
Inner Ring Road
Bangalore 560 071
Tel +91 80 3980 6000
Fax +91 80 3980 6999
Hyderabad
8-2-618/2
Reliance Humsafar, 4th Floor
Road No. 11, Banjara Hills
Hyderabad 500 034
Tel +91 40 6630 5000
Fax +91 40 6630 5299
Chennai
No. 10 Mahatma Gandhi Road,
Nungambakam,
Chennai 600 034
Tel +91 40 3914 5000
Fax +91 40 3914 5999
Kolkata
Infinity Benchmark,
Plot No.G-1, 10th floor,
Block - EP & GP,
Sector - V, Salt Lake City
Kolkata 700091
Tel: +91 33 44034066
Fax: +91 33 4403 4199
Pune
703, Godrej Castlemaine,
Bund Garden,
Pune 411 001
Tel +91 20 305 85764/65
Fax +91 20 305 85775
Kochi
4/F, Palal Towers,
M. G. Road,
Ravipuram, Kochi 682016
Tel +91 (484) 302 7000
Fax +91 (484) 302 7001
Chandigarh
SCO 22-23
Ist Floor, Sector 8 C
Madhya Marg
Chandigarh 160019
Tel +91 72 3935 781
Fax +91 72 3935 780
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 on
such information without appropriate professional advice after a thorough examination of the particular situation.
2010 KPMG, an Indian Partnership and a member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (KPMG International), aSwiss entity. All rights reserved.
www.kpmg.com/in