Trade facilitation –Surmounting the Deadlock

Erudition ‘ 06, 11th Annual Convention, Department of commerce, Delhi School of Economics,28 October 2006, PHD Chambers of Commerce & Industry, New Delhi

Karnika Seth,

Attorney at law & Partner

SETH ASSOCIATES

ADVOCATES AND LEGAL CONSULTANTS

Introduction

Trade facilitation (TF) aims to make trade procedures as efficient as possible through the simplification and harmonization of documentation, procedures and information flows

Includes several inter-related factors such as customs and border agencies, transport infrastructure services and IT (as it relates to better logistics), regulatory environment, product standards, tariff rates etc.

Easier movement of goods and services has several benefits Reduced costs for businesses Increased predictability and transparency Better revenue collection, and improved security and

control by governments

Introduction (contd.)

Systematic rationalization of procedures and documentation for international trade (UN ECE definition).

In WTO context, it means issues covered under GATT Articles V, VIII and X.

Would essentially cover subjects relating to importation and exportation: fees and charges; formalities; documentation; publication of laws; judicial and administrative tribunal; transit.

GATT Article V

GATT Article V deals with freedom of transit of goods.

The term “traffic in transit” implies movement of goods and means of transport (other than aircraft) across the territory of the country, where both the starting and the terminating point of the journey lies beyond it.

There should be freedom of transit via the routes most convenient for international transit.

GATT Article V (contd.)

No distinction shall be made on the basis of flag of vessels, the place of origin, departure, entry, exit or destination, ownership of goods or means of transport.

The charges imposed on traffic in transit shall be reasonable and will be on MFN basis.

GATT Article VIII

GATT Article VIII deals with fees and formalities connected with importation and exportation. Its important elements are:

All fees and charges (other than import and export duties) imposed in connection with importation and exportation shall be limited to the approximate cost of services rendered. It should not represent an indirect protection to domestic products or a taxation of imports or exports.

The number and diversity of fees for above purposes should be reduced.

GATT Article VIII (contd.)

There is a need to minimize the incidence and complexity of import/export formalities and to decrease and simplify import/export documentation requirements.

Substantial penalties should not be imposed for minor breaches of customs regulations or procedural requirements

The provision of this Article shall extend to fees, charges, formalities and requirements imposed by government authorities in connection with importation and exportation.

Illustrative list of areas where this would be applicable: consular transactions, such as consular invoices and certificates; quantitative restrictions; licensing; exchange control; statistical services; documents, documentation and certification; analysis and inspection; quarantine, sanitation and fumigation.

GATT Article X

GATT Article X deals with publication and administration of trade regulations. It lays down:

Various laws, regulations, judicial decisions and administrative rulings relating to various customs related issues for clearance of goods (classification or valuation; rates of duties; requirements, restrictions or prohibitions on imports/exports) shall be published promptly by the contracting parties to enable governments and traders to become acquainted with them.

GATT Article X (contd.)

No increase in rate of duty or a more burdensome requirement, restriction or prohibition on imports shall be enforced before such measure has been officially published.

Each contracting party shall administer the laws of the above kind in a uniform, impartial and reasonable manner

GATT Article X (contd.)

The contracting parties shall maintain judicial, arbitral or administrative tribunals for prompt review and correction of administrative action relating to customs matters.

Such tribunals shall be independent of the agencies entrusted with administrative enforcement

Barriers to Trade Facilitation

excessive data /documentation requirements Red-tapism High release and clearance times Antiquated customs techniques and inefficiencies leading to

high logistics costs Absence of co-ordination between customs and other agencies Inadequate transit regimes Corruption Regulatory/administrative barriers in establishing and operating

new businesses Port congestion Scarce use of IT Lack of quick legal redress Unattractive tariff regimes

The import timeline…

Only 25% of time taken to import

(in days) is consumed in transportation

12

13

16

59

Port and TerminalHandling

Inland Transport

Customs andInspection

Prearrival documents

Source: World Bank Doing Business 2006

Typical Cargo Dwell TimeInternationalIndia

Less than 24 hrs7-14 daysImport Dwell Time

Less than 18 hrs3-5 daysExport Dwell Time

Less than 6 hrs3-5 daysShip Waiting Time

Less than 12 hrs8 daysImport

Less than 12 hrs2.5 daysExport

MumbaiContainerized Sea Freight

Delhi airportAir Freight

NormLocationTransaction

Source: Jayanta Roy “ Towards International Norms for Indirect Taxes and Trade Facilitation in India” Background paper prepared for the Task Force on Indirect Taxes, Government of India, October 2002

Trade Facilitation-GATT-Important Proposals Made94 written contributions made so far- about 60 deal with the first

aim proposals made by countries like EC, US, Canada, Japan,

Switzerland, China, Korea, Uganda, Rwanda, Paraguay, Mongolia, Argentina, India etc. Compiled in TN/TF/W/43/Rev.5

Transparency Publication of all border related laws, regulations, procedures

and practices (Gazettes, Internet) Time interval between publication of rules and entry into force Prior consultation and commenting on new and amended rules Information on policy objectives Enquiry point Advance Ruling Right of appeal/Release of goods in event of appeal Maintenance of integrity amongst officials

Important Proposals Made (Contd.)Simplification of fees fees be relatable to service provided and not

be ad valorem Publication/Notification of fees/charges Prohibition on collection of unpublicized

fees Periodic review of fees/charges Automated payment Reduction/minimization of the number and

diversity of fees and charges

Important Proposals Made (Contd.)Simplification of procedures and documentation Risk management Post clearance audit Single Window/one time submission Border agency coordination Authorized trader system Automation of customs Acceptance of commercially available information and

copies of documents Use of international standards Pre arrival clearance Expedited procedures for express shipments Separating Release from Clearance Procedures Periodic Review of Formalities and Requirements

Important Proposals Made (Contd.) Establishment and publication of

average release and clearance times Abolition of pre-shipment inspection,

consular invoices and compulsory use of brokers

Objective criteria for tariff classification Publication of fees and charges and

prohibition of unpublished ones Periodic review of fees and charges

Important Proposals Made (Contd.)

Transit formalities and documentation requirements

Give choice of route to operators Reduction/Simplification of procedures Harmonization/Standardization Promotion of regional transit

arrangement Simplified and preferential clearance for

certain goods

Important Proposals Made (Contd.) Whether transit of oil and gas through pipeline

and electricity through grid could come under Article V (in addition to air, road, rail and boat)

Non-discrimination between individual carriers and types of consignments for transit procedures

Movement of goods from one part of a country to another through a foreign country be recognised as movement in transit

Proposals made by India

GATT Art. VIII Members of a Customs Union (CU) should

adopt the same border procedures- this should include adoption of same standards, including specifications, terminologies, and definitions, inspection, sampling, and test methods, for border clearance of agriculture and food products

Testing methods should be based on specific product features and its physical state at the point of consumption, such as ‘fresh’, ‘dehydrated’, or ‘otherwise processed’.

Proposals made by India

All forms and documentation requirements relating to import clearance should be uniform for all members of a CU

In case of rejection of a consignment to meet certain standards, an option would be first given to return the rejected good to the exporter and only upon failure to exercise this option within a reasonable period of time, any other course of action, including destruction of goods could be considered

Norms of authorised trader system shall be applied uniformly across a CU

Proposals made by India

To the extent possible, a harmonised risk management system would be adopted across the entire CU

GATT Article X Import alert/rapid alert be imposed all across a

CU only if all members apply uniform standards Rapid alert be lifted if [x] successive

consignments imported from a country/exporter fulfill the prescribed standard

The speed and standard of publicity of denotification of such alert shall be of same level as its issuance

Proposals made by India

When goods are detained for inspection by customs or any other authority, there should be a mechanism to inform the importer regarding such detention-either by issuing detention memo or through an on-line system

Each member should allow importer or exporter a right of a second confirmatory test of a sample where the first test result has given an adverse finding

Technical Assistance/Capacity Building-India's recommendation

Identify important areas where a large number of developing countries require TA

Prepare an inventory of current TA work being done by donors in these identified areas-ascertain willingness of donors to extend TA-put up the information on specially created WTO website

Attempt a coordinated approach to achieve coherence

Indian Economy – An Overview Economic Performance

Sustained economic growth Average last 10 years 6.5% 2004-05 6.9% Forecast up to 2006-07 >7.0% Forecast till 2050 – Goldman Sachs 5 % p.a.

Services share in GDP over 50% (52.4% share in GDP in 2004-05) Manufacturing sector grew at 8.8% in 2004-05 (17.4% share in GDP in

2004-05) Foreign Trade

Merchandise exports grew by 25% in 2004-05, now US$80 billion Imports grew by 36%, now US$106 billion

Investment Foreign Investment – over US$14 billion in 2004-05 (FDI US$5.5

billion, FII US$8.9 billion) Mature Capital Markets

NSE third largest, BSE fifth largest in terms of number of trades A well developed banking system

Economic Reforms- Fiscal

Rationalization of tax structure – both direct and indirect

Progressive reduction in peak rates Peak Customs duty reduced to 15% Corporate Tax reduced to 30% Customs duties to be aligned with ASEAN levels

Value Added Tax introduced from 1st April 2005-

Fiscal Responsibility & Budget Management Act, 2003 Revenue deficit to be brought to zero by 2008

Economic Reforms: Liberalisation of Investment & Trade Policies Industrial Licensing

Progressive movement towards delicensing and deregulation

Licensing limited to only 5 sectors (security, public health & safety considerations)

Foreign Investment Progressive opening of economy to FDI Portfolio investment regime liberalised Liberal policy on technology collaboration

Trade Policy Most items on Open General License, Quantitative

Restrictions lifted Foreign Trade Policy seeks to double India’s share in

global merchandise trade in 5 years

Trade Policies in India

Exim Policies

Streamlined trade procedures

Liberalised import regime

Thrust on export orientation

Medium Term Export Strategy, 2002

1% share in global exports by 2007

Foreign Trade Policy 2004-2009

To double India’s share in global

merchandise trade by 2009

International Trade and India

International Trade of Select Countries in 2003

Country Exports Imports GDP Trade as % of GDP(US$ bn.) (US$ bn.) (US$ bn.)

Korea 197.6 175.5 605.0 61.7China 438.3 393.6 1446.9 57.5Mexico 165.4 171.0 626.1 53.7Russia 135.9 75.4 433.5 48.7South Africa 38.7 35.0 160.1 46.0Argentina 29.4 13.1 129.7 32.8Brazil 73.1 48.3 492.1 24.7India 57.0 74.3 588.8 22.3Source: Economist Intelligence Unit

India’s share in global merchandise exports: 0.8% (2003)

India’s Export Performance

India's Export Performance (1999-2000 to 2003-04)

63623

47742

52856

439764414736760

29751

0

10000

20000

30000

40000

50000

60000

70000

1999-2000 2000-01 2001-02 2002-03 2003-04

Years

US$

mill

ion

All Commodities Agricultural & allied productsOres & minerals Manufactured goodsPetroleum & crude products

Source: DGCIS, MOC&I

Foreign Trade Policy 2004-2009

Simplifying procedures and bringing down transaction costsTransaction costs are incurred at the pre and post-production stages, and arise out from several procedural complexities associated with administrative processes, availability of finance and transportation problems.

For enhancing the growth of exports it is important to reduce the transaction costs involved. Exim Bank Study on Transaction Costs of Indian Exports

Findings of Exim Bank’s Study

Sector No. of Firms

Transaction costs as % of export revenue (2003

Survey)

Transaction costs as % of

export revenue (1998 Survey)

 Textile/Garments 23 3-10 15

Engineering goods 18 < 5 10

Pharmaceuticals 9 8 10

Chemicals 7 < 5 14

Computer software 9 1-5 10

Agro-Industries 2 1-2 7-8.5

Electronic & Electrical machinery

3 5 -

Plastic components 2 5-10 -

Paper Industry 2 5-7 -

Others 7 1-2  

India’s Import Performance

Source: DGCIS, MOC&I

India's Import Performance (1999-2000 to 2003-04)

77237

566135158850056

61572

49799

37172

0

10000

20000

30000

40000

50000

60000

70000

80000

90000

1999-2000 2000-01 2001-02 2002-03 2003-04

Years

US$

mill

ion

All Commodities Petroleum crude & products Non-POL items

Potential for Increased exports

Exim Bank Study “Strategy for Quantum Jump in Exports: Focus

on Africa, Latin America and China”

India could aim to achieve:

US$ 18 billion in Africa’s Imports by 2007 from US$ 3.8 bn

in 2003-04

US$ 4 bn in China’s imports by 2007 (in 64 identified

groups) from US$ 0.86 bn in 2000

US$ 1.8 bn in LAC’s imports by 2007 (in 100 identified

groups) from US$ 0.6 bn in 2000

Share in India’s Exports in 2003-04: Africa (6%); Latin

America (1.8%); China (4.7)

Advantages

IT –ITES Industry Exports US$17.2 billion in 2004-05, growth of

34% over previous year 2008 exports target : US$60 billion, to be

35% of India’s total exports

High quality standards 76 SEI/CMM level 5 companies, two third of

world’s total, are Indian Over 250 of the Fortune 500 companies are

clients of Indian firms R&D base of over 100 FORTUNE 500

companies

Investment Opportunities • Collaborative ICT research • Joint Software development in a variety of

applications Source: NASSCOM

IT- ITES ExportsIn US $ Billion

6.2

10

12.8

17.2

8

0

2

4

6

8

10

12

14

16

18

20

2000-01 2001-02 2002-03 2003-04 2004-05

Evolution of FDI Policy

1991

1997

2000

Allowed selectively up to 40%

Up to 74/51/50% in 112 sectors under theAutomatic Route 100% in some sectors

Up to 100% under Automatic Route in all sectors except a small negative list

More sectors opened ; Equity caps raised in many other sectors Procedures simplified

FDI Policy

Liberalization

FDI up to 51% allowed under the Automatic route in 35 Priority sectors

Factors facilitating FDI

Availability of skilled manpower Politically stable economy Strong macroeconomic fundamentals Effective legal and regulatory system Flexible labor laws Trade Facilitation businesses rank customs procedures as most important impediment to

trade, followed by administrative regulations, and then tariffs Simple and predictable customs procedures Sound infrastructure network Reliable Logistics

Ability to maintain reliable, low-cost flow of raw materials and components

An effective distribution system efficient transport and logistic services are crucial for export competitiveness

and FDI- Increased private-public sector collaboration

Recent changes in FDI Policy

FDI up to 74% is permitted for the following telecom services subject to licensing and security requirements:

a. Internet service providers with gateways; b. Radio paging; and c. End-to-end bandwidth Proposals with FDI beyond 49% shall require

prior Government approval. FDI up to 49% from all sources is permitted in

the banking sector on the automatic route subject to conformity with guidelines issued by RBI from time to time.

Recent changes in FDI Policy

FDI up to 100% is permitted on the automatic route for Mass Rapid Transport Systems in all metropolitan cities, including associated commercial development of real estate.

NRI investment in foreign exchange is made fully repatriable whereas investments made in Indian rupees through rupee accounts shall remain non-repatriable.

Recent changes in FDI Policy

FDI up to 100% is permitted for development of integrated townships, including housing, commercial premises, hotels, resorts, city and regional level urban infrastructure facilities such as roads and bridges, mass rapid transit systems; and manufacture of building materials. Development of land and providing allied infrastructure will form an integral part of township’s development, for which necessary guidelines/norms relating to minimum capitalisation, minimum land area, etc., will be notified separately by the Government. FDI in this sector would be permissible with prior Government approval.

FDI up to 100% is permitted on the automatic route in hotel and tourism sector.

Recent changes in FDI Policy

FDI up to 100% is permitted on the automatic route for manufacture of drugs and pharmaceutical, provided the activity does not attract compulsory licensing or involve useof recombinant DNA technology and specific cell / tissue targeted formulations. FDIp roposals for the manufacture of licensable drugs and pharmaceuticals and bulk drugs produced by recombinant DNA technology and specific cell / tissue targeted formulationswill require prior Government approval.

FDI up to 100% is permitted in airports, with FDI above 74% requiring prior approval of the Government.

Economic Reforms: Exchange Control & Taxation

Exchange Control All investments are on repatriation basis Original investment, profits and dividend can be freely

repatriated Foreign investor can acquire immovable property

incidental to or required for their activity Rupee made fully convertible on current account

Taxation Companies incorporated in India treated as Indian

companies for taxation Convention on Avoidance of Double Taxation with 65

countries

Manufacturing competitiveness Second most attractive destination for manufacturing

ATKearney’s FDI Confidence Index 2004 Indian industry globally competitive in a wide range of

manufacturing skill-intensive products: Apparels, electrical and electronics components;

speciality chemicals; pharmaceuticals; etc. Automotive components: Major MNC’s & their OEMs

sourcing high-quality components from India Volvo, GM, GE, Chrysler, Ford, Toyota, Unilever,

Cliariant, Cummins, Delphi Indian companies now having manufacturing presence in

many countries Over 55% of approved outward investment by India

companies in manufacturing activities

India: FDI Outlook

2nd most attractive investment destination among the Transnational Corporations (TNCs) - UNCTAD’s World Investment Report, 2005

3rd most attractive investment destination – AT Kearney Business Confidence Index, 2004

Up from 6th most attractive destination in 2003 and 15 th in 2002 2nd Most attractive destination for manufacturing

Among the top 3 investment ‘hot spots’ for the next 4 years UNCTAD & Corporate Location – April 2004

Most preferred destination for services - AT Kearney’s 2005 Global Services Location Index (previously Offshore Location Attractiveness Index)

Draft Approach Paper to the Eleventh Five Year Plan (2007-08 to 2011-12) suggests that the economy can grow between 8 and 9 per cent per year

Trade agreements

Asia Pacific Trade Agreement (APTA) Trade Agreement with Japan, China, Korea, Pakistan,

Bangladesh, Maldives, Bhutan, Mongolia etc. Comprehensive Economic Cooperation Agreement

(CECA) with Singapore. Framework Agreement with The Member States of the

Cooperation council for the Arab States of the Gulf (GCC).

Framework Agreement with ASEAN, Thailand & Chile. PTA with Afghanistan, Chile , Mercosur. FTA with Sri Lanka.

India & EU Trade Relations

EU is India's largest trading partner, with two-way trade touching about 40 billion Euros last year and growing by 20 per cent .

In September 2005 it was decided to launch a High Level Trade Group (HLTG) to explore ways and means to deepen and widen the bilateral trade and investment relationship.

India and the European Union on 13th Oct 2006 agreed to begin negotiations on a Trade and Investment Agreement to lower tariff barriers and make investment flows easier.

The proposed agreement involved huge cuts in import duties and would cover 90 per cent of tariff lines over a period of time

India & EU Trade Relations

The agreement will cover trade in goods, services, investment, trade facilitation .etc.

It would open prospects for Indian agricultural exports to Europe, besides textiles, leather, gems and jewellery, chemicals and steel.

Transparency in laws and recognition of degrees will also be incorporated in the agreement .

The HLTG had suggested that the agreement be completed in a year but this time-frame looked like a "hard call". The outer limit for concluding the pact is two years.

Recent Infrastructure Initiatives

National Highway Development Programme to develop over 24,000 km of highways

Golden Quadrilateral NSEW Corridor Links to ports and State capitals

Modernisation of airports Metro and other airports

Development of ports with private sector The Electricity Act, 2003 provides the framework for development of

power sector ‘Bharat Nirman’ Programme to develop rural infrastructure at an

estimated cost of Rs. 1,74,000 crore (~US$40 billion) Jawhar Lal Nehru Urban Renewal Mission –Rs. 100,000 crore (US$22

billion) Country wide rural connectivity programme to link all unconnected

village having population of 500 with fair weather road undertaken

Roads

Policy FDI up to 100% is permitted for construction and maintenance

of roads, highways, vehicular bridges, toll roads, vehicular tunnels

Ten year tax holiday for road and highway projects Recent Initiatives

Existing road network of 3.3 million kilometers 24,000 km of Highways being developed under National

Highway Development Programme Golden Quadrilateral : 5846 kms- 5000 kms completed NSEW Corridor: 7300 kms – 784 kms completed, 3691 kms under

implementation Investment US$20 billion envisaged

Investment Opportunities Projects for 12,000 km would be on offer Many more opportunities in the States

Ports

Policy & Incentives FDI up to 100% permitted for construction and

maintenance of ports and harbours. Ten year tax holiday

Public-private partnership 12 major ports, 185 minor ports 14 private/ captive projects with investment of US$ 600

million completed 24 projects with investment of US$1.6 billion under

implementation/award Investment requirement of US$22 billion to develop

maritime sector Ports & Shipping Inland waterways

Telecommunications

Among the fastest growing telecom markets 550,000 km of optical fibre cable laid

2 million Cellular phones added every month Among the lowest mobile tariff in the world

Share of private sector 50% Tele-density of 10.66, expected to be 20 in next three years New Broad Band Policy announced:

690,000 connections since April 2005 Internet subscribers 6 million (March 05)

Investment Opportunities Setting up manufacturing facilities; Supply of hand sets and equipments Telecom & Value added service.

Food processing

Third largest producer of food items Largest milk producer Largest livestock population; 2nd largest in fruits & vegetables

Opportunities in food processing sector 50% of household income spent on food items With increasing income levels and urbanisation fast growth in demand

of processed food expected; over 250 million strong middle class Low levels of value addition in food sector: only 7%

New Integrated Food Law being enacted Investment of US$ 28 billion required to raise food processing from 2%

to 8-10%. Investment opportunities in

Processing of fruit & vegetable, meat, fish & poultry, milk products, packaged food & drinks.

Establishing infrastructure, cold chain, etc.

SEZ Act

Policy Duty free zones, deemed foreign territories FDI up to 100% permitted in almost all

manufacturing activities Transfer of goods from DTA to SEZ treated as

exports, Units to be net foreign exchange earner within 5

years. No export commitments No limits on DTA sales Can be set up in the public, private or joint sector Single Window Clearance

SEZs

Incentives For developer: Income tax exemption for a block of

10 years in 15 years For units: 100% Income Tax exemption for first 5

years, 50% for next 5 years and 50% of the ploughed back export profits for next 5 years

Exemption from indirect taxes; excise, sales, services tax, etc.

Freedom to raise ECB with out any maturity restrictions

SEZs

11 Special Economic Zones are functional SEEPZ Mumbai, Kandla, Cochin, Chennai,

Visakhapatnam, Falta, NOIDA, Surat, Salt Lake, Indore and Jaipur

Over 800 functional units employing over 100,000 persons

Exports of US$4 billion in 2004-05 42 new Special Economic Zones have been approved

and are under establishment Many have participation with State Governments and

Private Sector Major Industries in Special Economic Zones

Gems & Jewellery, Electronics & Hardware, Software, Textile & Garment, Engineering Goods, Sports Goods, Leather Products, Chemicals & Allied Products

Incentives for the Development of Industrially Backward Areas

A special package of incentives to promote industrilisation of industrially backward regions North Eastern states, Sikkim, Jammu & Kashmir,

Uttaranchal and Himachal Pradesh

Incentives 100% Income Tax Exemptions for 10 years Excise Duty Exemptions for 10 years Transport Subsidy for transportation of raw material

and finished products, Investment Subsidy (50-90%)

Governance - Initiatives

Major e-governance initiatives undertaken at Central and State level National e-Governance Action Plan

Projects being taken up in Mission mode at Central and State level. Integrated services projects for services across Departments. MCA-21 - Ministry of Company Affairs, to cover all Registrar of

Companies by June 2006 e-Biz project being taken up by the Department of IPP

To set up a web enabled portal to provide for the services at the Central, State and Local level during the entire life cycle of business

To begin with a pilot project covering 25 services in four states Project capable of rapid upscaling to cover other services and extend

to other areas Right to Information Act for greater transparency in public administration

Investment opportunities-Snapshot Development and management of

infrastructure Food processing, including logistic and

support services, development of cold chain

Manufacturing – relocation into India R&D – leveraging on abundant skilled

manpower IT & ITES, Software as well as hardware

Conclusion

Business transaction costs can be reduced by cutting red tape, embracing automation, harmonizing standards and eliminating unnecessary barriers to trade.

More FDI does not automatically transfer into higher growth: a country also needs good policies and strong institutions.

Investment in TF measures is necessary for a holistic investment climate.

Governments should continue to explore opportunities for future partnership with the private sector in the development and execution of trade facilitation programs.

Conclusion

TF is essentially about domestic capacity building, not multilateral rules.

Multilateral cooperative action at national and regional levels, is required to assist developing countries in building the capacity to implement trade facilitation.

Thank You!

SETH ASSOCIATESSETH ASSOCIATES ADVOCATES AND LEGAL CONSULTANTSADVOCATES AND LEGAL CONSULTANTSNew Delhi Law OfficeNew Delhi Law Office: C-1/16, Daryaganj, New Delhi-110002, India: C-1/16, Daryaganj, New Delhi-110002, IndiaTel:+91 (11) 65352272, +91 9868119137Tel:+91 (11) 65352272, +91 9868119137Corporate Law OfficeCorporate Law Office: B-10, Sector 40, NOIDA-201301, N.C.R ,India: B-10, Sector 40, NOIDA-201301, N.C.R ,IndiaTel: +91 (120) 4352846, +91 9810155766Tel: +91 (120) 4352846, +91 9810155766Fax: +91 (120) 4331304Fax: +91 (120) 4331304E-mail: E-mail: mail@sethassociates.com