Tax Insights

from India Tax & Regulatory Services

Amendments to the Finance Bill,

2016 as passed by the Lok Sabha

May 10, 2016

In brief
On 5 May, 2016, the Lok Sabha (Lower House) passed the Finance Bill, 2016 (Bill). For becoming law,
this Bill now has to get passed by the Rajya Sabha (Upper House) and thereafter obtain the Presidential
assent. While passing the Bill, however, 47 different amendments in respect of Direct Tax provisions in
the Bill as tabled originally were moved by the Finance Minister, Arun Jaitley, and all these
amendments were passed. In this News Alert, we have explained in tabular format the major changes
relating to Direct Taxes introduced just before the Lower House passed the Bill.

In detail
Clause Section Amendment Amendment as passed Comments
No in in as tabled in Lok Sabha by Lok Sabha
Finance Income- on 29 Feb 2016 on 5 May, 2016
Bill tax Act,
1961
Clause 3 Section 2 While the proposed Third proviso to section Originally, the period of
amendment was mentioned 2(42A) inserted. In case of holding of shares in a
in the Budget Speech of the unlisted shares, period of company for
Finance Minister however holding for transfer to be determination of the
no corresponding change considered as a short-term nature of capital gains
was brought in the Finance capital asset reduced from vis-à-vis long-term or
Bill 36 months to 24 months. short-term was 12
months. However this
period was extended to
36 months in the case of
unlisted companies by
Finance Act (no. 2) of
2014, which was
considered by many as a
retrograde step.
The current reduction in
period of holding for
unlisted companies from
36 months to 24 months
partly addresses this
perception and will help
corporates in business
restructuring.

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Tax Insights
Clause No Section in Amendment as tabled in
in Income-tax Lok Sabha on 29 Feb 2016
Finance Act, 1961
Bill
Clause 7 Section 10 Section 10 clause (12) amended Proposed amendment of
clauses (12) to provide that nothing in this clauses (12) and (13) of section
and (13) clause would apply to any
w.e.f. 1 April accumulated balance
2017 attributable to contributions
made on or after the 1st April,
2016 by employee other than
excluded employee, exceeding
40% of such accumulated
balance due and payable in
accordance with rule 8 of Part A
of the Fourth Schedule.
Section 10 clause (13) amended
to provide that payments in
commutation of annuity
purchased out of contributions
made on or after 1 April, 2016,
exceeding 40% of the annuity,
shall be chargeable to tax.
Clause 16 New section Expenditure for obtaining right
35ABA w.e.f to use spectrum for
1 April 2017 telecommunication services -
any capital expenditure incurred
and actually paid by a taxpayer
on acquisition of any right to use
spectrum for
telecommunication services
shall be allowed as a deduction
in equal instalments over period
starting from year in which such
payment has been made to year
in which useful life of spectrum
ends. Sub-sections (2) to (8) of
section 35ABB to apply as if for
the word “licence”, the word
“spectrum” had been
substituted
Explanation to define certain
expressions used for the
purposes of the said section.
This amendment will take effect
from 1 April, 2017 and will apply
in relation to assessment years
(AYs) 2017-2018 and onwards.
Clause 19 Section Where taxpayer incurs any
35CCC from expenditure on an agricultural
AY 2017-18 extension project notified by
to AY 2020- CBDT in accordance with
21 guidelines prescribed, then
PwC
Amendment as passed by
Lok Sabha
on 5 May, 2016
10 rolled back.
Sub-section (3) now introduced
to provide that if, in a previous
year, deduction under section
35ABA(1) has been granted and
after that, any provision of the
section has not been complied
with, the deduction would be
deemed to have been wrongly
allowed. The Tax Officer (TO)
is given the power to re-
compute the total income and
make the necessary
rectification. Limitation under
section 154(7) would be 4 years
counted from the date of non-
compliance with provisions of
this section.
Words, “or payable in such
manner as may be prescribed”
added at end of Explanation
(iii) to new section 35ABA. This
qualifies the phrase, “payment
has actually been made”, which
means that even if the payment
has been made in a manner
prescribed, the payment would
be treated as actually been
made only when there was
actual payment of expenditure.
Proposed reduction of the
deduction from 150% to 100%
has been deferred. Thus, the
deduction available would
continue to be a weighted
deduction @150% of qualifying
Comments
It was proposed to tax
withdrawal from the
accumulated balance (in
excess of 40%) in the
provident fund account,
which is attributable to
employee’s contribution
made on or after 1 April,
2016.
After a lot of public pressure
the Finance Minister has
rolled back the amendment,
which will act as a major
relief for salaried taxpayers.
The proposed amendment
seeks to grant power to the
TO to rectify the total income
of the taxpayer where any of
the conditions specified
therein are not complied
with. Such rectification can
be done within 4 years from
the end of the previous year
in which the failure to
comply with the condition
happens.
The proposed sunset clause
has been extended to AY
2020-21 as against the initial
proposal of ending it by AY
2017-18.
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Clause No Section in Amendment as tabled in Amendment as passed by Comments

in Income-tax Lok Sabha on 29 Feb 2016 Lok Sabha
Finance Act, 1961 on 5 May, 2016
Bill
deduction of 150% of such expenditure until AY 2020-21;
expenditure would be allowed. thereafter the same shall
reduce to 100%
It was proposed to reduce the
deduction to 100%. This
amendment was to take effect
from 1 April, 2018 and apply
from the AY 2018-2019 and
onwards.
New Clause Section 49 New sub-section (5) inserted in The FB 2016 introduced the
29A w.e.f. 1 April, section 49 w.e.f. 1 April, 2017 to Income Declaration Scheme,
2017 provide that if a capital gain 2016, where taxpayers can
arises from transfer of an asset declare their undisclosed
declared under the Income income by paying tax @45%
Declaration Scheme 2016, and of the FMV of gross
tax, surcharge and penalty have undisclosed income/ assets.
been paid in accordance with
The amendment introduced
the Scheme on the Fair Market
clarifies that cost of the asset
Value (FMV) of the asset on the
considered for future capital
date of commencement of the
gain computation would be
Scheme, then such FMV would
the FMV used for declaration
be deemed to be cost of
of income under the Income
acquisition of the asset.
Declaration Scheme.

Clause 41 New Section Amended to provide deduction
80-IAC w.e.f of 100% of profits and gains
1 April 2017 derived by an eligible start-up
from business involving
innovation, development,
deployment or
commercialisation of new
products, processes or services
driven by technology or IP, for
three consecutive AYs out of
five, at option of taxpayer, if
incorporated before 1 April,
2019.
Clause 43 New Section Deductions in respect of profits
80-IBA w.e.f and gains from housing project:
1 April 2017 100% deduction of profits and
gains of taxpayer developing
and building housing projects, if
project approved by competent
authority on or before 31 March
2019, subject to conditions.
Taxpayer has to complete the
project within 3 years, failing
which deduction claimed in
previous years shall be deemed
to be the taxpayer’s income.
Explanation (ii) of the This amendment is a very
proposed section amended to welcome step, as LLPs were
include limited liability gaining traction as the
partnerships (LLPs) in the preferred legal structure for
definition of “eligible startup”, doing business. Exclusion of
and LLPs are defined to as LLPs from the original
partnerships referred to in amendment would have
section 2(1)(n) of the Limited curtailed the benefit being
Liability Partnership Act, available to start-ups.
2008.
Words, ‘in accordance with Mostly, the changes are
such guidelines as may be improvements to the draft of
prescribed” deleted from clause the new section to head off
(a) of section 80-IBA(2). possible controversies or
block potential loopholes,
Words, “on which the project”
such as:
have been substituted by the
words, “on which the building  no specific guidelines for
plan of such housing project” housing project need be
in Proviso (i) below clause (b) notified
of section 80-IBA(2).
 distance from municipal
Clause (d) of section 80-IBA(2) limits shall be measured
re-drafted, and for the words, aerially
“within the area of twenty-five
kilometres from the municipal  ‘built-up area’ of the
limits of these cities”, the residential unit shall be
words, “within the distance, relevant.
measured aerially, of twenty-
five kilometres from the

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Clause No Section in Amendment as tabled in Amendment as passed by Comments

in Income-tax Lok Sabha on 29 Feb 2016 Lok Sabha
Finance Act, 1961 on 5 May, 2016
Bill
municipal limits of these cities”
substituted. Similar change
also made in section 80-IBA(2)
Clause (g)(i).
Clause (da) has been
introduced in section 80-
IBA(2) to provide an additional
condition that the project
should be the only project on
the plot of land specified in
clause (d).
Clause (e) has been re-drafted
to clarify that the built-up area
of the residential units should
not exceed 30 sq mts for a
project in the four metro cities
or “within the distance,
measured aerially, of twenty-
five kilometres from the
municipal limits of these cities”
In section 80-IBA(2)(g)(i), for
the words, “area other than the
areas”, the words, “place other
than the place” have been
substituted.
In section 80-IBA(3), the
words, “undertaking which”
have been substituted by
“taxpayer who”.
In section 80-IBA(5), the
words, “under any scheme for
the housing” have been
omitted.
In section 80-IBA(6)(b), the
words, “by the Central
Government” have been
substituted by the words, “to
approve the building plan by,
or under any law for the time
being in force”.
In section 80-IBA(6)(d), the
word, “dwelling” has been
substituted by the “word,
“residential” and the word,
“specify” substituted by the
word, “approve”.
Clause 46 Section Proposed to amend sub-section Reference to “clause (viii)” has The proposed change is
92CA: (3A) to provide that in certain been changed to “clause (x)” in correction of a referencing
Reference to circumstances as in clauses (ii) the proviso to new sub-section error with regard to
Transfer or (viii) of Explanation (1) to (3A) of section 92CA. extension of time limit of
Pricing section 153, if period of reference to the TPO,
limitation available to transfer wherein exchange of

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Clause No Section in Amendment as tabled in Amendment as passed by Comments

in Income-tax Lok Sabha on 29 Feb 2016 Lok Sabha
Finance Act, 1961 on 5 May, 2016
Bill
Officer: w.e.f. pricing officer (TPO) for making information has been called
1 June 2016 order is less than 60 days, such for under sections 90/ 90A.
remaining period shall be
extended to 60 days.
New Clause Section 111A: With effect from 1 April, 2017, While in the original Finance
47A Bill tabled by the Finance
 In section 111A(1), a second Minister amendment to
proviso has been inserted to section 10(38) relating to
exempt transactions on any long-term capital gains was
recognised stock exchange proposed so as to cover
located in any IFSC in financial instruments traded
foreign currency. on the IFSC platform within
 Explanation below section the tax exemption domain
111A(3) has been without levy of STT,
substituted to define the however, no corresponding
terms, “equity oriented benefit under section 111A
fund” (as per Explanation to relating to short-term capital
section 10 clause (38)), gains was granted.
“International Financial The same has now been
Services Centre” (as per corrected by this
section 2(q) of the SEZ Act, amendment.
2005) and “recognized
stock exchange” (as per
clause (ii) of Explanation 1
to section 43AA(5)).
Clause 49 New section Sub-section (1) provides that the Section 115BA(2)(b) has been Firstly the proposed
115BA : tax income-tax payable in respect of re-drafted thus: amendment clarifies that
on income of the total income of a domestic core incidental activities like
Words, “the company is
certain company, for any previous year research on the goods
engaged in the business of
domestic relevant to the AY beginning on manufactured or their
manufacturing or production
companies or after the 1st day of April, 2017 distribution would be
of any article or thing” replaced
w.e.f. 1 April shall, at the option of such covered as part of eligible
by “the company is not
2017 person, be computed at 25%, if business activity to avail the
engaged in any business other
the conditions contained in sub- reduced tax rate of 25%.
than the business of
section (2) are satisfied. Sub-
manufacturing or production Further the option to avail
section (2) provides that the
of any article or thing, research the 25% tax rate while giving
conditions referred to in sub-
in relation to, or distribution up other tax incentives has
section (1) are the following,
of, such article or thing been made an irrevocable
viz:– (a) the company has been
manufactured by it;”. choice.
set up and registered on or after
the 1st day of March, 2016; (b) Section 115BA(4) has been re-
the company is engaged in the drafted to provide that this
business of manufacturing or section won’t apply unless the
production of any article or option is exercised on or before
thing; and … due date specified under
section 139(1); and that once
Sub-section (4) provides that
exercised, the option cannot be
the option shall be exercised in
subsequently withdrawn.
the prescribed manner on or
before the due date specified
under section 139(1).
Clause 50 New section Current provisions of the Act Opening portion of sub-section The initial proposed section
115BBDA provide that dividend income (1) has been re-drafted. had certain interpretational
w.e.f 1 April will be exempt if dividend issues as to whether the
Instead of words, “income
2017 aggregate dividend received
exceeding INR 1 million”, the
by the individual needs to be

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Clause No Section in Amendment as tabled in Amendment as passed by Comments

in Income-tax Lok Sabha on 29 Feb 2016 Lok Sabha
Finance Act, 1961 on 5 May, 2016
Bill
distribution tax is paid on such words, “income in aggregate considered for the additional
income. exceeding INR 1 million” are tax or it needs to be seen
inserted. singularly from each
New section 115BBDA to
company. Further there were
provide that any income by way Also, instead of “such
doubts as to whether the
of dividend declared, distributed dividends, at the rate of”, the
additional tax applies on
or paid by a domestic company, words, “such dividends in
dividend income exceeding
in excess of INR 1 million shall aggregate exceeding INR 1
the INR 1 million limit or in
be chargeable to tax at 10% in million, at the rate of” are
its entirety.
case of an individual, HUF or a inserted.
firm resident in India. This amendment wards off
such possible disputes and
No deduction in respect of any
clarifies that the additional
expenditure or allowance or set
tax has to be seen with
off of loss would be allowed in
reference to the aggregate
computing the income by way of
dividend in excess of INR 1
dividend, and a defining the
million received from
term ‘dividends’.
multiple payers.
Clause 52 New section New section 115BBF introduced Sub-clauses (3) and (4) have Many developed economies
115BBF, with to provide that where total been added to proposed section had a special tax regime to
effect from 1 income of eligible taxpayer 115BBF, which ushers in an incentive R&D activities. The
April 2017 includes income by way of optional 10% presumptive tax Bill introduced India’s very
royalty in respect of a patent regime for royalty income for own ‘Patent Box’ regime
developed and registered in income from patents developed wherein the royalties earned
India, the income-tax payable and registered in India. from the patents developed
shall be tax calculated on the and registered in India were
An eligible taxpayer can
royalty income at 10%, and the to be taxed on a gross basis
exercise this option within time
tax which the taxpayer would @10%.
allowed for filing return under
have had to pay had his total
section 139(1). If the The amendment done by the
income been reduced by the
presumptive tax option is not Finance Minister clarifies
10% tax on royalty income as
opted for 5 years, then the that for the purposes of the
above.
option cannot be exercised for condition of the patents
Also, the taxpayer shall not be the next 5 years either. being “developed in India”
eligible for deduction of any 75% of the expenditure
Developed in India means that
expenditure or allowance under should be incurred in India.
at least 75% of expenditure
any provisions of the Act in This will help bring certainty
incurred for any invention with
computing his income referred and also addresses the
a granted patent is incurred in
to section 115BBF(1)(a). practical difficulty expressed
India.
by many companies of
An Explanation in section
Condition that the unit set up ensuring all expenses being
115BBF is inserted to define
in an IFSC now no longer incurred in India.
certain expressions used
needs to be set up on or after 1
therein.
April 2016.
Clause 53 Section New section 115JB(7) provides The condition of being One of the conditions to avail
115JB w.e.f. 1 that for a company, being a unit established on or after 1 April the reduced MAT rate of 9%
April, 2017 in an IFSC established on or 2016 removed. for units set up in the IFSC
after 1 April 2016 and deriving was that they need to be
its income solely in convertible established on or after 1
foreign exchange, tax rate would April 2016. This condition
be 9%. has been relaxed and
therefore the reduced MAT
rate of 9% grandfathers units
already set up in the IFSC
before 1 April 2016.

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Clause No Section in Amendment as tabled in Amendment as passed by Comments

in Income-tax Lok Sabha on 29 Feb 2016 Lok Sabha
Finance Act, 1961 on 5 May, 2016
Bill
Clause 60 New chapter Notwithstanding anything Two additional provisos added In order to ensure that the
including contained in any other provision to section 115TD(2) intended purpose of
new sections of the Act, a trust or institution exemption availed by a
i. to exclude accreted income
115TD, registered under section 12AA registered charitable trust is
attributable to asset
115TE and shall be liable to tax on accreted not misused, a new ‘exit tax’
acquired out of agricultural
115TF: Tax income in case of certain has been introduced on
income; and to asset
on certain eventualities, at maximum accreted income of such
acquired between trust/
accreted marginal rate, in addition to tax trust which was claimed
institution being established
income of chargeable in respect of total exempt from tax in earlier
and the date on which its
certain income. Other provisions years.
registration under section
trusts and include providing for asset
12AA became effective. For the purpose of
institutions, valuation, making exceptions to
computation of accreted
w.e.f. 1 June certain assets, forms of ii. If exemption given to trust
income, assets purchased out
2016 conversion making trust for previous year before
of agricultural income, being
ineligible for registration, how registration under section
not chargeable to tax, or on
additional tax is calculated, 12AA became effective, due
account of assets purchased
when to pay tax, and provisions to operation of first proviso
prior to availing any
for interest for delayed payment to section 12A(2),
exemption shall be excluded.
and penalty for failure to pay the registration deemed to be
additional tax. effective from earlier Further, the time limit for
previous year. payment of taxes on accreted
income has also been
Two more changes in date by
relaxed.
which additional tax has to be
paid in case of cancellation of
registration of trust/
institution, merger or rejection
of application.
Clause 66 Section 143: Proviso inserted after section Section 143: New sub-section Originally all tax returns
Assessment, 143(1D) (1D), and proviso thereto, were required to be
changes inserted. processed under section
w.e.f. 1 June, 143(1) within a time frame of
Processing of return not
2016 1 year from end of the
necessary before expiry of 1
relevant AY. Thereafter vide
year from end of FY in which
Finance Act 2012 an
return is made, where notice
amendment was brought in
has been issued under section
whereby processing of tax
143(2), but has to be completed
returns was not mandatory
before issue of order under
where the case of the tax
section 143(3).
payer has been selected for
scrutiny assessment.
Vide the current Finance Bill
processing of tax returns
even in cases of scrutiny
selection was made
mandatory before passing of
the final assessment order.
The Finance Bill as passed by
the Lok Sabha now provides
that the time limit of one
year shall not be applicable
for processing of tax returns,
though it is mandatory to
process the tax return before

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Clause No Section in Amendment as tabled in Amendment as passed by Comments

in Income-tax Lok Sabha on 29 Feb 2016 Lok Sabha
Finance Act, 1961 on 5 May, 2016
Bill
passing the final assessment
order under section 143(3).
Clause 81 Section Proviso added - if payee is non- A proviso has been inserted
194LBB: company non-resident or a so as to provide that where
TDS on foreign company, no TDS is income of the non-resident is
income from required under section 194LBB not chargeable to tax, no tax
units of on income on which no tax is shall be deducted in such
investment chargeable. cases (for instance in case of
fund, w.e.f.1 tax treaty benefit being
April, 2016 availed).
Clause 86 Section Proposed that seller to collect Instead of being included as The Finance Bill, 2016
206C: Tax the tax at 1% on sale of motor additional item in the Table brought the sale of motor
Collection at vehicle of value exceeding INR 1 under section 206C(1), this vehicle (value exceeding INR
Source million w.e.f. 1 June 2016. proposal now has its own sub- 1 million) within the ambit of
section – (1F); with TCS, which is proposed to be
consequential changes. collected by seller at the time
of debiting the amount
receivable or at the time of
receipt, which is earlier.
Now, the Finance Bill, 2016
as passed by the Lok Sabha
provides that tax shall be
collected on sale of motor
vehicle only at the time of
receipt of consideration.
Further in the original
Finance Bill 2016 there was
an exclusion on account of
purchase of motor vehicle for
personal consumption,
which has not been provided
in the Bill as passed by the
Lok Sabha.
Clause 96 New section Bill seeks to insert section 270A Following amendments have The Finance Bill 2016
270A w.e.f.1 in the Income tax Act relating to been approved by Lok Sabha: introduced a new penalty
April, 2017 penalty for under-reporting and scheme vide section 270A.
One more instance of under-
misreporting of income. This basically bifurcated the
reporting of income is added.
cases liable for imposition of
Rate of penalty proposed is 50%
Section 270 A(2), new clause penalty into two parts, viz:
of tax in case of under-reporting
(f) inserted : Person is deemed cases involving under
of income, and 200% of tax in
to have under-reported his reporting of income and
case of misreporting of income.
income if total income cases involving mis-
What constitutes under- reassessed as per section 115JB reporting of income.
reporting of income: The or section 115JC (MAT or
The Finance Bill as passed by
Finance Bill, 2016 proposed six AMT) is greater than deemed
the Lok Sabha adds on
instances where a person shall total income assessed/
another situation for under-
be deemed to have reassessed under MAT or the
reporting of income wherein
underreported his income. AMT immediately before such
penalty can be levied on
reassessment.
account of reassessed
Section 270A(2), earlier clause income being under MAT
(f) re-numbered as clause (g). provisions.
Section 270A(6) : Principal Further, the definition of ‘tax
Commissioner also added to payable’ in respect of under-

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Clause No Section in Amendment as tabled in Amendment as passed by Comments

in Income-tax Lok Sabha on 29 Feb 2016 Lok Sabha
Finance Act, 1961 on 5 May, 2016
Bill
list of officers who can record reported income has also
satisfaction re bona fide been amended to classify the
explanation given by taxpayer. cases in the following three
buckets:
Section 270A(10): How to
calculate tax payable in three  Where tax return has not
different scenarios. been furnished.
 In case of loss determined
on the basis of processing
of tax return or
assessment /
reassessment.
 In any other cases.
Clause 97 New section The taxpayer may apply to TO Immunity application can Immunity from initiation of
270AA: for grant of immunity from cover immunity from prosecution proceedings has
Immunity penalty under section 270A and prosecution under section been extended to cases
from s.270A prosecution under section 276C, 276CC as well. covered by section 276CC
penalty/ provided he pays tax and which provides for
prosecution interest payable as per prosecution in case of failure
assessment order within period to furnish the income tax
specified in demand notice and return.
does not appeal against the
order.
New Clause S 276C Amends section 276C w.e.f. 1 With the introduction of the
106A April, 2017 to cover cases of new penalty scheme in
under-reporting of income relation to under reporting
(new section 270A) as well. of income, referencing has
been made in section 276C
which provides for
prosecution in case of
evasion of taxes.
Clause 112 Fourth Rule 6 of Sch. IV inter alia Proposed amendment to tax It was proposed to tax the
Schedule provides that contributions the employer contribution to employer contribution in the
Part A , w.e.f. made by employer to credit of provident Fund in excess of provident fund, in excess of
1 April, 2017 employee participating in a INR 150,000 has been rolled RINR 150,000 made on or
recognised provident fund over back. after 1 April, 2016.
12% of employee’s salary or INR
The Finance Bill, 2016 as
150,000, whichever is less, is
passed by the Lok Sabha
taxable in employee’s hands.
withdraws such amendment
and maintains the status-
quo for the taxability of
employer’s contribution to
provident fund.
Clause 192 References to section 119 and The Finance Bill 2016
section 138 of the Income-tax introduced the Income
Act included. Declaration Scheme, 2016
where taxpayers can declare
their undisclosed income by
paying tax @45%.
This Scheme also provides
for applicability of
machinery provisions of

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Clause No Section in Amendment as tabled in Amendment as passed by Comments

in Income-tax Lok Sabha on 29 Feb 2016 Lok Sabha
Finance Act, 1961 on 5 May, 2016
Bill
Income-tax Act and Wealth-
tax Act to the Scheme.
Now, the bill passed by Lok
Sabha also made referencing
to section 119 (Instruction to
subordinate authorities) and
section 138 (Disclosure if
information respecting
taxpayer) to the Scheme.

Let’s talk
For a deeper discussion of how this issue might affect your business, please contact:
Tax & Regulatory Services – Direct Tax
Gautam Mehra, Mumbai Rahul Garg, Gurgaon
+91-22 6689 1154 +91-124 330 6515
gautam.mehra@in.pwc.com rahul.garg@in.pwc.com

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Tax Insights

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countries with more than 208,000 people who are committed to delivering quality in assurance, advisory and tax
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In India, PwC has offices in these cities: Ahmedabad, Bangalore, Chennai, Delhi NCR, Hyderabad, Kolkata, Mumbai
and Pune. For more information about PwC India's service offerings, visit www.pwc.com/in

PwC refers to the PwC International network and/or one or more of its member firms, each of which is a separate,
independent and distinct legal entity in separate lines of service. Please see www.pwc.com/structure for further
details.

©2016 PwC. All rights reserved

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This publication has been prepared for general guidance on matters of interest only, and does not constitute professional advice. You should not act upon the information
contained in this publication without obtaining specific professional advice. No representation or warranty (express or implied) is given as to the accuracy or completeness
of the information contained in this publication, and, to the extent permitted by law, PwCPL, its members, employees and agents accept no liability, and disclaim all
responsibility, for the consequences of you or anyone else acting, or refraining to act, in reliance on the information contained in this publication or for any decision based
on it. Without prior permission of PwCPL, this publication may not be quoted in whole or in part or otherwise referred to in any documents.

© 2016 PricewaterhouseCoopers Private Limited. All rights reserved. In this document, “PwC” refers to PricewaterhouseCoopers Private Limited (a limited liability company
in India having Corporate Identity Number or CIN : U74140WB1983PTC036093), which is a member firm of PricewaterhouseCoopers International Limited (PwCIL), each
member firm of which is a separate legal entity.