TAX

OPPI Knowledge Series
Impact of Direct Taxes Code Bill 2010
September 2010
KPMG IN INDIA

Agenda
1 2 3 4 5 6 7 8 9 Background Corporate Tax Personal tax Capital Gains Overview – Sources of Income International Taxation Branch Profits Tax Transfer Pricing MAT

10 Deduction for Scientific R & D allowance 11 Tax Incentives - Others 12 SEZs / SEZ Units 13 Business income 14 DDT Credit 15 Wealth tax 16 CFC 17 Hits & Misses / Key focus areas for MNCs
© 2010 KPMG, India Private Limited, an Indian private limited companynetwork of independentthe KPMG network of independent member firms affiliated with KPMG International, a © 2010 KPMG an Indian Partnership and a member firm of the KPMG and a member firm of member firms affiliated with KPMG International Cooperative (“KPMG International”), a Swiss entity. All All rights reserved. Swiss cooperative. rights reserved.

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Background
       DTC 2009 unveiled in August 2009 The Government received over 1,600 representations on DTC 2009 RDP released in June 2010 on 11 specific issues DTC 2010 tabled in the Lok Sabha on 30 August 2010 DTC 2010 to cost the Exchequer revenue loss of INR 531,720 Million on reduced rates 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

319 Sections and 22 Schedules in DTC 2010 vis-à-vis 298 Sections and 14 Schedules in the ITA Simplified Legislation ?
© 2010 KPMG, an Indian Partnership and a member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (“KPMG International”), a Swiss entity. All rights reserved.

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Foreign Company 40 percent  Additional branch profit tax . a Swiss entity.Indian Company ITA (Headline Rates) 30 percent 30 percent  30 percent DTC 2010 Income tax .Corporate Tax Rates Category Income Tax . 4 . an Indian Partnership and a member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (“KPMG International”). All rights reserved.15 percent 18 percent 15 percent 20 percent 15 percent MAT DDT Income distributed by mutual fund to unit holders of equity oriented Funds Income distributed by life insurance companies to policy holders of equity oriented life insurance Schemes Not applicable 5 percent of income distributed Not applicable 5 percent of income distributed © 2010 KPMG.

65 years of age or more) basic exemption limit enhanced to INR 250.Personal Tax .000 INR 500.000 Above INR 800.000 Tax Rate (Per cent) Nil 10 20 30 For resident Senior Citizens (i.000.000 INR 500.000 Above INR 1.000 Proposed Slabs (As per DTC 2010) Upto INR 200.001 to 1. 5 .000 Impact / Issues – Token reduction in tax liability (i.000* INR 160.e.000* INR 200. a Swiss entity.Rates of income tax Existing Slabs (As per ITA) Upto INR 160. an Indian Partnership and a member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (“KPMG International”). All rights reserved.000 from INR 240.001 to 800. increase in net disposable income) – In case of Resident Women same exemption limit as Resident Men assessees – Education cess (@ 3 per cent) has been abolished © 2010 KPMG.001 to 500.000.e.001 to 500.

however. 6 . an Indian Partnership and a member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (“KPMG International”). a Swiss entity.Definition of Residency  Category of ‘Not Ordinary Resident’ deleted but the concept remains  Individual can be either “Resident” or “Non Resident”  Residency threshold for visiting Indian citizens/person(s) of Indian origin reduced to 60 days from 182 days  Expatriates of Foreign Nationality not adversely affected qua Income-Tax. adversely affected qua Wealth Tax © 2010 KPMG.Personal Tax . All rights reserved.

an Indian Partnership and a member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (“KPMG International”). a Swiss entity.Income from Employment  “Employer” defined “means a person who controls an individual under an express or implied contract of employment and is obliged to compensate him by way of salary”  Income from Employment = Gross Salary – Specified Deductions  TDS on salary now on payment/ credit whichever is earlier Additional burden of TDS on credit to books of accounts  Most exemptions/ deductions retained with minor tweaking © 2010 KPMG. All rights reserved.Personal Tax . 7 .

a Swiss entity. an Indian Partnership and a member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (“KPMG International”). Fixed deposits etc) © 2010 KPMG. 8 . Impact / Issues – Retaining EEE taxation – major relief in absence of established social security system – Withdrawals of Provident Fund. – Deduction limits for life (premium less than 5 per cent) and health insurance premiums. ELSS.000 p.Personal Tax – Incentives  Incentives – Exempt – Exempt – Exempt (EEE) mode of taxing long term retiral savings retained – Deduction to approved provident funds.000 p. amounts received on death/ maturity of life insurance policy tax -free – Avenues reduced (no Housing Loan Principal.a. All rights reserved.a. pension funds etc upto INR 100. tuition fees restricted to INR 50.

a Swiss entity.upto INR 50. an Indian Partnership and a member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (“KPMG International”).000 (if premium < 5 per cent of capital sum) • Deduction part of INR 50.000 limit • Annual accretion exempt • Annual accretion exempt • No change • Maturity proceeds exempt (if premium < 20 per cent of capital sum) • Maturity proceeds exempt if premium < 5 per cent of capital sum • For exemption on maturity. premium limit reduced to 5 per cent of capital sum © 2010 KPMG. 9 . All rights reserved.Personal Tax – Incentives Investment Life Insurance Premium (LIP) ITA DTC 2010 Impact • LIP deduction upto INR 1 Lakh (if premium < 20 per cent of capital sum) • LIP deduction .

Capital gains tax Gain on transfer of Equity Shares / Units of Equity Oriented Fund on which STT is paid ITA DTC 2010 Long Term Capital Gains (more than 1 year) Exempt Deduction allowed for 100% of gains (Effectively exempt) Short Term Capital Gains (1 year or less) Gain on transfer of other Investment Assets If held for more than 1 year from end of FY in which asset is acquired 15% ITA 20% (10% in certain cases. an Indian Partnership and a member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (“KPMG International”). a Swiss entity. 10 . if indexation not availed) Deduction allowed for 50% of gains – Balance taxable at normal rates (30%) DTC 2010 Taxable at normal rates (30%) Indexation available LTCA : Period of holding of shares / units  One year from the date of acquisition or  One year from the end of the FY in which the shares / units are purchased ? © 2010 KPMG. All rights reserved.

for all Assesses Pari materia with DTC 2009 © 2010 KPMG. etc. horse race.) Royalty and Fees for Technical Services. a Swiss entity.Overview – Sources of Income Income Special Sources  Non-Resident     Investment Income (Interest. Capital Gains. race. Ordinary Sources Other than Special Sources:      Income from Employment Income from House Property Income from Business Capital Gains Income from Residuary Sources Non-Resident Sportsman / Sports Association / Institution Winning from lottery. any game or betting. etc. Dividend. All rights reserved. 11 11 . an Indian Partnership and a member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (“KPMG International”). etc.

a Swiss entity.” DTC 2009 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’ Multiple POEMs in India and abroad : Application of tie-breaker test in tax-treaty? © 2010 KPMG. 12 . at any time in the FY ‘Place of effective management’ (‘POEM’) situated in India. at any time in the FY “place of effective management of the company” means DTC 2010  the place where the board of directors of the company or its executive directors. or  in a case where the board of directors routinely approve the commercial and strategic decisions made by the executive directors or officers. All rights reserved. the place where such executive directors or officers perform their functions. make their decisions.Tax Residency for Foreign Companies ITA Control and management of affairs situated wholly in India Control and management of affairs situated wholly or partly in India.International Taxation . an Indian Partnership and a member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (“KPMG International”).

in India from transfer of a capital asset situated in India (Same as ITA) However. following shall be not be deemed to accrue / arise in India: (New) Income from transfer. a Swiss entity. directly or indirectly. outside India.Transfer of Assets by non-residents DTC 2009 Income deemed to accrue/arise. directly or indirectly.International Taxation . which are critical in determining applicability of this provision  Provision can be overridden by a favourable tax treaty © 2010 KPMG. in India from the transfer. of shares or interest in a foreign company unless FMV of assets in India (owned directly or indirectly by the company) represent atleast 50 percent of the FMV of all assets owned by the foreign company 50 percent test to be applied at any time during the 12 months prior to transfer (New) Tax on income computed under DTC 2010 to be pro-rated based on FMV proportion of India assets/ total assets of foreign company (New) DTC 2010 Impact / Issues  Overseas transfer of assets / shares (with underlying economic interest in India) whether taxable?  Meaning of the expressions ‘interest’ in a foreign company / ‘owned directly and indirectly’ by the Company  Exclusions applicable only for shares or interest in a foreign company and not to intangible assets like trademark  Guidelines awaited on FMV methodology. directly or indirectly. of a capital asset situated in India Income deemed to accrue / arise. 13 . All rights reserved. an Indian Partnership and a member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (“KPMG International”).

a Swiss entity. or  BPT levied Impact / Issues  Deeming provisions for non-residents: Scope enlarged in DTC 2010  Treaties to override deeming provisions © 2010 KPMG.Tax Treaty not to have preferential status when  GAAR invoked.International Taxation – Treaty Override   No preferential treatment between DTC or the Tax Treaty Provision which is later in point of time to prevail DTC 2009 DTC 2010  Restoration of Treaty supremacy over domestic law as under ITA  Limited Treaty Override . or  CFC triggered. 14 . All rights reserved. an Indian Partnership and a member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (“KPMG International”).

a Swiss entity. an Indian Partnership and a member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (“KPMG International”). . expenses. relief. Income. expenses. etc •Deemed connected person as same.International Taxation – GAARs (1/2) Rights / Obligations not at arm’s-length the arrangement as void Disregard accommodating parties/ Treat parties as one and the same •Treat Lacks commercial/ economic substance Re-characterize Equity -Debt. All rights reserved. etc Misuse / Abuse of DTC GAARs invoked Is main purpose ‘Arrangement’ of tax benefit? (impermissible avoidance arrangement) Re-allocate income. relief. etc Disregard/ combine/ recharacterize the arrangement Is not for bonafide purposes 15 © 2010 KPMG.

a Swiss entity. Cyprus. etc. an Indian Partnership and a member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (“KPMG International”). etc.?  GAARs not to be invoked for every arrangement involving tax mitigation (RDP)  To watch out for CBDT guidelines on GAARs  Effectiveness of DRP route for resolving GAARs related disputes  Availability of AAR mechanism? © 2010 KPMG. All rights reserved. 16 . in absence of appropriate substance / commercial rationale.International Taxation – GAARs (2/2) Impact / Issues  GAARs to override tax treaties: Sustainability of tax treaty protection with Mauritius.

treaty definition of PE not relevant for BPT Chargeability to BPT in a situation where PE exists under the DTC 2010 but no PE under treaty (and consequently no liability to Income tax) ? © 2010 KPMG.  Substantial Equipment PE (no time threshold specified) and  Agency PE (excludes independent agents) Impact / Issues       Non-specification of time thresholds : Impact thereof No exclusions for preparatory and auxiliary activities No definition for Independent Agent PE definition in Treaties to over-ride ‘Business Connection’ test BPT not subject to treaty protection.International Taxation . All rights reserved.Permanent Establishment   PE defined : Relevant for Business Connection and BPT PE includes :  Fixed place PE. a Swiss entity.  Construction / Installation / Assembly / Supervisory PE (no time threshold specified). 17 . an Indian Partnership and a member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (“KPMG International”).  Service PE (no time threshold specified). hence.

Branch Profits Tax (‘BPT’)  Additional BPT proposed to be levied @ 15% on income of foreign companies  Effective tax rate – 40. All rights reserved. or  from an immovable property in India  Corresponds to DDT on Indian companies  however not linked to repatriation of income  Levy of BPT overrides tax treaty provisions  Applicability of BPT on overseas entities like LLP. a Swiss entity. an Indian Partnership and a member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (“KPMG International”). 18 .5%  Applicable to income of foreign companies:  attributable directly or indirectly to a PE in India. etc?  Use of subsidiary may achieve tax deferral till repatriation © 2010 KPMG. LLC.

Transfer Pricing  APA regime continues as provided under DTC 2009  Widening of powers for determination of ALP  Audit Process  Proposal to select cases based on “Risk” dropped  TPO no longer required to issue “show-cause” before making adjustment  AE definition generally aligned with ITA. 19 . some broadening  Location . an Indian Partnership and a member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (“KPMG International”).Enterprises in any specific location (to be prescribed)  Provision of Services . nomination of directors etc. All rights reserved. loans. a Swiss entity. aligned with ITA © 2010 KPMG.where amount / conditions are influenced by other enterprise  Shareholding.

20 . All rights reserved. an Indian Partnership and a member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (“KPMG International”). a Swiss entity.MAT       ‘Asset’ based levy in DTC 2009 substituted with ‘Book Profits’ based levy as under ITA SEZ developers / SEZ Units no longer exempt from MAT Headline Rate increased from 18 percent to 20 percent MAT Credit : Similar Mechanism as under ITA Carry forward of MAT credit upto 15 years as against 10 years in the ITA MAT credit to lapse in case of conversion of a private company or an unlisted public company into a limited liability partnership Impact / Issues  No specific provision for grandfathering of unutilized MAT credit carried forward from ITA  No provision for carry forward of MAT credit in case of business reorganisation © 2010 KPMG.

an Indian Partnership and a member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (“KPMG International”). petroleum or natural gas Commercial production of a new or improved material / device / product Commercial use of a new or improved process Style changes Routine data collection Benefit not available where R&D is the business of the assessee © 2010 KPMG. etc. Products or Processes Prospecting. 21 .refers to basic research. a Swiss entity. of minerals. applied research and experimental development in field of technology.Deduction for Scientific R & D allowance (1/2)  Scientific R&D definition as per DTC 2009 retained . natural or applied science  Specifically excludes following activities:          Market research or Sales Promotion Research in social sciences / humanities Quality control or Routine Testing of Materials. Devices. All rights reserved.

Deduction for Scientific R & D allowance (2/2) Particulars ‘In house’ R&D expenditure available to a corporate only (includes both revenue and capital expenditure. All rights reserved. excluding land and building cost) Outsourced R&D  Approved Research Association / National Laboratory / University / College / Institution for scientific research Approved Research Association / University / College / Institution for social science Contribution made to a company engaged in scientific research 175% 125% 175% ITA 200% DTC 2009 150% DTC 2010 200%   125% 125% 125% 125% 100% 100% © 2010 KPMG. an Indian Partnership and a member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (“KPMG International”). a Swiss entity. 22 .

a Swiss entity. 2012  Profits to be computed as per the Code  No deduction to be allowed for capital expenditure and expenditure incurred before commencement of business  Conditions specified in relevant provisions of the Act to be complied with  Investment linked tax incentives retained and extended to specified new hospital © 2010 KPMG. 23 .unit should have been eligible for deduction for AY beginning on April 1. an Indian Partnership and a member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (“KPMG International”). All rights reserved.Tax Incentives .Others  Specified profit linked tax holiday under the Act to continue for the unexpired period  Tax holiday under Section 80 IC grandfathered .

2014 (No condition for due date for notification of SEZ) Yes – commencement of operations on or after 01.04.04.2012 Yes – irrespective of date of notification Not Applicable MAT payable No No DDT payable No Yes © 2010 KPMG. a Swiss entity.3. All rights reserved.3.2012 ITA Yes – irrespective of date of commencement of operations SEZ Units DTC 2010 Yes – commencement of operations before 31.SEZs / SEZ Units Particulars SEZ Developers ITA Profit-linked incentive Yes – irrespective of date of notification DTC 2010 Yes – notified up to 31. an Indian Partnership and a member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (“KPMG International”). 24 .2014 Yes – irrespective of date of commencement of operations Investment-linked incentive Not Applicable Yes – notified on or after 01.

unlike DTC 2009 Sale of carbon credits to be taxable as business income : Impact on earlier years ? Expenditure to be allowed in the year of payment of TDS – Two years’ limitation under DTC 2009 dropped  Non-moving creditors beyond five years to be treated as taxable business income as against three years in DTC 2009  Deduction for specified deferred revenue expenditure to be allowed on straight-line basis over 6 / 10 years as against allowance on WDV basis @ 25 percent / 15 percent as under DTC 2009  Cost of acquisition of license / right / benefit now allowed as a deduction from sale consideration © 2010 KPMG. All rights reserved. 25 .Business Income    Slump sale to be taxed as capital gains and not business income. an Indian Partnership and a member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (“KPMG International”). a Swiss entity.

a Swiss entity. except condition no. if: 1) dividend (INR 70) is received (by X) from a subsidiary (Y) 2) subsidiary (Y) has paid DDT on such dividend (INR 70).DDT Credit In computing DDT. 3 deleted Impact / Issues  X eligible for DDT credit under DTC 2010 unlike ITA. and 3) recipient company (X) is not a subsidiary of any other company (Z) Same as ITA ITA DTC 2009 DTC 2010 Same as ITA. 26 . amount of dividend declared (INR 100) by a Company (X) to be reduced by dividend received (INR 70) from another Company (Y). All rights reserved. even if X is a subsidiary of Z: Significant relaxation for intermediate holding companies  Availability of Multi-level DDT credit (DDT on INR 70 paid by Y and set-off by X) flow through to Z for dividends declared by Z? © 2010 KPMG. an Indian Partnership and a member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (“KPMG International”).

an Indian Partnership and a member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (“KPMG International”). a Swiss entity.000  Bank deposits outside India  Cash in hand in excess of INR 200. paintings. 27 . drawings.000 Particulars Overseas assets for foreign citizens ITA DTC 2010 Impact  Overseas assets exempt irrespective of residential status  Wealth-tax on specified overseas assets if Residents of India  Greater wealthtax liability Indian Citizens / PIOs repatriating funds to India  Overseas Assets exempt irrespective of residential status  Wealth-tax on specified overseas assets if Residents of India  Greater wealth-tax liability © 2010 KPMG. sculptures or any other work of art  Watch with a value in excess of INR 50. All rights reserved.Wealth Tax Wealth Tax:  Every person (other than a NPO) will be liable to pay wealth-tax at the rate of 1 percent on net wealth exceeding INR 10 Million  Scope of “Specified Assets” expanded to interalia include certain additional assets such as:  Archaeological collections.

28 . a Swiss entity. an Indian Partnership and a member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (“KPMG International”). All rights reserved.CFC CFC provisions introduced     Total income of residents to include income attributable to a CFC CFC specifically defined in the Code Income attributable to a CFC to be computed as per Specified Formula CFC provisions to impact outbound investments © 2010 KPMG.

29 29 . an Indian Partnership and a member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (“KPMG International”). a Swiss entity.Hits and Misses for MNCs  Exemption from LTCG on listed shares  MAT leviable on Book Profits as against Gross Assets  Income Tax Holiday for SEZ units partially extended  Supremacy of Tax Treaty in most cases  APA regime  MAT for SEZ Units  Wide-sweep of GAARs retained  Wide PE definition HITS MISSES  Non-Rationalization of DRP regime  Uncertainty in taxability of crossborder transactions / overseas M&As © 2010 KPMG. All rights reserved.

an Indian Partnership and a member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (“KPMG International”). Netherlands)  Preparing for APAs  Outsourcing of services / activities to India before March 31.Key Focus Areas for MNCs  Representation before Parliamentary Standing Committee  Inbound Investments through Mauritius / Cyprus etc:  Evaluating substance – if not then build substance. a Swiss entity. 2014 – SEZ tax holiday  Evaluate existing structures with Branch Office in India due to introduction of BPT  Evaluate withholding tax implications on cross border transactions  Taxability of overseas M&A © 2010 KPMG. All rights reserved. 30 30 . or  Transition investment to other tax efficient jurisdiction having substance (Singapore.

1961 Long-term Capital Asset TP TPO NPO PIOs Transfer Pricing Transfer Pricing Officer Non-Profit Organisation Person of Indian Origin SEZ STCG STT TDS Special Economic Zone Short-term Capital Gain Securities Transaction Tax Tax Deducted at Source NPO PE POEM RDP R&D Non Profit Organisation Permanent Establishment Place of Effective Management Revised Discussion Paper on Direct Taxes Code Research & Development LTCG LLP MAT Long-term Capital Gain Limited Liability Partnership Minimum Alternate Tax © 2010 KPMG.Glossary AY AAR AE APA BPT CFC CBDT CG DTC 2009 DTC 2010 DRP DDT FII FMV FY GAARs ITA LTCA Assessment Year Authority for Advance Rulings Associated Enterprise Advance Pricing Agreement Branch Profits Tax Controlled Foreign Companies Central Board of Direct Taxes Capital Gains Direct Taxes Code Bill 2009 Direct Taxes Code Bill 2010 Dispute Resolution Panel Dividend Distribution Tax Foreign Institutional Investors Fair Market Value Financial Year General Anti Avoidance Rules Income-tax Act. an Indian Partnership and a member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (“KPMG International”). All rights reserved. 31 . a Swiss entity.

a Swiss entity.Questions Answers © 2010 KPMG. an Indian Partnership and a member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (“KPMG International”). All rights reserved. 32 .

All rights reserved. 33 .THANK YOU ALL FOR YOUR ATTENTION ! Hitesh Gajaria Executive Director KPMG in India Tel: +91 22 3090 2110 Email: hgajaria@kpmg.com © 2010 KPMG. a Swiss entity. an Indian Partnership and a member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (“KPMG International”).

Although we endeavor to provide accurate and timely information. II Floor. Mumbai 400 011 Tel +9122 39896000 Fax +91 22 39836000 New Delhi Building No. Joshi Marg. M.com/in Mumbai Lodha Excelus.EP & GP. Sector . 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. Mahalakshmi. . 10 Mahatma Gandhi Road. 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.10. Apollo Mills Compound. an Indian Partnership and a member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (“KPMG International”). N. Plot No. Koramangala. 1st Floor.G-1. Road. 11.www. G. Block . 8th Floor.kpmg. Salt Lake City Kolkata 700091 Tel: +91 33 44034066 Fax: +91 33 4403 4199 Pune 703. No one should act on such information without appropriate professional advice after a thorough examination of the particular situation. Chennai 600 034 Tel +91 40 3914 5000 Fax +91 40 3914 5999 Kolkata Infinity Benchmark.V. Pune 411 001 Tel +91 20 305 85764/65 Fax +91 20 305 85775 Kochi 4/F. East Wing. Ravipuram. Inner Ring Road Bangalore 560 071 Tel +91 80 3980 6000 Fax +91 80 3980 6999 Hyderabad 8-2-618/2 Reliance Humsafar. Nungambakam. Tower B. Kochi 682016 Tel +91 (484) 302 7000 Fax +91 (484) 302 7001 Chandigarh SCO 22-23 Ist Floor. All rights reserved. Palal Towers. a Swiss entity. Phase – II Gurgaon 122002 Haryana Tel +91 124 3074000 Fax +91 124 2549101 Bangalore Maruthi InfoTech Centre 11/1 and 12/1. DLF Cyber City. Bund Garden. 4th Floor Road No. Godrej Castlemaine. © 2010 KPMG. Banjara Hills Hyderabad 500 034 Tel +91 40 6630 5000 Fax +91 40 6630 5299 Chennai No.M. 10th floor.

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