A TAX PROJECT ON

MINIMUM ALTERNATIVE TAX: AN ANALYSIS

_________________________________________

SUBMITTED TO: MR. V. SURYA NARAYAN RAJU

___________________________________________________________

SUBMITTED BY: MUSKAN KHATRI

ROLL NO.: 87

SEMESTER: X

DATE: 30TH NOVEMBER, 2022

HIDAYATULLAH NATIONAL LAW UNIVERSITY

(CHHATTISGARH)
 CONTENTS
Acknowledgements 2

Objectives 3

Research Methodology 4

Introduction 5

Caution in Criticizing Judicial Act 6

Reporting news pertaining to court proceedings 7

International Efforts 7

The Basic Principle 8

Restrictions 9

Tabloidization and page 3 Syndrome 10

Manipulation of Information 13

Erosion of ‘Editors’ 13

Focus on trivia 14

Conclusion 16

Bibliography 18
 INTRODUCTION

MAT stands for Minimum Alternate Tax, as per Income tax Act, 1962. It is applicable to
Companies and Firms/LLPs.  Many a time, firms and companies avail all the benefits in tax laws
and end up paying a paltry sum as tax or pay no tax at all, on account of excellent tax planning.
The MAT ensures that no company with healthy finances and substantial income can avoid
paying income tax, even after claiming exemptions. Companies Act 2013, Income Tax 1961 and
Finance Act operate entities and define the taxes and liabilities that a company has towards
various stakeholders including the state. Companies were able to avoid paying tax by claiming
legal exemptions under the following heads before the introduction of the Minimum Alternate
Tax (MAT). MAT was introduced in 1988 to bring zero tax companies into the ambit of tax. The
Government reports poor tax collection and thereby the projects of the government are not met
or results in greater deficit than estimated. If it is not plugged in time, these perpetual deficits
would result in greater inflation in the economy.  Hence the governments all over the world have
brought this concept of minimum amount of tax, to be collected, regardless of benefits
received/availed by taxpayers.

The objective of introducing MAT is to bring into the tax net "zero tax companies" which in
spite of having earned substantial book profits and paid handsome dividends, do not pay tax.
MAT was introduced by the Finance Act, 1987 with effect from assessment year 1988-89.

Section 115JB of Income Tax Act, 1961:

The tax liability of a firm will be higher of the following under the MAT concept:

 The company's tax liability is calculated in accordance with the standard rules of the
Income-tax Law, i.e., tax is calculated on the company's taxable income using the
company's specific tax rate. Taxes calculated in the manner above can be considered
regular tax liabilities.
  tax calculated at 15% of book profit (plus any relevant surcharges and cess) (manner of
computation of book profit is discussed in later part). The tax that is calculated by
applying 15% (plus any relevant surcharge and cess) to book profit is known as MAT.

If a company is a unit of an international financial services centre and receives all of its revenue
in convertible foreign exchange, MAT is collected at a rate of 9% (plus surcharge and cess if
applicable).

ILLUSTRATION:

Essem Minerals Pvt. Ltd.'s taxable income, calculated in accordance with the rules of the
Income-tax Act, is Rs. 8,40,000. According to the guidelines in section 115JB, the company's
book profit is Rs. 18,40,000. What will Essem Minerals Pvt. Ltd.'s tax obligations (ignoring cess
and surcharge) be?

***

A company's tax liability will be the greater of I normal tax liability or (ii) MAT. A typical tax
rate for an Indian firm is 30%*. (plus cess and surcharge as applicable). Tax of Rs. 2,52,000 on
Rs. 8,40,000 at a rate of 30% (plus cess). The company's book profit is Rs. 18,40,000. On Rs.
18,40,000, MAT liability (exclusive of cess and surcharge) at 15% equals Rs. 2,76,000.

Essem Minerals Pvt. Ltd. will thus have a higher tax obligation than usual, amounting to Rs.
2,76,000 (plus applicable cess).

A domestic company is subject to 25% taxation if its prior-year turnover or gross receipts did not
exceed Rs. 400 crores. In this instance, it has been presumed that the company's revenue in the
prior fiscal year 2020–21 exceeded 400 crores rupees.
APPLICABILITY AND NON-APPLICABILITY OF MAT:

According to section 115JB, if the income tax (including surcharge and cess) payable on the total
income, computed in accordance with the provisions of the Income-tax Act in respect of any
year, is less than 15% of its book-profit + surcharge (SC) + health & education cess, the taxpayer
being a company is required to pay MAT.

The following domestic companies, however, are exempt from the MAT's provisions:

1. Domestic companies that have chosen to be taxed under Section 115BAA or Section
115BAB;

2. Companies that receive income from the life insurance business mentioned in Section
115B;

3. Shipping companies whose income is subject to tonnage taxation.

Furthermore, it is clarified in Explanation 4 to Section 115JB as amended by the Finance

Act, 2016 with retrospective effect from 1/4/2001 that the MAT provisions shall not apply and
shall be deemed never to have applied to an Assessee, being a foreign company, if—

(i) the Assessee is a resident of a country or a specified territory with which India has an
agreement referred to in Subsection (1) of Section 90 or the Central Government has
adopted any agreement;

(ii) The assessee resides in a nation with which India does not have an agreement of the
type mentioned in clause (i) and is not obliged to apply for registration under any
company-related laws that are now in effect.

The MAT provisions are also not applicable to a foreign company whose total income
consists of profits and gains from the types of businesses mentioned in sections 44AB, 44BB,
44BBA, or 44BBB and which have been offered for tax at the rates mentioned in those
sections, according to Explanation 4A to section 115JB as added by the Finance Act of 2018.
Meaning of Book Profit:-

According to section 115JB(2) Explanation 1, "book profit" refers to net profit as it appears in
the statement of profit and loss prepared in accordance with Schedule III to the Companies Act,
2013, increased and lowered by certain items specified in this respect. The following items need
to be increased and decreased:

COMPUTATION OF BOOK PROFIT:

Section 115JB's Explanation 1 to Subsection (2) of that section mandated certain things that
were to be either added to or subtracted from the net profit as it was displayed in the profit
and loss account.

Addition in net profit:  The following sums were debited to the profit and loss account:

1. The amount added to any reserves, regardless s of the term used (other than reserves
relating to shipping business created under Section 33AC)

2. The amount of spending in relation to section 10-covered incomes [apart from section
10(38)];

3. Dividend amounts paid or anticipated to be paid;

4. The amount of depreciation according to tax regulations.

5. The remaining balance in the revaluation reserve for the revalued asset upon retirement
or sale of the asset.

6. The amount of deferred tax or its provisions.

7. The amount of income tax paid, owed, or otherwise provided; however, income tax
penalties or their interest, taxes that include wealth tax penalties or their interest Other
laws' penalties do not have to be added back.

8. Provisions for a subsidiary's loss

 9. The amount or amounts of expenditures related to income that represent the taxpayer's
part of the income of a group of people or an association of people for which no income
tax is due in accordance with section 86.

10. The sum or sums of expenses related to earnings accruing or arising to a taxpayer that is a
foreign corporation, from:

 the interest, royalties, or fees for technical services that are subject to tax at the
rate or rates specified in Chapter XII if the income-tax payable on the
aforementioned income is less than the rate of MAT or capital gains.

11. the amount representing the notional loss on the transfer of a capital asset, such as a share
or special purpose vehicle, to a business trust in exchange for units allocated by that trust
as described in clause (xvii) of section 47.

12. Expenditures related to royalties from patents that are subject to tax under section
115BBF

13. Amounts placed aside as a reserve for asset value declines; for instance, a reserve for bad
debts to be added.

14. Amounts set aside for making provisions for yet-to-be-determined obligations; however,
provisions based on scientific principles are not to be added back.

15. If the amount in the revaluation reserve for a revalued asset is not credited to the
statement of profit and loss upon retirement or sale of that asset.

Subtraction From Net Profit: The following sums were credited to the profit and loss account:

1. The sum that was taken out of any reserve or provision.

2. The amount of income that is subject to section 10 (save for section 10(38)), section 11 or
section 12.
3. The amount of unabsorbed depreciation or the amount of loss carried forward, whichever
is less according to the books of account.

4. Depreciation, excluding that resulting from asset revaluations.

5. Any money taken out of the reserve for revaluing assets that is credited to the P&L
account as long as it doesn't exceed the amount of depreciation due to the revaluation of
the assets

6. The amount of any deferred taxes

7. A sick industrial company's profits are subject to specific restrictions

8. Any revenue that is credited to the statement of profit and loss that represents the
taxpayer's share of an association of people or group of people's income for which no
income tax is due in accordance with section 86.

9. The amount of income accruing or arising to a taxpayer that is a foreign corporation

from:

(a) the capital gains arising on securities transactions; or

(b) the interest, royalties, or fees for technical services that are chargeable to tax at the
rate or rates specified in Chapter XII if such income is credited to the statement of profit
and loss and the income-tax payable on above income is less than the rate of MAT.

10. The amount (if any) credited to the statement of profit and loss that represents either

(a) a notional gain on the transfer of a capital asset, such as a share of a special
purpose vehicle to a business trust in exchange for units allocated by that trust as
described in clause (xvii) of section 47;

(b) a notional gain resulting from any change in the carrying amount of said units; or

(c) a gain on the transfer of units as described in clause (xvii)

 11. The sum representing the fictitious gain on the transfer of units mentioned in clause (xvii)
of section 47 is calculated by taking into account the cost of shares exchanged for such
units. The carrying amount of shares at the time of exchange is not considered a fair
market value.

12. Income from royalties related to patents that is subject to taxation under section 115BBF.
The total amount of unabsorbed depreciation and loss brought forward in cases where the
Tribunal, upon the Central Government's application, has suspended the Board of
Directors of such company.

Procedure for Computation of MAT u/s 115JB :-

The provisions of section 115JB provide for working out the income-tax payable as MAT on a
deeming basis. The MAT tax liability under section 115JB can be worked out by undergoing the
following steps:-

1. Compute the total income of the company (ignoring the provisions of u/s115JB).
2. Compute the income-tax payable on total income is worked out under (1) above.
3. Work out the Book Profit under the provisions of section 115JB.
4. Calculate 15 per cent of book profit (as per provisions of section 115JB).
5. MAT tax liability as worked out under (4) above would be the tax payable if it is more
than the amount of tax worked out (2) above.

RELIEF IN COMPUTATION MECHANISM U/S 115JB

A new Rule 10RB 'Relief in tax payable u/s 115JB(1)' is inserted in the Income-tax Rules,
1962 along with a new Form No. 3CEEA for claiming the relief. The CBDT vide Notification
No. 92/2021 in G.S.R. 551(E) dated 10th August 2021 notifies the Income Tax (23rd
Amendment), Rules, 2021.

The Finance Act of 2021 amended section 115JB's provisions to include any adjustments due
to past-year additional income that was included in the current year's books of accounts as a
result of a secondary adjustment under section 92CE or as a result of an Advance Pricing
Agreement (APA) signed with the taxpayer under section 92CC.

As a result, a new section 115JB(2D) was added, according to which the Assessing Officer
must, upon the assessee's request in this regard, recalculate the book profit of the prior year or
years and any tax due during the prior year in the manner specified.

The assessee company must submit an application to the Assessing Officer in the prescribed
format, Form No. 3CEEA, asking him or her to recalculate the book profit for the prior year(s)
and the tax due on it. After the end of the financial year in which the application is lodged, the
Assessing Officer has four years to recalculate or correct the error.

MEANING OF BOOK PROFIT FOR INDIAN ACCOUNTING STANDARDS (IND AS)

COMPLIANT COMPANIES

1. According to the Finance Act of 2017, which added the recently defined section
115JB(2A), "book profit" for an Ind AS compliant company is defined as the book
profit computed in accordance with Explanation 1 to section 115JB(2) as:

a. increased by all amounts credited to other comprehensive income (OCI) in the

statement of profit and loss that will not be reclassified to profit or loss;

b. decreased by all amounts debited to other comprehensive income (OCI)

The statement of profit and loss on distribution of non-cash assets to shareholders in a demerger
of companies in accordance with Appendix A of Ind AS 10 was:

c. increased by all amounts or the aggregate of amounts debited to the statement,

and

d. decreased by all amounts or the aggregate of amounts credited.

2. For the purpose of calculating book profit, any item credited or debited to OCI that will
not be reclassified as profit or loss should be omitted if it is:
 (i) Revaluation surplus for tangible and intangible assets in accordance with Indian
Standards 16 and 38; or

(ii) Gains or losses from equity instrument investments assessed at fair value through
other comprehensive income (FVTOCI) in accordance with Indian Accounting
Standard (Ind AS) 109.

3. If the assets and liabilities of the undertaking or undertakings being received by it are
recorded at values different from values appearing in the demerged company's books of
account immediately prior to demerger, any change in such value shall be disregarded for
the computation of book profit of the resulting company.

4. Following helps in determining an Ind AS compliant company's book profit:

PARTICULARS AMOUNT

Book profit as computed from above XXXXX

Adjustments as mentioned in point (3) above XXXXX

Adjustments for revaluation gain/loss for fixed assets & intangible assets XXXXX
in the year of their disposal or transfer

Adjustments for gains or losses from investments in equity instruments XXXXX

measured at FVTOCI in the year if their disposal or transfer

Adjustments for any other OCI items that will not be re-classified to profit XXXXX
or loss

Book profit to be used to compute MAT XXXXX

MAT CREDIT :-

A business must pay more tax than is required by law or the MAT requirements. The corporation
is eligible to claim credit for MAT paid above and beyond the regular tax duty in the next year if
it pays MAT due in any given year (s). Section 115JAA contains the provisions relating to MAT
credit carryover and adjustments. As long as the amount of Foreign Tax Credit ('FTC') allowed
against the MAT does not exceed the amount of FTC that is admissible against the tax that the
assessee owes under the regular provisions of the Income-Tax Act, the excess amount is
disregarded when calculating the amount of FTC under this sub-section.

As per section 115JAA, MAT credit can be carried forward for set-off against regular tax
payable during the subsequent years subject to certain conditions, as under:-

1. If MAT is paid u/s 115JA its credit can be carried forward and utilized Five
assessment year immediately succeeding the assessment year in which tax credit
becomes allowable under sub-section (1) of section 115JAA.
2. If MAT is paid u/s 115JB its credit can be carried forward and utilized Seven
assessment year immediately succeeding the assessment year in which tax credit
becomes allowable under sub-section (1A) of section 115JAA. (Inserted by Finance
Act,2006 ,w.e.f. 01-04-2007)
3. The credit allowed will not bear any interest.

A numerical illustration:-

Essem Minerals Ltd.'s tax obligation for the fiscal year 2022–2023 is Rs. 8,40,000 under the
regular provisions of the Income-tax Act, and it is Rs. 10,00,000 under the MAT requirements.
Will the company be qualified to apply for any MAT credits under section 115JAA in the
upcoming year(s)?

***

A business that pays MAT is eligible to claim the credit for MAT that was paid in excess of
regular tax obligations. In this scenario, Essem Minerals Ltd.'s obligation for the year 2022–2023
is Rs. 8,40,000 under standard provisions, but it is Rs. 10,00,000 under section 115JB's
provisions (which is greater than standard tax liability), hence the firm must pay Rs. 10,00,000,
i.e., liability as per MAT provisions.

According to section 115JAA, if a firm pays its tax liability according to MAT in any given year,
it may then claim MAT credit for the excess MAT paid over the standard tax payment. Due to
the increased MAT liability in this situation, the corporation will be able to claim MAT credit in
the amount of Rs. 1,60,000. (being excess of MAT over normal tax liability of Rs. 8,40,000).

SECTION 115JB OF THE INCOME TAX ACT, 1962

For arriving book profit of the company, the net profit as shown in the P&L Account as per the
provisions of the Companies Act is to be increased by the items mentioned in clause (a) to (j) to
Explanation-1 of Section 115JB (if these items are debited to the P&L account) and is to be
reduced by the items mentioned in clause (i) to (viii) to Explanation-1 of Section 1 15JB of the
Act. It is to be noted that rate of 15% is applicable for A.Y. 2022 onwards.

There are many issues related to Section 115JB, which have been the matter of contention
between the assessees and the Department. Some of these issues have been settled by way of
amendment in the Act or by way of judgements of the Hon’ble Supreme Court; however, some
of these issues are still controversial. Both type of issues are discussed here under-

1. If taxable income is calculated using MAT, can penalties be applied for additions made
in accordance with regular rules?

No penalty may be imposed under section 271(1)(c) for additions made in accordance with
standard requirements where taxable income is calculated under section 115JB. Deputy
Commissioner of Income-Tax v. Unison Hotels Ltd.1

2. Can a reassessment be started in cases where the assessee company suffered a loss and
paid MAT on book profit?
1
[2013] 40 taxmann.com 237 (Delhi)]
When the assessee-company incurred a loss and paid tax on a book profit calculated in
accordance with the MAT provision, it was determined that the assessee would still be subject to
the provisions of section 115JB and be assessed on the same book profit after making the
proposed addition to income [Motto Tiles (P.) Ltd. v. ACIT2], and reassessment could not be
started.

3. When a firm is required to pay MAT, DTAA allows for the allowance of double
taxation relief.

According to the decision in Deputy Commissioner of Income-tax, Circle-4 v. iGate Global

Solutions Ltd.3 the assessee is only entitled to a credit for tax paid abroad to the extent of the
income that was subject to double taxation; the remaining amount, whose corresponding income
is not included in the computation of income under section 115JB, is not eligible for the credit.
The amount of foreign tax credit should be limited to the amount obtained by applying the MAT
rate to the doubly taxed income if the income was subject to tax in the other nation at a rate
higher than the MAT rate.

4. MAT is applicable to LLPs incorporated outside India (Foreign LLPs), not to Indian
LLPs

The definition of "company" under the Act is substantially more expansive than the definition in
the Companies Act of 2013, as can be observed from clauses (17) and (26) of section 2 of the
Act. According to section 2(23), an LLP formed in India under the LLP Act, 2008 is a "firm" and
not a corporation. LLPs that were founded in India will therefore not be responsible for MAT.
However, foreign LLP shall be recognised as a foreign company and liable for MAT unless
exempted under Explanation 4 or Explanation 4A of Section 115JB. Foreign LLP is a company
under the definition of Section 2(17)(ii)(2).

5. Applicability of the provisions of Advance tax:

It has been clarified by Circular No.13/2001 dated 09/11/2001 that provisions of advance tax are
also applicable on the companies paying MAT and interest under Section 234B & 234C is

2
[2016] 73 taxmann.com 176 (Gujarat)
3
[2019] 111 taxmann.com 192 (Pune - Trib.)
leviable in case of default by these companies. This view has been affirmed by the Honb’le
Supreme Court in the case of JCIT vs. Rolta India Ltd.4

6. Tax credit under Section 115JAA and calculation of interest under Section 234B:

The controversy in this regard has been settled in favour of the assessee by way of substitution of
explanation to sub-section(1) of Section 234B of the Act. The tax credit under Section 115JA has
to be given before calculating the shortage in respect of payment for advance tax. This
explanation was substituted by the Finance Act, 2006 and is applicable from A.Y. 2007-08
onwards.

7. Depreciation on account of revaluation of assets:

Depreciation on account of revaluation of assets cannot be reduced while computing book profit.
Amount of depreciation is to be added back to the net profits, if debited to P&L account. Clause
(g) and clause (iia) were inserted in the Act by the Finance Act, 2006.

8. Amount withdrawn from any reserve:

The A.O. should examine the P&L account of the year in which the reserved was created.
Amount transferred to every kind of reserve is to be added to net profit to determine book profit.
The Hon'ble Supreme Court in a very well reasoned and speaking judgement in the case of Indo
Rama Synthetics (I) Ltd v. CIT5, has discussed this provision at length.

9. Carry forward of unabsorbed depreciation and business losses:

Taxation on the basis of book profits does not affect the carry forward and set off of business
losses and unabsorbed depreciation under the normal provisions of the Act. This has been amply
clarified in sub-section (3) of Section 115JB of the act.

Business losses, unabsorbed depreciation or investment allowance etc. determined as per the
normal provisions of the Act should be set-off against the total income and only balance amount
should be carried forward. The Supreme Court in the case of Karnataka Small Scale Industries

4
196 Taxman 594
5
196 Taxman 535
Development Corporation vs. CIT,6 has held that the brought forward business losses are not
taxable.

Applicant does not have the option to reduce the current year's profits by the loss brought
forward or unabsorbed depreciation. The AAR in the case of Rashtrya Ispat Nigam Ltd., In re7.
In this case, The applicant had correctly applied the provisions of Section 115 JB in the current
year. But while carrying forward it had adjusted the book profit from unabsorbed depreciation.
This was done in order to ensure that figure of carried forward business losses does not become
nil in near future.v

10. Treatment of capital gains:

The Hon’ble Bombay High Court in the case of CIT vs. Veekaylal Investment Co. (P) Ltd.,
116 Taxman 104 has held that The calculation of book profits would take capital gains into
account. The Hon'ble High Court has ruled that a company must disclose any money it receives
as a result of giving up leasehold rights in its P&L account as a non-recurring transaction or a
transaction of an exceptional nature, regardless of whether it is a capital or revenue transaction,
as required by clause (2) of part-II of Schedule VI to the Companies Act. Transferring such a
sum directly to the capital reserve is not appropriate.

11. Scope of scrutiny of P&L account by the A.O. while applying MAT provisions:

The Hon’ble Supreme Court in the landmark judgement of Apollo Tyres Ltd. vs. CIT, 122
Taxman 562 has held that the A.O. while computing the income under Section 1 15J has only
the power of examining whether the books of account are certified by the authorities under the
Companies Act as having been properly maintained in accordance with the Companies Act. The
A.O. thereafter has limited power of making additions and reductions as provided for in the
Explanation to the said section. To put it differently, the A.O. does not have the jurisdiction to go
behind the net profit shown in the P&L account except to the extent provided in the Explanation
to Section 115J.

12. Applicability of MAT provisions on statutory corporations and boards etc.:

6
258 ITR 770
7
155 Taxman 60
In the case of certain companies by way of insertion of clause (b) in sub-section (2) in Section
115JB by the Finance Act, 2012. It has been mandated in this clause that every company, to
which proviso to sub-section (2) of Section 211 of the Companies Act is applicable, shall prepare
its P&L account as per the Act governing such company for the purposes of Section 115 JB.

The following companies have been mentioned in proviso to sub-section (2) of Section 211 of
the Companies Act-

(i)                Insurance or banking company.

(ii)             Any company engaged in the generation or supply of electricity.

(iii) Any other class of company for which a form of P&L account has been specified in or under
the Act governing such class of company.

13. Arrears of depreciation:

Deduction of extra depreciation as arrears of past years while computing book profit is not allowable, as held by the
Hon'ble M.P. High Court in the case of Gilt Pack Ltd vs. Union of India reported in 163 Taxman 331.

14. Prior period expenses:

The Department of Revenue has come to the conclusion that prior period expenses, if shown in P&L account, are
liable for deduction under the Companies Act. The judgements of the Hon'ble Kerala High Court in the case of Sree
Bhagwathy Textiles Ltd. vs. ACIT and CIT vs. Swamiji Mills Ltd., 25 Taxmann.com 110 are in the favour of the
Department.
15.     Applicability of MAT provisions on foreign companies: The applicability of MAT
provisions on foreign companies has been a matter of dispute since long. The Authority for
Advance Ruling in P.No.14 of 1997, In re 234 ITR 335 held that Dutch Company was liable to
tax on book profits. In the case of Timken Company, In re 326 ITR 193, the AAR has held that
since the non resident US Company has no PE in India, therefore, it cannot be liable for MAT.
16. MAT not applicable to income from life insurance business

The Finance Act, 2012 inserted sub-section (5A) in section 115JB with retrospective effect from
assessment year 2001-02. Sub-section (5A) provides that MAT shall not apply to any income
accruing or arising to a company from life insurance business referred to in section 115B.

Conclusion
In order to uncover the borrowings of people and businesses who hide behind tax avoidance
loopholes, other taxes are required in an economy. In order to ensure that taxpayers who benefit
from multiple deductions and exemptions still have to pay at least a minimal amount of tax, the
Minimum Alternate Tax clause was included to the Income Tax Act. Businesses are subject to
the Minimum Alternate Tax regulations, whereas individuals are subject to the Alternative
Minimum Tax restrictions.
 Bibliography

Books Referred:-

● Essays on press freedom/V R Krishna Iyer and Vinod Sethi. – New Delhi: Capital
Foundation Society, 1996
● Media Law/Peter Carey. – 2nd Ed. – London: Sweet & Maxwell, 1996.
● Law of the Press / Durga Das Basu. – 2nd Ed. – New Delhi: Prentice Hall Inc.,
1986.
● Facets of Media Law- A mini encyclopedia covering multiple dimensions of
Media Law: by Madhavi Goradia Divan, EBC Publications
● Cases and materials on Media Law: Jethmalani, Ram and Chopra, D. S; Thomson
Reuters
● Gallant & Epworth Media Law: A Practical Guide to Managing Publication Risks

 Reports and Papers Referred:-

● Tabloidization of the Media: The Page Three Syndrome , Address by Mr. Justice G.N.
Ray, Chairman, Press Council of India at Seminar organised by the Public Relations
Society of India and Mass Media Centre, Government of West Bengal on August 25,
2006 at the Abaninddra Sabhaghar, Kolkata.

Website referred:-

● www.manupatra.com
● www.scribd.com
● www. Indiankanoon.com