TIOL-DDT 1060 · the untouched capture
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<p align="justify"><font size="2" face="Verdana, Arial, Helvetica, sans-serif"><strong><font color="#663399" size="3">TIOL-DDT 1060</font><br>
25.02.2009<br>
Wednesday</strong></font></p>
<p align="center"><font color="#006600" size="2" face="Verdana, Arial, Helvetica, sans-serif"><strong>Third Stimulus - The Notifications have come – as promised by us</strong></font></p>
<p align="justify"><font size="2" face="Verdana, Arial, Helvetica, sans-serif"><strong>ON</strong> February 16, 2009, when the whole media was aghast and the stock market nosedived, we had promised that the stimulus Notifications will come soon. Please see <strong><a href="http://www.taxindiaonline.com/RC2/inside2.php3?filename=bnews_detail.php3&newsid=8613">Interim Budget - Anti-Climax - Surprised Channels - Shocked Opposition - But you can still wait for those Stimulus Notifications. </a></strong>We had promised that the notifications will come in a couple of weeks – we were wrong; they came a little earlier.</font></p>
<p align="justify"><font size="2" face="Verdana, Arial, Helvetica, sans-serif">The effective rates of duties on goods and services now stand at 8% and 10% respectively, which also gives a preview of the likely rates of GST as and when it is introduced. Then in such a case, can we expect GST from April 1, 2010? This is a million dollar question which may get an answer in the next regular budget as and when it will be presented by the new Government.</font></p>
<p align="justify"><font size="2" face="Verdana, Arial, Helvetica, sans-serif">Interestingly, while making a statement on the tax rate cuts in Parliament, the Acting Finance Minister, Mr Pranab Mukherjee mentioned that the duty relief given on December 7, 2008 is being extended <strong>beyond March 31, 2009</strong>. While the whole world (read print and electronic media) including <strong>TIOL </strong> lapped it up as God-sent manna, giving unprecedented and unwarranted mileage to the Government and the FM, the fact of the matter is that neither the earlier Notifications issued on December 7, 2008 nor the current Notifications has any sunset clauses stipulating that the duty relief is applicable only for a certain fixed period of time (except for the import of Naphtha which had a sunset clause when it was introduced in December 7, 2008 but now even this is done away with).</font></p>
<p align="justify"><font size="2" face="Verdana, Arial, Helvetica, sans-serif">The highlights of the new stimulus package are detailed below.</font></p>
<p align="center"><font color="#006600" size="2" face="Verdana, Arial, Helvetica, sans-serif"><strong>Across the Board reduction in Service Tax</strong></font></p>
<p align="justify"><font size="2" face="Verdana, Arial, Helvetica, sans-serif">The Government by exercising its power in terms of Section 93 (1) of the Finance Act, 1994 reduced the service tax rate from 12% to 10% with effect from yesterday for all the taxable services.</font></p>
<p align="justify"><font size="2" face="Verdana, Arial, Helvetica, sans-serif"><strong><a href="http://www.taxindiaonline.com/RC2/subCatDesc.php3?subCatDisp_Id=40&filename=notification/servicetax/2009/stnot09_008.htm" target="_blank">Notification No. 8/2009–ST Dated: February 24, 2009</a></strong></font></p>
<p align="center"><font color="#006600" size="2" face="Verdana, Arial, Helvetica, sans-serif"><strong>Excise duty rates further reduced by two percent</strong></font></p>
<p align="justify"><font size="2" face="Verdana, Arial, Helvetica, sans-serif">On December 7, 2008, as a part of the stimulus package the excise duty rates were reduced by 4% by amending certain notifications through Notification 58/2008-CE dated December 7, 2008. Now in the current round, the duty rate is further reduced by 2%. However, this reduction of 2% is applicable only to goods which carry an effective rate of 10%. The goods which have an effective rate of 8%, 4% and Nil are left untouched this time around.</font></p>
<p align="justify"><font size="2" face="Verdana, Arial, Helvetica, sans-serif">In terms of Rule 6(3) of the CENVAT Credit Rules 2004, a manufacturer opting not to maintain separate accounts for exempted and dutiable goods, has to pay 10% on the price of the exempted goods. This 10% was fixed when the peak rate of excise duty was at 16%. The excise duty rate is now reduced to 8%. Arithmetically the 10% under rule 6(3) should be now at 5% (half of the original 10%). Every time the excise duty rate is reduced, we have been reminding the Board that there should be a corresponding reduction in Rule 6(3), with no result. Now the penalty for not maintaining separate accounts is that the manufacturer has to pay 2% more duty on exempted goods at 10% while all other goods attract duty at 8%. How ridiculous! Why give an exemption at all when the exempted goods will attract 10% while non-exempted goods will suffer only 8%?</font></p>
<p align="justify"><font size="2" face="Verdana, Arial, Helvetica, sans-serif"><strong><a href="http://www.taxindiaonline.com/RC2/subCatDesc.php3?subCatDisp_Id=30&filename=notification/excise/2009/etariff09_04.htm" target="_blank">Notification No. 4/2009–CE Dated: February 24, 2009</a></strong></font></p>
<p align="center"><font color="#006600" size="2" face="Verdana, Arial, Helvetica, sans-serif"><strong>Customs duty rates reduced by two percent for certain products</strong></font></p>
<p align="justify"><font size="2" face="Verdana, Arial, Helvetica, sans-serif">On the Customs front the General Exemption Notification 21/2002- Cus Dated March 1, 2002 was amended on December 7, 2008 as a part of the stimulus package through Notification 128/2008- Cus Dated 7, 2008. There is a further amendment to this Notification wherein apart from reduction of CVD from 10% to 8% for goods against S. No. 226, 228, 236, 237, 344A , 399, 404 and 433 the sunset clause for import of Naphtha for generation of electricity except for captive consumption is deleted.</font></p>
<p align="justify"><font size="2" face="Verdana, Arial, Helvetica, sans-serif">The “__” confusion still remains! See our <strong><a href="http://www.taxindiaonline.com/RC2/inside2.php3?filename=bnews_detail.php3&newsid=8655" target="_blank">Breaking News</a>.</strong></font></p>
<p align="justify"><font color="#FF6600" size="2" face="Verdana, Arial, Helvetica, sans-serif">All the exemptions are effective from 24.02.2009 – these notifications were made available to the public only by evening of 24.02.2009. In fact we got more than a hundred calls from frantic assessees whether the reduced rates are applicable from 24th or 25th. Why create all this confusion? Why couldn't they calmly publish these notifications and make them applicable from the next day? Now there will be a lot of litigation on the amount of duty paid yesterday. Actually many of our callers had loaded trucks waiting and they were not sure as to which rate of duty should be charged.</font></p>
<p align="justify"><font color="#FF6600" size="2" face="Verdana, Arial, Helvetica, sans-serif">I was in a Central Excise Day meeting when one of these calls came and a Central Excise officer sitting next to me told me, “This caller is a confirmed evader – the rates are applicable only to those who pay duty – what difference does it make to him as to what the rate is when he will not pay the duty anyway.”</font></p>
<p align="justify"><font size="2" face="Verdana, Arial, Helvetica, sans-serif"><strong><a href="http://www.taxindiaonline.com/RC2/subCatDesc.php3?subCatDisp_Id=23&filename=notification/custom/2009/ctariff09_020.htm" target="_blank">Notification No. 20/2009– Cus Dated: February 24, 2009</a></strong></font></p>
<p align="center"><font color="#006600" size="2" face="Verdana, Arial, Helvetica, sans-serif"><strong>Service Tax on ‘maintenance or repair of roads' – Board Clarifies</strong></font></p>
<p align="justify"><font size="2" face="Verdana, Arial, Helvetica, sans-serif">Come election time, “ bijli+sadak+paani ” is back in the reckoning, whether we like it or not. In<a href="http://www.taxindiaonline.com/RC2/inside2.php3?filename=bnews_detail.php3&newsid=6764" target="_blank"> <strong>DDT-798-Dated-February 6, 2008</strong></a>, we reported that a request from the Chief Minister of Madhya Pradesh for exempting maintenance and/or repair of roads be exempted from levy of Service Tax was turned down by the Finance Ministry and a letter was issued by DGST to all the field formations to initiate action to recover service tax on this activity.</font></p>
<p align="justify"><font size="2" face="Verdana, Arial, Helvetica, sans-serif">In this regard we referred to a clarification issued vide F.No.B1 /6/2005- TRU, dated: July 27, 2005 wherein it was clarified that immovable property also includes roads and therefore maintenance or repair of roads would come under the purview of Management, Maintenance or Repair Service.</font></p>
<p align="justify"><font size="2" face="Verdana, Arial, Helvetica, sans-serif">But this time, the Commissioner from Nashik had raised a doubt on the taxability of maintenance or repair of roads. The latest clarification issued by the Ministry dispels the doubt on this subject by clarifying that maintenance or repair of roads is subject to levy of service tax. Strangely, the latest clarification does not make any reference to the DGST's clarification issued vide F.No . V/ DGST /30-Misc-16/2008448 dated: January 31, 2008 issued in the backdrop of the Madhya Pradesh CM's request.</font></p>
<p align="justify"><font size="2" face="Verdana, Arial, Helvetica, sans-serif">In
the latest Circular, the Board has clarified that though definition of taxable
services viz., ‘Commercial or Industrial Construction Service' and ‘Management,
Maintenance or Repair Service' do not specifically provide for levy of service
tax on <strong>construction of road</strong>, a conjoint reading of these
two definitions will lead to the conclusion that maintenance or repair of
roads is a taxable service under the purview of ‘Management, Maintenance
or Repair Service'.</font></p>
<p align="justify"><font size="2" face="Verdana, Arial, Helvetica, sans-serif">It was further clarified to distinguish the specific nature of activities under the category of ‘construction of road' and ‘maintenance/repair of road'. In this regard, “Maintenance or repair activities” includes resurfacing, renovation, strengthening, relaying and filling of potholes while “Construction Activities” includes laying of a new road, widening of narrow road to broader road (such as conversion of a two lane road to a four lane road) and changing road surface (gravelled road to metalled road/ metalled road to blacktopped/blacktopped to concrete etc).</font></p>
<p align="justify"><font size="2" face="Verdana, Arial, Helvetica, sans-serif">The field formations were directed to decide the pending cases basing on this clarification and also protect revenue.</font></p>
<p align="justify"><font size="2" face="Verdana, Arial, Helvetica, sans-serif">Now all the contractors engaged in maintenance/repair of roads may have to factor this levy and also the litigation cost while quoting their rates for the tenders called for in this regard by the authorities.</font></p>
<p align="justify"><font size="2" face="Verdana, Arial, Helvetica, sans-serif">Going by the logic of this latest clarification where Board has clarified that ‘construction of road' is excluded from the purview of service tax levy, we at <strong>TIOL </strong> fail to understand the logic of levying tax on maintenance and/or repair of such roads. In fact, in <strong><a href="http://www.taxindiaonline.com/RC2/inside2.php3?filename=bnews_detail.php3&newsid=6764" target="_blank">DDT-798</a> </strong> we raised a question on the propriety of levying tax on maintenance and/or repair of roads, as these roads belong to either Central Government or State Government or the local municipal bodies.</font></p>
<p align="justify"><font size="2" face="Verdana, Arial, Helvetica, sans-serif"><strong><a href="http://www.taxindiaonline.com/RC2/subCatDesc.php3?subCatDisp_Id=41&filename=notification/servicetax/2009/sercir110.htm" target="_blank">Circular No. 110/4/2009-ST Dated: February 23, 2009</a></strong></font></p>
<p align="center"><font color="#006600" size="2" face="Verdana, Arial, Helvetica, sans-serif"><strong>Export of Service Rules – CBEC clarifies the obvious – 126 Crores demand on Microsoft becomes a bunch of waste papers.</strong></font></p>
<p align="justify"><font size="2" face="Verdana, Arial, Helvetica, sans-serif">Unlike commodities, as the services are intangible in nature, it is very difficult to define what constitutes export of service given the dynamics of various business models. However, the job has become more or less easy after the ‘Export of Service Rules 2005' have been notified. All the services have been classified into three categories to define the export of services for each of those three categories.</font></p>
<p align="justify"><font size="2" face="Verdana, Arial, Helvetica, sans-serif">However, it seems the benefit of export of service is being denied in respect of some services on the ground that such services are <strong>not used outside India; </strong> Board has intervened and clarified whether the following services are to be considered as export of services.</font></p>
<blockquote>
<p align="justify"><font size="2" face="Verdana, Arial, Helvetica, sans-serif">i. Call centres engaged by foreign companies who attend to calls from customers or prospective customers from all around the world including from India;</font></p>
<p align="justify"><font size="2" face="Verdana, Arial, Helvetica, sans-serif">ii. Medical transcription where the case history of a patient as dictated by the doctor abroad is typed out in India and forwarded back to him;</font></p>
<p align="justify"><font size="2" face="Verdana, Arial, Helvetica, sans-serif">iii. Indian agents who undertake marketing in India of goods of a foreign seller. In this case, the agent undertakes all activities within India and receives commission for his services from foreign seller in convertible foreign exchange;</font></p>
<p align="justify"><font size="2" face="Verdana, Arial, Helvetica, sans-serif">iv. Foreign financial institution desiring transfer of remittances to India, engaging an Indian organisation to dispatch such remittances to the receiver in India. For this, the foreign financial institution pays commission to the Indian organisation in foreign exchange for the entire activity being undertaken in India.</font></p>
</blockquote>
<p align="justify"><font size="2" face="Verdana, Arial, Helvetica, sans-serif">It has been clarified that Export of Services Rules, 2005 categorizes the services into three types:</font></p>
<p align="justify"><font size="2" face="Verdana, Arial, Helvetica, sans-serif" align="left">i. <u>Category(I)[Rule3(1)(i)]</u> : For services (such as Architect service, General Insurance service, Construction service, Site Preparation service) that have some nexus with immovable property, it is provided that the provision of such service would be ‘export' if they are provided in relation to an immovable property situated outside India.</font></p>
<p align="justify"><font size="2" face="Verdana, Arial, Helvetica, sans-serif" align="left">ii. <u>Category(II)[Rule3(1)(ii)] </u>: For services (such as Rent-a-Cab operator, Market Research Agency service, Survey and Exploration of Minerals service, Convention service, Security Agency service, Storage and Warehousing service) where the place of performance of service can be established, it is provided that provision of such services would be ‘export' if they are performed (or even partly performed) outside India.</font></p>
<p align="justify"><font size="2" face="Verdana, Arial, Helvetica, sans-serif" align="left">iii. <u>Category(III)[Rule3(1)(iii)]</u> : For the remaining services (that would not fall under category I or II), which would generally include knowledge or technique based services, which are not linked to an identifiable immovable property or whose location of performance cannot be readily identifiable (such as, Banking and Other Financial services, Business Auxiliary services and Telecom services), it has been specified that they would be ‘export',-</font></p>
<blockquote>
<p align="justify"><font size="2" face="Verdana, Arial, Helvetica, sans-serif">(a) If they are provided in relation to business or commerce to a recipient located outside India; and</font></p>
<p align="justify"><font size="2" face="Verdana, Arial, Helvetica, sans-serif">(b) If they are provided in relation to activities other than business or commerce to a recipient located outside India at the time when such services are provided.</font></p>
</blockquote>
<p align="justify"><font size="2" face="Verdana, Arial, Helvetica, sans-serif">It is an accepted legal principle that the law has to be read harmoniously so as to avoid contradictions within legislation. Keeping this principle in view, the meaning of the term ‘used outside India' has to be understood in the context of the characteristics of a particular category of service as mentioned in sub-rule (1) of rule 3. For example, under Architect service (a Category I service [Rule 3(1)(i]), even if an Indian architect prepares a design sitting in India for a property located in U.K. and hands it over to the owner of such property having his business and residence in India, it would have to be presumed that service has been used outside India. Similarly, if an Indian event manager (a Category II service [Rule 3(1)(ii)]) arranges a seminar for an Indian company in U.K. the service has to be treated to have been used outside India because the place of performance is U.K. even though the benefit of such a seminar may flow back to the employees serving the company in India. For the services that fall under Category III [Rule 3(1)(iii)], the relevant factor is the location of the service receiver and not the place of performance. In this context, the phrase ‘used outside India' is to be interpreted to mean that the benefit of the service should accrue outside India. Thus, for Category III services [Rule 3(1)(iii)], it is possible that export of service may take place even when all the relevant activities take place in India so long as the <strong>benefits of these services accrue outside India</strong>.</font></p>
<p align="justify"><font color="#FF6600" size="2" face="Verdana, Arial, Helvetica, sans-serif">Netizens may recall our story in case of demand of service tax of Rs 126 Crores</font><font size="2" face="Verdana, Arial, Helvetica, sans-serif"> <strong><a href="http://www.taxindiaonline.com/RC2/inside2.php3?filename=bnews_detail.php3&newsid=7285">The 'real' and 'surreal' tax demands besiege Microsoft in India! </a></strong></font></p>
<p align="justify"><font color="#FF6600" size="2" face="Verdana, Arial, Helvetica, sans-serif">Microsoft India (Pvt) Ltd has entered into a “Market Development Agreement” with MO, Singapore under which the former will use its best efforts to further the interest of MO and maximize the markets for Microsoft products in India, Bhutan, Nepal and Maldives. For such service, Microsoft (India) Pvt Ltd will issue invoices in USD on MO Singapore. Microsoft (India) has been treating such income as export of service (under Business Auxiliary Service) and therefore has not paid any service tax on the income received. However, Delhi Service Tax Commissioner felt otherwise and issued demand notice. </font></p>
<p align="justify"><font color="#FF6600" size="2" face="Verdana, Arial, Helvetica, sans-serif">Now that the Board has clarified that the same has to be treated as export of service, the 126 Crores demand notice has no more value than a bunch of papers. But what about the ACRs written on the basis that “the officers detected evasion of service tax of Rs 126 crores ”? Will they be recalled and re-written?</font></p>
<p align="justify"><font size="2" face="Verdana, Arial, Helvetica, sans-serif"><strong><a href="http://www.taxindiaonline.com/RC2/subCatDesc.php3?subCatDisp_Id=41&filename=notification/servicetax/2009/sercir111.htm" target="_blank">Circular No.111 /05/2009-ST, Dated: February 24, 2009</a></strong></font></p>
<p align="center"><font color="#006600" size="2" face="Verdana, Arial, Helvetica, sans-serif"><strong>Central Excise Day</strong></font></p>
<p align="justify"><font size="2" face="Verdana, Arial, Helvetica, sans-serif">While Central Excise Day was being celebrated all over the Country in grand ways, the poor officers in the Board were busy with those stimulus notifications. That reminds one of the famous Lata Mangeshkar song –</font></p>
<p align="center"><font size="2" face="Verdana, Arial, Helvetica, sans-serif"><strong>JAB DESH ME THI DIWALI<br>
WO KHEL RAHE THE HOLI</strong></font></p>
<p align="center"><font size="2" face="Verdana, Arial, Helvetica, sans-serif"><strong>JAB HUM BAITHE THE GHARO ME<br>
WO JHEL RAHE THE GOLI</strong></font></p>
<p align="justify"><font size="2" face="Verdana, Arial, Helvetica, sans-serif">Even I had to forego my samosas at a Central Excise Day function to rush back to savour the notifications.</font></p>
<p align="justify"><font size="2" face="Verdana, Arial, Helvetica, sans-serif">With so much happening, we are sorry we are not able to report much about the Central Excise Day functions in various zones.</font></p>
<p align="justify"><font size="2" face="Verdana, Arial, Helvetica, sans-serif">However we can't resist the temptation to report that in Hyderabad, the Day was different with environmentalist Amala Akkineni, the charming yesteryear film star making an impressive presentation on Global Warming and former CESTAT Member Moheb Ali making a very humorous speech wherein he mentioned about the tax collector being like the bee which collects the honey without damaging the flower. “But the point is”, he said, “who asked the flower?”</font></p>
<p align="center"><font size="2" face="Verdana, Arial, Helvetica, sans-serif"><strong><font color="#006600">Jurispruden</font><font color="#FF6633" size="5">tiol</font><font color="#006600">–Tomorrow's cases</font></strong></font></p>
<p align="justify"><font size="2" face="Verdana, Arial, Helvetica, sans-serif"><strong><font color="#FF6633" size="2" face="Verdana, Arial, Helvetica, sans-serif"><strong><strong><strong><strong><strong><strong><strong><b><img src="http://www.taxindiaonline.com/RC2/image/stories/ddt_hammer.jpg" alt="Legal Corner Icon" width="100" height="84" hspace="5" border="0" align="left"></b></strong></strong></strong></strong></strong></strong></strong></font></strong></font><font color="#663399" size="2" face="Verdana, Arial, Helvetica, sans-serif"><strong>Income Tax</strong></font></p>
<p align="justify"><font color="#FF6600" size="2" face="Verdana, Arial, Helvetica, sans-serif"><strong>Even if agreement was not an agency agreement and it was a simple contract, amount received on termination of Contract can still be taxed as a revenue receipt : ITAT</strong></font></p>
<p align="justify"><font size="2" face="Verdana, Arial, Helvetica, sans-serif"><strong>THE</strong> assessee was deriving income from the business of running of several agencies. During the year under consideration, the assessee had received commission on account of agencies of 90 companies. The assessee was dealing in chemical products of several overseas companies. It had also an agency of Degussa AG (in short, ‘Degussa'), a German company. The agency agreement with Degussa was existing since 1-1-1969 though the formal agreement had been signed on 23-10-1972 applicable from 1-10-1972 which was automatically renewable at the end of the calendar year unless terminated by either party by giving a notice of three months. Though fresh agreements had been entered into from time to time, the terms and conditions basically remained the same. The last agreement had been signed on 10-6-1988 applicable from 1-1-1988. This agreement was being renewed from year to year. Degussa, however, gave a notice dated 21-7-1999 for termination of the agreement and, thereafter, a termination agreement was arrived at between the parties on 23-7-1999 as per which the assessee ceased to act as an agent of Degussa from 31-8-1999. From the said date, Degussa Hull (India), was appointed as an agent of the assessee.</font></p>
<p align="justify"><font color="#663399" size="2" face="Verdana, Arial, Helvetica, sans-serif"><strong>Customs</strong></font></p>
<p align="justify"><font color="#FF6600" size="2" face="Verdana, Arial, Helvetica, sans-serif"><strong>Pre-Deposit; power of waiver of pre-deposit has to be exercised such that the order of the assessing authority will be tested by appellate forum and it will not cause any serious prejudice to the revenue: Allahabad High Court</strong></font></p>
<p align="justify"><font size="2" face="Verdana, Arial, Helvetica, sans-serif"><strong>SINCE</strong> it is always the endeavour of this Court to have the matter decided on merits and where the order of revenue authority is subject matter of appeal but condition of pre-deposit is there in the statute before the appal can be entertained, the power of waiver of pre-deposit has to be exercised by the appellate authority considering over all facts and circumstances with a view that if a party gets opportunity to have matter decided on merit, the order of the assessing authority will be tested by appellate forum and it will not cause any serious prejudice to the revenue. On the contrary, it will get doubly sure about the correctness of the order and this will inspire confidence in the public in assessing that no particular, unjust and undue demand has been made by the revenue authorities.</font></p>
<p align="justify"><font color="#663399" size="2" face="Verdana, Arial, Helvetica, sans-serif"><strong>Central Excise</strong></font></p>
<p align="justify"><font color="#FF6600" size="2" face="Verdana, Arial, Helvetica, sans-serif"><strong>CENVAT Credit - Service Tax paid on Air Travel Agent's Commission and Real Estate Consulting Services – issue arguable; Pre-deposit ordered by Tribunal</strong></font></p>
<p align="justify"><font size="2" face="Verdana, Arial, Helvetica, sans-serif"><strong>LESSER</strong> the quantum of duty or CENVAT credit involved in a dispute, more problematic the case is – you do not usually find a decision which has final say in the matter, there are contrary decisions given by the same Bench and the issue boils over to such an extent that as a humble assessee you feel it is better to pay the amounts and buy peace rather than spending astronomical sums and taking the matter to the Apex Court. In fact, they would prefer to plough back the probable litigation expenses into their business. No doubt, there are some assessees who can afford and who will or should we say, should take their case to the highest court – it is a matter or principles, not merely a pyrrhic victory.</font></p>
<p align="justify"><font size="2" face="Verdana, Arial, Helvetica, sans-serif">But for revenue, a case is a case, whether it involves a rupee or a Crore and they are going to fight it out, rain or shine.</font></p>
<p align="justify"><font color="#663399" size="2" face="Verdana, Arial, Helvetica, sans-serif"><strong>See our columns Tomorrow for the judgements</strong></font></p>
<p align="justify"><font color="#FF6600" size="2" face="Verdana, Arial, Helvetica, sans-serif">Until Tomorrow with more<strong> DDT</strong></font></p>
<p align="justify"><font color="#FF6600" size="2" face="Verdana, Arial, Helvetica, sans-serif">Have a nice day.</font></p>
<p align="justify"><font color="#FF6600" size="2" face="Verdana, Arial, Helvetica, sans-serif">Mail your comments to</font><font size="2" face="Verdana, Arial, Helvetica, sans-serif"> <a href="mailto:vijaywrite@taxindiaonline.com">vijaywrite@taxindiaonline.com</a></font></p>
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