TIOL-DDT 1871 · the untouched capture
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<!DOCTYPE HTML PUBLIC "-//W3C//DTD HTML 4.01 Transitional//EN" "http://www.w3.org/TR/html4/loose.dtd"> <html> <head> <title>Untitled Document</title> <meta http-equiv="Content-Type" content="text/html; charset=iso-8859-1"> </head> <body> <p><font size="2" face="Verdana, Arial, Helvetica, sans-serif"><strong><font size="2" face="Verdana, Arial, Helvetica, sans-serif"><strong><font color="#663399" size="2" face="Verdana, Arial, Helvetica, sans-serif"><a href="http://www.taxindiaonline.com/RC2/inside2.php3?filename=bnews_detail.php3&newsid=14276"><img src="http://www.taxindiaonline.com/RC2/image/ddt/ddt_1794.jpg" alt="DDT in Limca Book of Records" width="175" height="120" hspace="5" border="0" align="right"></a></font></strong></font><font color="#663399" size="3">TIOL-DDT 1871 </font><br> 04.06.2012 <br> Monday </strong></font></p> <p align="center"><strong><font color="#006600" size="2" face="Verdana, Arial, Helvetica, sans-serif">CAG Evades Service Tax? Show Cause Notice to be issued? </font></strong></p> <p align="justify"><font size="2" face="Verdana, Arial, Helvetica, sans-serif"><strong>THE</strong> CAG is getting it back. Everyone is scared of the CAG but the CAG is answerable to none. DDT on several occasions had suggested that there should be an audit of the CAG, especially on the amount of money wasted because of the silly objections raised by the CAG. </font></p> <p align="justify"><font size="2" face="Verdana, Arial, Helvetica, sans-serif">Now the Nagpur Central Excise Commissioner seems to be ready to take the CAG by its horns. Commercial Audit wing of the Comptroller and Auditor General of India (C&AG) are conducting commercial audit of accounts of Government companies/corporations. For such audits, CAG charges fees from <em><strong>concerned </strong></em>entities. The Commissioner feels that the said services of conducting audit of accounts falls under taxable services of "<strong>Practicing Chartered Accountant, Practicing Cost Accountant and Practicing Company Secretary"</strong> Service which is defined under Section 65(105)(s)(t)(u) of Finance Act, 1994. However, CAG is not discharging its service tax liability all over India against said services provided by them. </font></p> <p align="justify"><font size="2" face="Verdana, Arial, Helvetica, sans-serif">The Chief Commissioner of Central Excise, Nagpur has written a letter to the Chief Commissioners in India that the inquiry conducted so far has revealed that the Office of AG (Audit-II), Nagpur is conducting audit of accounts of certain Central Public Sector Undertakings/ statutory corporations/ Autonomous organizations and are collecting fees/ charges from the <em><strong>concerned</strong></em> organisations for the same. Preliminary enquiry reveals that they have received Rs.3.3 Crores approx. from three organizations, in last <strong>five years</strong> for providing services, but have failed to pay Rs.33 lakhs as Service Tax on such taxable service provided by them. The investigation is being finalized shortly for issue of SCN. Further it has been noticed that commercial audit by AG's office Nagpur is conducted only a few cases at Nagpur and major activities are being undertaken in Metro Cities. </font></p> <p align="justify"><font size="2" face="Verdana, Arial, Helvetica, sans-serif">The Chief Commissioner, Nagpur tells the other Chief Commissioners, <em>"Since the issue has all India ramifications, the same is brought <strong>into </strong>your notice for further necessary action at your end"</em>.</font></p> <p align="justify"><font size="2" face="Verdana, Arial, Helvetica, sans-serif">So, the Nagpur Service Tax unit is getting ready to issue a Show Cause Notice to CAG. Most probably, the CAG will be charged with suppression and intent to evade tax – the notice would be for the last five years, and stuck with a mandatory penalty. </font></p> <p align="justify"><font size="2" face="Verdana, Arial, Helvetica, sans-serif">The Government's policy is not to exempt the Government from payment of Service Tax as it would result in distortions. The Board had in <strong><a href="http://www.taxindiaonline.com/RC2/subCatDesc.php3?subCatDisp_Id=41&filename=notification/servicetax/2006/sercir89.htm" target="_blank">Circular No. 89/7/2006 –S.T dated 18.12.2006</a></strong>, clarified, </font></p> <blockquote> <p align="justify"><font size="2" face="Verdana, Arial, Helvetica, sans-serif"><em>The Board is of the view that the activities performed by the sovereign/public authorities under the provision of law are in the nature of statutory obligations which are to be fulfilled in accordance with law. The fee collected by them for performing such activities is in the <strong>nature of compulsory levy as per the provisions of the relevant statute</strong>, and it is deposited into the Government treasury. Such activity is purely in public interest and it is undertaken as <u>mandatory and statutory function</u>. These are not in the nature of service to any particular individual for any consideration. Therefore, such an activity performed by a sovereign/public authority under the provisions of law does not constitute provision of taxable service to a person and, therefore, no service tax is leviable on such activities. </em></font></p> <p align="justify"><em><font size="2" face="Verdana, Arial, Helvetica, sans-serif">However, if such authority performs a service, which is not in the nature of statutory activity and the same is undertaken <strong>for a consideration not in the nature of statutory fee/levy</strong>, then in such cases, service tax would be leviable, if the activity undertaken falls within the ambit of a taxable service. </font></em></p> </blockquote> <p align="justify"><font size="2" face="Verdana, Arial, Helvetica, sans-serif">Now, will the CAG be covered in the above clarification? The Chief Commissioners are meeting in Delhi today and tomorrow for their annual conference. Will they discuss this issue? </font></p> <p align="center"><strong><font color="#006600" size="2" face="Verdana, Arial, Helvetica, sans-serif">CAG and Commercial Audit – A Peep into History </font></strong></p> <p align="justify"><font size="2" face="Verdana, Arial, Helvetica, sans-serif"><strong>STRANGE</strong> as it may sound, the CAG was originally of the opinion that the Government India had no business to start commercial enterprises and Government Companies were constituted unconstitutionally! </font></p> <p align="justify"><font size="2" face="Verdana, Arial, Helvetica, sans-serif">The Commercial Audit in the Indian Audit Department was set up in 1925 when a Chartered Accountant selected by the Secretary of State for India joined as Director of Commercial Audit in the AG's office. Somewhere down the line, this practice was discontinued. </font></p> <p align="justify"><font size="2" face="Verdana, Arial, Helvetica, sans-serif">At the time of independence, there were very few commercial concerns of the Government of India like Posts and Telegraphs, Government Railways, Ordnance factories, All India Radio…. They were run like departments of the Government. </font></p> <p align="justify"><font size="2" face="Verdana, Arial, Helvetica, sans-serif">In 1951, the then CAG Narahari Rao revived commercial audit by inducting a Controller of Commercial Audit in his office. </font></p> <p align="justify"><font size="2" face="Verdana, Arial, Helvetica, sans-serif">The Government of India decided to organise industrial undertakings as Limited Companies under the Companies Act to be managed by Boards of Directors appointed by the Government. </font></p> <p align="justify"><font size="2" face="Verdana, Arial, Helvetica, sans-serif">The CAG objected. It pointed out that: </font></p> <p align="justify"><font size="2" face="Verdana, Arial, Helvetica, sans-serif">"Industry is a State subject and a special legislation of Parliament was necessary under entry 7 or 52 of List I, Seventh Schedule, before the Union Government undertook, participated in or controlled an industry. And the withdrawal of moneys from the Consolidated Fund for the purpose was not constitutional. The formation of private companies under the Indian Companies Act for the management of Governmental industrial undertakings financed from the Consolidated Fund whittled away Parliamentary control over public money. Private companies would not be subject to the same degree of Parliamentary control, even though they were financed by Government out of funds released from the Consolidated Fund and not by private share capital. </font></p> <p align="justify"><font size="2" face="Verdana, Arial, Helvetica, sans-serif">The CAG would not have any automatic right to audit such a company, and it would be scarcely in accordance with the Constitution: that large sums of public money should be taken out of Parliamentary control, a substantial part of which was exercised on its behalf by the CAG. </font></p> <p align="justify"><font size="2" face="Verdana, Arial, Helvetica, sans-serif">Any request of the company to the CAG to be the Auditor, if necessary, by incorporating suitable provisions in its Articles of Association would be neither proper nor binding as the CAG's duties and functions were prescribed by Parliament, and cannot be regulated by the Articles of Association of a company. Furthermore, even if he undertook audit on a consent basis, on <strong>payment of fees</strong>, he can only submit his Audit Report to the company, and not to Parliament through the President. Parliament cannot watch through the PAC the regularity of the operations and the financial results of any such company". </font></p> <p align="justify"><font size="2" face="Verdana, Arial, Helvetica, sans-serif">While the CAG did not consider the investment constitutional and felt further legislation was necessary, and stuck to his view that the formation of a Private Company Limited without a specific statute authorising it was contrary to the Constitution, he <strong>agreed to conduct the audit</strong> <em>of the accounts of the factory on the consideration that by an improper diversion of funds it should not escape his audit scrutiny. </em></font></p> <p align="justify"><font size="2" face="Verdana, Arial, Helvetica, sans-serif"><strong>FRAUD ON STATUTE:</strong> V. Narahari Rao informed the Public Accounts Committee in December 1952 that the formation of private companies under the Indian Companies Act for the management of government industrial undertakings from the Consolidated Fund were, in his opinion, a fraud on the Companies Act and also on the Constitution, because money cannot be taken away from the Consolidated Fund for the establishment and transformation of certain concerns into private companies in the name of the President and Secretary to the Government. Conversion of a government concern into a private company solely by executive action was unconstitutional. </font></p> <p align="justify"><font size="2" face="Verdana, Arial, Helvetica, sans-serif">A.K. Chanda, the next CAG did not fully share the views of his predecessor regarding the legality of the company form of management and preferred to accept the opinion of the Attorney General, who held it intra vires of the provisions of Company Law: </font></p> <p align="justify"><font size="2" face="Verdana, Arial, Helvetica, sans-serif">In the initial allocations for the share capital of these enterprises, the members of Parliament did get an opportunity for discussing the investment. </font></p> <p align="justify"><font size="2" face="Verdana, Arial, Helvetica, sans-serif">Then came THE INDIAN COMPANIES ACT, 1956, which in Section 619 stipulated:- </font></p> <p align="justify"><font size="2" face="Verdana, Arial, Helvetica, sans-serif">(2) The auditor of a Government company shall be appointed or reappointed by the Central Government on the advice of the CAG of India : </font></p> <p align="justify"><font size="2" face="Verdana, Arial, Helvetica, sans-serif">(3) The Comptroller and Auditor General of India shall have power- </font></p> <blockquote> <p align="justify"><font size="2" face="Verdana, Arial, Helvetica, sans-serif">(a) to direct the manner in which the company's accounts shall be audited by the auditor appointed in pursuance of sub - section (2) and to give such auditor instructions in regard to any matter relating to the performance of his functions as such; </font></p> <p align="justify"><font size="2" face="Verdana, Arial, Helvetica, sans-serif">(b) to conduct a supplementary or test audit of the company's accounts by such person or persons as he may authorise in this behalf; and for the purposes of such audit, to require information or additional information to be furnished to any person or persons, and in such form, as the CAG may, by general or special order, direct. </font></p> </blockquote> <p align="justify"><strong><font size="2" face="Verdana, Arial, Helvetica, sans-serif">So, in most cases, Audit by the CAG is by invitation - only after accepting the invitation, he doesn't behave like a guest!</font></strong></p> <p align="center"><strong><font color="#006600" size="2" face="Verdana, Arial, Helvetica, sans-serif">Expenditure Management - Government Departments to tighten belts </font></strong></p> <p align="justify"><font size="2" face="Verdana, Arial, Helvetica, sans-serif"><strong>IN</strong> the context of the current fiscal situation where there is a tremendous pressure on Government's resources, there is an urgent need for rationalization of expenditure and optimization of available resources with a view to improve the macroeconomic environment, says the Secretary (Expenditure) in the Finance Ministry. He wants babus to spend less in all activities. </font></p> <p align="justify"><font size="2" face="Verdana, Arial, Helvetica, sans-serif"><strong>Cut in Non-Plan expenditure: </strong>For the year 2012 2013, Every Ministry/Department shall effect a mandatory 10% cut in non-Plan expenditure excluding interest payment, repayment of debt, Defence capital, salaries, pension and the Finance Commission grants to the States. No re-appropriation of funds to augment the non-Plan heads of expenditure on which cuts have been imposed, shall be allowed during the current year. </font></p> <p align="justify"><font size="2" face="Verdana, Arial, Helvetica, sans-serif"><strong>Seminars and Conferences:</strong> Utmost economy shall be observed in organizing conferences/Seminars/workshops. Only such conferences, workshops, seminars, etc. which are absolutely essential, should be held and even there a 10% cut on budgetary allocations for seminars/ conferences shall be effected. </font></p> <p align="justify"><font size="2" face="Verdana, Arial, Helvetica, sans-serif">Holding of exhibitions/seminars/conferences abroad is strongly discouraged except in the case of exhibitions for trade promotion. </font></p> <p align="justify"><font size="2" face="Verdana, Arial, Helvetica, sans-serif">There will be a ban on holding of meetings and conferences at five star hotels. </font></p> <p align="justify"><font size="2" face="Verdana, Arial, Helvetica, sans-serif"><strong>Purchase of vehicles:</strong> Purchase of vehicles is banned until further orders, including against condemned vehicles. (Who's buying vehicles now a days – they are all on fancy hired cars) </font></p> <p align="justify"><font size="2" face="Verdana, Arial, Helvetica, sans-serif"><strong>Foreign Travel:</strong> It would be the responsibility of the Secretary of each Ministry/Department to ensure that foreign travel is restricted to most necessary and unavoidable official engagements based on functional necessity and extant instructions, including on the number of visits, are strictly followed. </font></p> <p align="justify"><font size="2" face="Verdana, Arial, Helvetica, sans-serif"><strong>Creation of Posts:</strong> There will be a total ban on creation of Plan and Non-Plan posts. (<font color="#FF6633"><strong>No Cadre Review?</strong></font>)</font></p> <p align="justify"><a href="http://www.taxindiaonline.com/RC2/subCatDesc.php3?subCatDisp_Id=70&filename=pitara/oms/Office_Memorandum012.htm" target="_blank"><strong><font size="2" face="Verdana, Arial, Helvetica, sans-serif">Mof Expenditure Secretary's OM No. 7(1)E.Coord/2012 , Dated: May 31, 2012 </font></strong></a></p> <p align="center"><strong><font color="#006600" size="2" face="Verdana, Arial, Helvetica, sans-serif">Tariff Value - Hike in Poppy Seeds; Decrease for Brass Scrap, Gold and Silver </font></strong></p> <p align="justify"><font size="2" face="Verdana, Arial, Helvetica, sans-serif"><strong>GOVERNMENT</strong> has decreased the tariff values of Brass Scrap (all grades) from USD 4362 to USD 4270 and increased the tariff value of poppy seeds from USD 3680 to 3896. </font></p> <p align="justify"><font size="2" face="Verdana, Arial, Helvetica, sans-serif">The Tariff Value of Gold is decreased from 507 to 501 USD per 10 grams and the tariff value of silver is decreased from 920 to 899 per kilogram. Tariff value was fixed for gold and silver only recently by Notification No. <strong><a href="http://www.taxindiaonline.com/RC2/subCatDesc.php3?subCatDisp_Id=24&filename=notification/custom/2012/cnt12_002.htm" target="_blank">2/2012-Cus(NT)</a></strong> dated 13th January 2012. </font></p> <p align="justify"><font size="2" face="Verdana, Arial, Helvetica, sans-serif">There is no change in the tariff value of other items. </font></p> <p><a href="http://www.taxindiaonline.com/RC2/subCatDesc.php3?subCatDisp_Id=24&filename=notification/custom/2012/cnt12_047.htm" target="_blank"><strong><font size="2" face="Verdana, Arial, Helvetica, sans-serif">Notification No. 47/2012 - Cus.,(N.T.), Dated: May 31, 2012 </font></strong></a></p> <p align="center"><strong><font color="#006600" size="2" face="Verdana, Arial, Helvetica, sans-serif">CBEC Chief Commissioners' Conference Today </font></strong></p> <p><font size="2" face="Verdana, Arial, Helvetica, sans-serif"><strong>THE</strong> FM will address a two-day conference of the Chief Commissioners of Customs and Central Excise today at Vigyan Bhavan in New Delhi. The Conference is to discuss: </font></p> <blockquote> <p align="justify"><font size="2" face="Verdana, Arial, Helvetica, sans-serif">1. <strong>Negative List of Services and Common Tax Code of Central Excise and Service Tax:</strong> There is so much of negative opinion on this – let us hope the top officers would consider the feedback from the trade. </font> </p> <p align="justify"><font size="2" face="Verdana, Arial, Helvetica, sans-serif">2. <strong>Automation in CBEC – Review and Challenges</strong>: The Systems are almost falling apart – there is urgent need for a total revamp. </font> </p> <p align="justify"><font size="2" face="Verdana, Arial, Helvetica, sans-serif">3. <strong>Large Taxpayer Unit – Review and Future Road Map:</strong> It seems in LTU Mumbai, the Air Conditioners are not working and there are no fans – You can imagine the plight of people working there. It seems the Department has not paid a rent of over Rs. 2 Crores. The LTUs started with much fanfare are in shambles. </font> </p> <p align="justify"><font size="2" face="Verdana, Arial, Helvetica, sans-serif">4. <strong>Motivation and Image Building</strong>. How can you motivate a staff that do not get promotions and proper transfers and then have to work in squalor? </font></p> </blockquote> <p align="justify"><font size="2" face="Verdana, Arial, Helvetica, sans-serif">And do you really need a Chief Commissioners' conference? Why can't they have a videoconference instead of so many top officers travelling to Delhi and incurring huge expenditure on their travel, stay, protocol and other paraphernalia? The Expenditure Secretary should have started his austerity drive from the Finance Ministry. </font></p> <p align="center"><font color="#006600" size="2" face="Verdana, Arial, Helvetica, sans-serif"><strong>Measure the Irrelevant</strong></font></p> <p><font size="2" face="Verdana, Arial, Helvetica, sans-serif"><strong>TWO</strong> anecdotes:</font></p> <p align="justify"><font size="2" face="Verdana, Arial, Helvetica, sans-serif">A dhabha where, as is to be expected, the food was delightful. A guest after enjoying the meal washed his hands and asked for a towel to dry them. The towel that was proffered was so filthy that he was driven to protest. The dhabha owner was perplexed. He replied <em>"Saab! Hazaron log use kiye hain; abhi tak koi complaint kiye nahi!"</em> (Sir! A thousand people have used that towel and nobody has complained!) </font></p> <p align="justify"><font size="2" face="Verdana, Arial, Helvetica, sans-serif">This concerns a seller of <em>gud</em> in a <em>mandi</em> in Rajasthan. Noticing that the whole mound of <em>gud</em> was covered with flies, a young police officer asked the shopkeeper to do something about it. The shopkeeper was unperturbed. He said: <em>“Wo kitna kha sakta hai, saab!''</em> (How much can they eat, sir!) </font></p> <p align="justify"><em><font size="2" face="Verdana, Arial, Helvetica, sans-serif">"These anecdotes tell us a great deal about our culture. One, as in the case of the dirty towel, we are content with the barest minimum utility and have no concern for quality. Two, as in the case of flies, we measure what is irrelevant. We are backward in technology not because we do not have the materials, not because we do not have the talent, not because we do not have the money, not even because we cannot get the technology. We are backward because, as Mancur Olson has postulated, our culture makes us think poor." - </font></em><font size="2" face="Verdana, Arial, Helvetica, sans-serif">Prof. P V Indiresan, the legendary former director of IIT, Madras, who is our Guest Columnist today. Please see our <strong><a href="http://www.taxindiaonline.com/RC2/inside2.php3?filename=bnews_detail.php3&newsid=15144" target="_blank">Guest Column </a></strong></font></p> <p align="center"><font size="2" face="Verdana, Arial, Helvetica, sans-serif"><strong><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"> – Tuesday's cases</font></strong></font></strong></font></p> <p><strong><font color="#663399" size="2" face="Verdana, Arial, Helvetica, sans-serif"><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">Customs</font></strong></p> <p align="justify"><strong><font color="#FF6633" size="2" face="Verdana, Arial, Helvetica, sans-serif">Import of Zircon Sand - Benefit of Exemption under Notification No.4/2006-C.E for payment of CVD - Notification provides for exemption to Ores but not for concentrates - Dispute regarding Zircon Sand is Ore or Concentrate - During pendency of appeal before CESTAT, imported consignments ordered for clearance on payment of 25% of duty amount and on execution of a bond to pay assessed amount: HC</font></strong></p> <p align="justify"><font size="2" face="Verdana, Arial, Helvetica, sans-serif"><strong>THE </strong>benefit of exemption is available to Ores but not for Concentrates – Dispute regarding Zircon Sand is Ore or Concentrate - In the test report of the samples, a strange view was sought to be taken that Zircon content is 98.3% and the product thereof is Zircon concentrate - Retest of samples not allowed - The proper officer held that the product in question is "Zircon concentrate" and not exempted under Notification No. 4/2006-CE - Commissioner (A) upheld the order of the Deputy Commissioner - Appellants filed appeal before CESTAT, which is pending – Other importers clearing ‘Zircon Sand' without payment of CVD through other ports - Under the existing law, so long the decision passed by the Commissioner (A) is not set aside by the higher appellate authority, the petitioner is bound to pay the duty imposed in order to clear the imported goods - At this stage, there is no alternative remedy prescribed by law - the petitioner is required to run its business in a disadvantageous situation by selling its product at a comparable lower profit than the one earned by the other competitors in the field who will clear the same goods from other ports not situated in this State without payment of the CVD. </font></p> <p align="justify"><strong><font color="#663399" size="2" face="Verdana, Arial, Helvetica, sans-serif">Income Tax </font></strong></p> <p align="justify"><strong><font color="#FF6633" size="2" face="Verdana, Arial, Helvetica, sans-serif">Whether when UTI units held by assessee for long period get converted into tax-free bonds by a Govt decision, such conversion amounts to transfer, and losses resulting from such transfer are allowable - NO, rules ITAT </font></strong></p> <p align="justify"><font size="2" face="Verdana, Arial, Helvetica, sans-serif"><strong>ASSESSEE</strong> is a Company engaged in the business of manufacturing of automobiles tyre tubes, valves and accessories. It filed its ROI claiming long term capital loss. The assessee was keeping certain units of UTI and by flux of time these units were converted into tax free bonds by the Govt. As a result of which the assessee suffered these losses. The Assessee claimed these losses as capital loss. The AO during the course of assessment proceedings disallowed these losses on the ground that for capital loss there must be a transaction of transfer behind the transaction and further the losses attributable to those income which did not form part of total income were not allowable. The CIT(A) affirmed the finding of the AO. </font></p> <p align="justify"><strong><font color="#663399" size="2" face="Verdana, Arial, Helvetica, sans-serif">Central Excise </font></strong></p> <p align="justify"><strong><font color="#FF6600" size="2" face="Verdana, Arial, Helvetica, sans-serif">Waiver of pre-deposit does not fall under any of enumerated categories in Sec 22 of Sick Industrial Companies Act - protection thereunder not available to assessee: CESTAT </font></strong></p> <p align="justify"><font size="2" face="Verdana, Arial, Helvetica, sans-serif"><strong>THE </strong>applicants availed credit of Rs.43,62,547/- without any duty paying documents and remaining credit on the strength of Xerox copies of invoices. In these circumstances, it is not a case for total waiver of dues. The Hon'ble Supreme Court in the case of <em>Metal Box India Ltd. vs. CCE, Mumbai</em> <strong><a href="http://www.taxindiaonline.com/RC2/subCatDesc.php3?subCatDisp_Id=32&filename=legal/sc/2003/2003-TIOL-66-SC-CX.htm" target="_blank"><font size="1">(2003-TIOL-66-SC-CX)</font></a></strong> held that waiver of pre-deposit covered under Sec.35F of the Central Excise Act does not fall under any of the enumerated categories in Sec.22 of the Sick Industrial Companies (Special Provisions) Act, 1985, protection thereunder not available to the assessee. </font></p> <p align="justify"><strong><font color="#663399" size="2" face="Verdana, Arial, Helvetica, sans-serif">See our columns Tomorrow for the judgements </font></strong></p> <p align="justify"><font color="#FF6666" size="2" face="Verdana, Arial, Helvetica, sans-serif">Until Tomorrow with more <strong>DDT</strong></font></p> <p align="left"><font color="#FF6666" size="2" face="Verdana, Arial, Helvetica, sans-serif">Have a Nice Day</font></p> <div align="justify"><font color="#FF6666" size="2" face="Verdana, Arial, Helvetica, sans-serif">Mail your comments</font><font color="#FF6633" size="2" face="Verdana, Arial, Helvetica, sans-serif"> </font><font size="2" face="Verdana, Arial, Helvetica, sans-serif">to <a href="mailto:vijaywrite@taxindiaonline.com"><strong>vijaywrite@taxindiaonline.com </strong></a></font> </div> </body> </html>