TIOL-DDT 2300 · the untouched capture
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<p align="justify"><font size="2" face="Verdana, Arial, Helvetica, sans-serif"><strong><strong><strong><strong><strong><strong><strong><strong><strong><strong><strong><strong><strong><strong><strong><strong><strong><strong><strong><strong><strong><strong><strong><strong><strong><strong><strong><strong><strong><strong><strong><strong><strong><strong><strong><font color="#006600"><strong><strong><strong><strong><strong><strong><strong><strong><strong><img width="115" height="125" border="0" align="right" src="image/ddt/10yearsDDT.jpg" alt="" /></strong></strong></strong></strong></strong></strong></strong></strong></strong></font></strong></strong></strong></strong></strong></strong></strong></strong></strong></strong></strong></strong></strong></strong></strong></strong></strong></strong></strong></strong></strong><font color="#006600"><strong><strong><strong><strong><strong><strong><strong><strong><strong><a href="http://www.taxindiaonline.com/RC2/inside2.php3?filename=bnews_detail.php3&newsid=17063"><img width="175" hspace="5" height="120" border="0" align="right" src="http://www.taxindiaonline.com/RC2/image/stories/limca_book2013.jpg" alt="DDT in Limca Book of Records" /></a></strong></strong></strong></strong></strong></strong></strong></strong></strong></font></strong></strong></strong></strong></strong></strong></strong></strong></strong></strong></strong></strong></strong><font color="#663399" size="3">TIOL-DDT 2300 </font><br>
24.02.2014 <br>
Monday </strong></font></p>
<p align="center"><font color="#006600" size="2" face="Verdana, Arial, Helvetica, sans-serif"><strong>DGFT cannot Legislate - High Court</strong></font></p>
<p align="justify"><font size="2" face="Verdana, Arial, Helvetica, sans-serif"><strong>A </strong>meeting of the Policy Interpretation Committee was held under the Chairmanship of the DGFT on 15.03.2011. Zonal Jt.DGFTs and the RAs brought to the notice of the Committee their inability to settle the Deemed Export claims due to inadequate Budget Provision. They informed that in all offices there has been large number of pending cases. DG informed the Committee that Rs. 2,000 crores has been allotted in the Supplementary Appropriation which would be received shortly. This amount needs to be utilized in the current financial year itself that is before 31st March 2011. Dr. L.B. Singhal, Jt.DGFT, referred to the Public Notice No.35 issued on 1st March 2011 which amended para 8.3.1 of Handbook of Procedure, Vol. I and Appendix of ANF-8 and explained the background. Provisions of PN 35 and Notification 28 have to be mandatorily followed for any payment of duty drawback claims/refund of Terminal Excise Duty henceforth.</font></p>
<p align="justify"><font size="2" face="Verdana, Arial, Helvetica, sans-serif">Regarding <strong>refund
of Terminal Excise Duty (TED) for supplies to non-mega power projects,
it was clarified that Para 8.4.4(iv) of Foreign Trade Policy, 2009-14 clearly
stipulates that the benefit of refund of TED under para 8.3(c) of the Policy
is not available for such supplies. </strong>In such cases excise duty
paid at the terminal stage of supply (last instance of excise duty paid
in the chain of manufacture process in the supply) is not to be refunded
in any manner <strong>including as drawback </strong> [para 8.3(b) of Policy].</font></p>
<p align="justify"><font size="2" face="Verdana, Arial, Helvetica, sans-serif">Recovery notices flew in all directions.</font></p>
<p align="justify"><font size="2" face="Verdana, Arial, Helvetica, sans-serif">Recently the Gujarat High Court held that the DGFT had no power to legislate and the power to frame Duty Draw Back Rules can be legislated by the Central Government only and the same cannot be delegated to the DGFT.</font></p>
<p align="justify"><font size="2" face="Verdana, Arial, Helvetica, sans-serif">We bring you this judgement today. Please see <strong><a href="http://www.taxindiaonline.com/RC2/inside2.php3?filename=bnews_detail.php3&newsid=19851" target="_blank">Breaking News</a></strong>.</font></p>
<p align="center"><font color="#006600" size="2" face="Verdana, Arial, Helvetica, sans-serif"><strong>Foreign Trade Policy - History</strong></font></p>
<p align="justify"><font size="2" face="Verdana, Arial, Helvetica, sans-serif"><strong>UNDER</strong> British regime the import of goods from Great Britain was encouraged and the export of goods from India and the import of goods from other developed countries was discouraged by imposition of higher customs duties. The statutory mechanism for controlling foreign trade was the Sea Customs Act, 1878. Regarding imports and exports, the Government of India Act, 1935 granted an exclusive power to the Centre to legislate on the subject. But no specific enactment was passed by the Central Legislature.</font></p>
<p align="justify"><font size="2" face="Verdana, Arial, Helvetica, sans-serif">During the Second World War, under the compulsive necessity created by the scarce foreign exchange resources and the acute shortage of shipping space in the Indian ports, a notification under the Defence of India Rules was issued in 1939, bringing under control the import of 68 commodities. Steadily other notifications were issued bringing more items under control. In July, 1943 a consolidated notification was issued covering a wide range of controlled items. With the end of the Second World War, the Defence of India Rules lapsed but the provisions regarding import control instructions were continued by virtue of the Emergency Provisions (Continuance) Ordinance, 1946 which was replaced, in so far as the imports and exports control is concerned, by the Imports and Exports (Control) Act, 1947. It came into force for a period of three years but was extended from time to time.</font></p>
<p align="justify"><font size="2" face="Verdana, Arial, Helvetica, sans-serif">In 1971 it became a permanent statute. By the Imports and Exports (Control) (Amendment) Ordinance, 1975, changes of far reaching character were made in the Imports and Exports (Control) Act, 1947. The Ordinance was replaced by the Imports and Exports (Control) (Amendment) Act, 1976. In spite of changes made by the Act of 1976 the Imports and Exports (Control) Act, 1947 continued to suffer from deficiencies. The legal regime set up under the Act, 1947 became out-dated and hindered the growth and development of India's foreign trade. Consequently, on 19th June, 1992, the President of India promulgated the Foreign Trade (Development and Regulation] Ordinance repealing the Imports and Exports (Control) Act, 1947. To replace the Foreign Trade (Development and Regulation) Ordinance, 1992, the Foreign Trade (Development and Regulation) Bill was introduced in the Parliament with the following statement of objectives and reasons:</font></p>
<p align="justify"><font size="2" face="Verdana, Arial, Helvetica, sans-serif">It is now generally acknowledged that foreign trade is the driving force of economic activity. Technology, investment and production are becoming increasingly interdependent upon each other and foreign trade brings these elements together and spurs economic growth.</font></p>
<p align="justify"><font size="2" face="Verdana, Arial, Helvetica, sans-serif">The Imports and Exports (Control) Act, 1947 was made under the then prevailing circumstances. Since the Act did not provide an adequate legal frame work for the development and promotion of India's foreign trade, it was amended from time to time. Besides, in July, 1991 and August, 1991, major changes in trade policy were made by the Government of India. The goals of the new trade policy are to increase productivity and competitiveness and to achieve a strong export performance. The Exports and Import Policy is a vital part of trade policy. The basic law governing foreign trade must serve as an instrument to create an environment that will provide a strong impetus to exports, facilitate imports and render export activity more profitable.</font></p>
<p align="justify"><font size="2" face="Verdana, Arial, Helvetica, sans-serif">The above extract is from the judgement in the DGFT case referred to above. </font></p>
<p align="justify"><font size="2" face="Verdana, Arial, Helvetica, sans-serif">Finance Minister Chidambaram once recounted an interesting experience:</font></p>
<blockquote>
<p align="justify"><font size="2" face="Verdana, Arial, Helvetica, sans-serif">"<em>I was introduced to a gentleman who introduced himself as the Chief Controller of Imports and Exports. I asked him, little knowing that within a month, I would become his Minister: I understand why you are the chief controller of imports, but please tell me why you are the chief controller of exports? He had no answer and within a month when I was his Minister I told him I am abolishing your post </em>."</font></p>
</blockquote>
<p align="center"><font color="#006600" size="2" face="Verdana, Arial, Helvetica, sans-serif"><strong>FTP - Export Obligation - Extended</strong></font></p>
<p align="justify"><font size="2" face="Verdana, Arial, Helvetica, sans-serif"><strong>GOVERNMENT</strong> has amended Foreign Trade Policy to insert a new para 5.5.1(c), which reads as:</font></p>
<p align="justify"><font size="2" face="Verdana, Arial, Helvetica, sans-serif">5.5.1 (c): Wherever the holder of any EPCG Authorization is granted relief under Corporate Debt Restructuring (CDR), then such Authorization holder may be allowed EO extension of 3 years (from the date of approval of the CDR mechanism/scheme). Such extension in EO will not attract any Composition fee and will be in addition to (and not in lieu of) the granting of EO extension, if any, available under Para 5.11 of HBPv1.</font></p>
<p align="justify"><a href="http://www.taxindiaonline.com/RC2/subCatDesc.php3?subCatDisp_Id=45&filename=notification/dgft/2013/dgft13not070.htm" target="_blank"><font size="2" face="Verdana, Arial, Helvetica, sans-serif"><strong>DGFT Notification No. 70 (RE-2013)/2009-2014, Dated: February 20, 2014</strong></font></a></p>
<p align="center"><font color="#006600" size="2" face="Verdana, Arial, Helvetica, sans-serif"><strong>Order passed Nine months after conclusion of hearing cannot survive</strong></font></p>
<p align="justify"><font size="2" face="Verdana, Arial, Helvetica, sans-serif"><strong>THIS</strong> is what the almost nine years old CENTRAL EXCISE MANUAL OF CBEC'S INSTRUCTIONS says in Chapter 13, Part-II, titled 'Adjudication' -</font></p>
<blockquote>
<p align="justify"><font size="2" face="Verdana, Arial, Helvetica, sans-serif"><em>"4. <strong>Time limit for issue of adjudication orders </strong>: The demands on account of short levy, non-levy or erroneous refund, by reason of fraud collusion, willful mis-statement or suppression of facts shall be adjudicated within a period of one year from the date of issue of show cause notice, where it is possible { Clause (a) of Sub-section 2A of Section 11A of Central Excise Act, 1944 }. In any other case, as far as possible, the case shall be adjudicated within a period of six months {Clause (b) of Sub-section 2A of Section 11A ibid}.</em></font></p>
<p align="justify"><em><font size="2" face="Verdana, Arial, Helvetica, sans-serif">All cases where personal hearings have been concluded, it is necessary to communicate the decision immediately or within a reasonable time of <strong><font color="#FF0000">5</font> </strong>days. If the above time limit cannot be adhered to under any circumstances, the order should be issued within <strong><font color="#FF0000">15 days or at the most one month from the date of conclusion of personal hearing</font> </strong>(Board's Circular No. <strong>732/48/2003-CX </strong>dated 5.8.2003)."</font></em></p>
</blockquote>
<p align="justify"><font size="2" face="Verdana, Arial, Helvetica, sans-serif">In many Commissionerates there are a lot many orders shown as being passed on 31st March of every year to reduce the pendency figures and also as a measure of Revenue drive but the fact of the matter is that these orders are never given birth on 31st March but see the light of the day only in the month of July or later. Apart from the Revenue drive, what drives these adjudicating authorities to pass orders @speed of light is that their appraisals heavily lean on the disposals they make in the reporting period April to March. Needless to mention, the hearings are conducted (a farcical exercise, on occasions) before or on the supposed date of the order. Before the amendments made by the Finance Act, 2005, the Review cell in the Commissionerate and at the CC office had to burn the midnight oil for the review period of one year commenced from the date of the order and not from the date of communication of the order. The assessee was not affected because for them the appeal period commenced from the date of communication of the order. Be that as it may, there have been occasions when the adjudicating authority showed the O-in-O's as being passed on 31st March but then saw himself being transferred in the Annual Transfer order. And the officer who came next had to face embarrassment in case the officer transferred did not sign the orders with back dated signatures.</font></p>
<p align="justify"><font size="2" face="Verdana, Arial, Helvetica, sans-serif">The order which we are reporting today would be a godsend gift to many assessees who find such acts of the adjudicating authorities under the purported aegis of the Act <em>byzantine.</em></font></p>
<p align="justify"><font size="2" face="Verdana, Arial, Helvetica, sans-serif">See <strong><a href="http://www.taxindiaonline.com/RC2/inside2.php3?filename=bnews_detail.php3&newsid=19845" target="_blank">Breaking News.</a></strong></font></p>
<p align="center"><font color="#006600" size="2" face="Verdana, Arial, Helvetica, sans-serif"><strong>Rules for Issuing Pan Card</strong></font></p>
<p align="justify"><font size="2" face="Verdana, Arial, Helvetica, sans-serif"><strong>THE</strong> Income Tax Department has made changes in rules for issuing Permanent Account Number (PAN) Card. It has vide notification S.O. 3794 (E) dated 23.12.2013, amended Rule 114 of the Income-tax Rules, 1962 to provide, inter alia, that the application for allotment of PAN shall be accompanied by proof of date of birth of the applicant in addition to proof of identity (POI)/proof of address (POA). The notification has also amended the prescribed list of documents which can be furnished as POI/POA and Aadhar Card has been included as one of the POI and POA document.</font></p>
<p align="justify"><font size="2" face="Verdana, Arial, Helvetica, sans-serif">The number of PAN Card holders in the country as on 17.2.2014 is 20.24 crores. So far, 9.73 lakhs PAN have been issued where Aadhar has been captured and seeded in PAN database to maintain uniqueness.</font></p>
<p align="justify"><font size="2" face="Verdana, Arial, Helvetica, sans-serif">Identification of bogus/duplicate PAN Card is an integral part of the data management system. In order to ensure that bogus PAN cards are not issued, the Income-tax Department has started capturing Aadhar number, in PAN application forms in cases where it is available so that the additional uniqueness is brought in PAN allotment process.</font></p>
<p align="justify"><font size="2" face="Verdana, Arial, Helvetica, sans-serif">This information was given by the Minister of State for Finance, J.D. Seelam in written reply to a question in LokSabha on Friday.</font></p>
<p align="justify"> </p>
<p align="center"><font color="#006600" size="2" face="Verdana, Arial, Helvetica, sans-serif"><strong>Carrying/Wearing Gold for Passengers Flying from Abroad to India- No Change in Customs Rules</strong></font></p>
<p align="justify"><font size="2" face="Verdana, Arial, Helvetica, sans-serif"><strong>MINISTER</strong> of State for Finance, J.D. Seelam in a written reply to a question in LokSabha on Friday said,</font></p>
<blockquote>
<p align="justify"><font size="2" face="Verdana, Arial, Helvetica, sans-serif"><em>"There is no proposal under consideration of the Government to modify the existing rules with regard to carrying/wearing gold for passengers flying from abroad to India. In the Budget 2012-13, the Baggage Rules, 1998 regarding carrying/wearing gold for Indian passengers flying from abroad to India after residing abroad for over one year was modified to increase the limit of jewellery free of duty upto an aggregate value of Rs. 5000 <font color="#FF0000">(this is actually Rs. 50,000)</font> by a male passenger and Rs. 1,00,00 (</em></font><font size="2" face="Verdana, Arial, Helvetica, sans-serif" style="background-color:#FFFF00" span="span"><font size="2" face="Verdana, Arial, Helvetica, sans-serif"><em><font color="#FF0000">the comma is right but the zero is missing - it is actually Rs.1,00,000</font></em></font> </font><font size="2" face="Verdana, Arial, Helvetica, sans-serif"><em> by a female passenger."</em></font></p>
</blockquote>
<p align="justify"><font size="2" face="Verdana, Arial, Helvetica, sans-serif">But the Hindi version has got it correct for a female passenger while retaining the wrong figure for male passengers. </font></p>
<div align="center"><font size="2" face="Verdana, Arial, Helvetica, sans-serif"><strong><strong><strong><font color="#663399"><img src="http://www.taxindiaonline.com/RC2/image/stories/wrong_figure.jpg" alt="" width="600" height="200" hspace="5" border="0" align="center"></font></strong></strong></strong></font>
</div>
<p align="center"><font color="#006600" size="2" face="Verdana, Arial, Helvetica, sans-serif"><strong>Service Tax Demand on Nirmal Baba</strong></font></p>
<p align="justify"><font size="2" face="Verdana, Arial, Helvetica, sans-serif"><strong>IT</strong> is reported that the DG, CEI has slapped a demand of over Rs. 3 Crores on Nirmal Baba on the entry fee he collects for his meetings.</font></p>
<p align="justify"><font size="2" face="Verdana, Arial, Helvetica, sans-serif">Nirmal Baba conducts SAMAGAM, for which the Registration fee is Rs. 3000/- and a NIRMAL BABA SHOW for which the fee is Rs. 5000/-. Entry to Samagam and the Show are by prior booking only. Baba's website declares that the next Samagam in Delhi is on 12th April 2014 and bookings are open. The next SHOWs in Delhi are on 6th April, 10th May and 11th May 2014. It is HOUSE FULL for the first two days and bookings are open for the third day. The website also says that the fee is inclusive of taxes - it does not mention which taxes.</font></p>
<p align="justify"><font size="2" face="Verdana, Arial, Helvetica, sans-serif">Will Modi object to Service Tax on Nirmal Baba?</font></p>
<p align="justify"> </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"><strong>ON</strong> the occasion of 'Central Excise Day and Investiture Ceremony', Minister of State for Finance (Revenue), JD Seelam will give Presidential Certificates of Appreciation to Officers and Staff of Central Board of Excise and Customs (CBEC) Today, 24th February, 2014 at 2.15 pm at FICCI Golden Jubilee Auditorium, Tansen Marg, New Delhi.</font></p>
<p align="center"><font color="#006600" size="2" face="Verdana, Arial, Helvetica, sans-serif"><strong>Happy Central Excise Day</strong></font></p>
<p align="center"><font size="2" face="Verdana, Arial, Helvetica, sans-serif"><strong><strong><strong><font color="#663399"><img src="http://www.taxindiaonline.com/RC2/image/stories/CX_Day.jpg" alt="" width="500" height="242" hspace="5" border="0" align="center"></font></strong></strong></strong><br>
<br>
<strong><strong><font color="#006600">Jurispruden</font><font color="#FF6633" size="5">tiol</font><font color="#006600"> - Tuesday's cases</font></strong></strong></font></p>
<p align="justify"><font size="2" face="Verdana, Arial, Helvetica, sans-serif"><strong><strong><strong><font color="#663399"><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"></font></strong></strong><font color="#663399">Foreign Trade Policy</font></strong></font></p>
<p align="justify"><font color="#FF6633" size="2" face="Verdana, Arial, Helvetica, sans-serif"><strong>FTP - Refund of Terminal Excise Duty - Clearance to EOU - Deemed export entitled for refund of TED: HC</strong></font></p>
<p align="justify"><font size="2" face="Verdana, Arial, Helvetica, sans-serif"><strong>SUPPLIES</strong> made to EOUs in terms of para 8.2(b) are entitled to be regarded as deemed exports. The benefits for deemed exports include inter alia refund of TED. The authorities in this case appear to have proceeded to make an order adverse to the petitioner and proceeded to hold that the petitioner was disentitled to the benefit of refund in view of some clarification given by the Policy Interpretation Committee, in its meeting of 04.12.2012 to the effect that "refund of CENVAT credit provisions are available under Excise rules and CENVAT rules which should be availed of rather than claiming refund". This reasoning appears to have prevailed with the Policy Relaxation Committee as well in this case. The Court is unable to comprehend the rationale of the decision. Neither of the authorities dispute that the petitioner supplied goods to the EOU at the relevant time. Its entitlement, therefore, was defined in terms of the existing policy, i.e. refund in terms of paras 8.2, 8.3, 8.4 and 8.5 of the 2009 policy. That a subsequent amendment was made to the existing regime which in effect liberalized the position further and exempted payment of TED altogether cannot surely be a reason for denying the scheme for refund of payment already made.</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"><font color="#FF6633" size="2" face="Verdana, Arial, Helvetica, sans-serif"><strong>Whether mere filing of application for settlement adversely affects powers of Assessing Officer in any manner - NO: High Court</strong></font></p>
<p align="justify"><strong><font size="2" face="Verdana, Arial, Helvetica, sans-serif">THE</font></strong><font size="2" face="Verdana, Arial, Helvetica, sans-serif"> assessee is an individual. It had challenged an order passed by SETCOM, which rejected the assessee's application that the assessment for the period 01.04.1986 to 07.04.1987 was time barred. On 07.08.1997, search and seizure operations were conducted at the residential and business premises in respect of assessee, his wife and other relatives. Several articles and documents were seized. The last panchnama was drawn on 26.09.1997. Upon receipt of notice, assessee filed a return for the period 01.04.1986 to 07.04.1987. After considering this, the Income Tax Authorities were of the opinion that the accounts indicated had sufficient complexities warranting an audit u/s 142(2)A. A special auditor submitted the audit report on 14.02.2000. It was contended during the pendency of these proceedings that SETCOM by its order had entertained the application made to it. The order was a speaking one and made after submissions of the parties and was drawn up by the departmental authorities. Whilst the SETCOM's proceedings were pending, an order u/s 245 D (4) was contemplated and heard. Assessee had contended that the entire proceedings had to be closed since the block assessment had become time barred on 29.02.2000. It was submitted that by virtue of the then existing Section 158BE, which mandated that assessment were to be completed within a time bound manner which was to expire on 29.02.2000 (the period having been extended by virtue of special audit conducted u/s 142). In the absence of any order by SETCOM admitting the matter or proceeding further, AO had the lost authority to pass any orders. Consequently, the Commission itself did not possess jurisdiction. After hearing counsel for the parties, SETCOM rejected the assessee's argument.</font></p>
<p align="justify"><font size="2" face="Verdana, Arial, Helvetica, sans-serif">THE issues before the Bench are - Whether mere filing of an application for settlement would adversely affect the powers of the Assessing Officer in any manner; Whether the SETCOM is allowed to review its own order and Whether the remedy provided under section 245C, as a machinery provision for effecting settlement of tax disputes, is only in the nature of a option open to the assessee who desired to settle his tax matters. And the matter goes against the assessee.</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"><font color="#FF6633" size="2" face="Verdana, Arial, Helvetica, sans-serif"><strong>CENVAT - Transfer of credit on sale of factory - Condition of transfer of liability is applicable when there is a change in site of factory resulting from sale, merger, amalgamation or transfer to a joint venture - in the present case, factory has not been shifted to anywhere but only the ownership has been changed - condition of transfer of liability is not applicable to transfer of ownership- Matter remanded: CESTAT</strong></font></p>
<p align="justify"><font size="2" face="Verdana, Arial, Helvetica, sans-serif"><strong>THE </strong>appellant sold their unit to Exide on 16.02.1998/29.04.1998 with a condition that any liability towards excise duties shall be borne by the appellant. The appellant filed an application for transfer of credit lying in their MODVAT credit account attributable to inputs and capital goods, unutilized by them, to Exide. The said credit was denied by the lower authorities and, therefore, the appellant is before the CESTAT.</font></p>
<p align="justify"><font size="2" face="Verdana, Arial, Helvetica, sans-serif">It is submitted that as per Rule 57F(20) and Rule 57S(5) of the CER, 1944, on there being change of ownership, the MODVAT credit attributable to inputs can be transferred to the buyer of the unit irrespective of the clause that liabilities towards Central Excise payments are transferred or not.</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="#FF6666" size="2" face="Verdana, Arial, Helvetica, sans-serif">Until Tomorrow with more <strong>DDT</strong></font></p>
<p align="justify"><font color="#FF6666" size="2" face="Verdana, Arial, Helvetica, sans-serif"><strong>Have a nice day.</strong></font></p>
<p align="justify"><font color="#FF6666" 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"><strong>vijaywrite@taxindiaonline.com</strong></a></font></p>
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