Textiles and Goods and Services Tax

Timely and strict compliance of the law being the back bone of self-assessment under GST, becomes more important for every registered person under GST. And as the law is new for all and one, various interpretational and compliance issues are the initial challenges being faced by the industry.

The assessees who are already registered in Central Excise, Service Tax, Customs or State VAT are normally accustomed to timely comply with the procedural aspects of relevant statues. And the ones, who are for the first time being covered under indirect taxes feel more of these issues.

Textiles sector is one of such industry that has more or less enjoyed an exemption regime until now. With the imposition of Goods and Services Tax recently, the textile, hosiery and related job work units which are large in numbers and are mostly from micro, medium and small segment of industry are facing teething problems in this new regime of taxation. Most of the present units in Textile segment are running their units for several decades without being liable for Central Excise and Service Tax in particular and State VAT in general. The issues of concern for them range from procedural like rates of taxes to legal like place of supply of goods.

I am here with a series of write-ups concerning Goods and Services Tax specifically concerning Textile Sector with an endeavour to deliberate on these areas of concern.

This article, the first in the series will be covering rates of GST on Textiles, readymade, hosiery goods and the goods used in textile industry.

Rates of Central Excise Pre-GST

Natural Fiber, Natural Yarn, Natural Fabric (Cotton)	0% without CENVAT and 6% with CENVAT	Conditional Exemption
Manmade Fiber, Manmade Yarn, Manmade Fabric	12% with CENVAT	No Exemption Compulsory Duty
Readymade Garments, made-ups Branded and SP More Than Rs. 1000 (cotton or mixed)	Compulsory Duty With Two Options 1st Option 2% of 60% of RSP without CENVAT 2nd Option 12.5% of 60% of RSP with CENVAT	No Exemption Compulsory Duty Just Options for Rates
Readymade Garments, made-ups B/Unbranded and/or SP Less Than Rs. 1000 (PURE COTTON ONLY)	Voluntary Duty With Two Options 1st Option Nil Rate without CENVAT 2nd Option 6% of 60% of RSP with CENVAT	Conditional Exemption
Readymade Garments, made-ups Unbranded and SP Less Than Rs. 1000 (COTTON PLUS others)	Voluntary Duty With Two Options 1st Option Nil Rate without CENVAT 2nd Option 12.5% of 60% of RSP with CENVAT	Conditional Exemption

Primary Structure of Rates of Taxes under GST

Product	GST (%)
Cotton	5%
Cotton Cone Yarn	5%
Cotton Hank Yarn	5%
Cotton Waste	5%
Cotton Fabric	5% (No Refund of ITC accumulation)
Cotton Garment/Made-Ups Without brand name having Retail Sale Price below Rs.1000 (per piece)	5% (Sale Value not exceeding Rs 1000 per piece) 12% (Sale Value exceeding Rs 1000 per piece)
Cotton Garment/Made-Ups with brand name having of RSP of Rs. 1000 and above (per piece)	5% (Sale Value not exceeding Rs 1000 per piece) 12% (Sale Value exceeding Rs 1000 per piece)
Polyester Fiber	18%
Polyester Yarn	18%
Polyester Fabric	5% (No Refund of ITC accumulation)
Polyester Garment/Made-Ups Without Brand Name having RSP below Rs. 1000 (per piece)	5% (Sale Value not exceeding Rs 1000 per piece) 12% (Sale Value exceeding Rs 1000 per piece)
Polyester Garment/Made-Ups Without Brand Name having RSP of Rs. 1000 (per piece) and above	5% (Sale Value not exceeding Rs 1000 per piece) 12% (Sale Value exceeding Rs 1000 per piece)

ITEM WISE RATES OF GST

Kindly note that the ”Tariff item”, “sub-heading” “heading” and “Chapter” given below shall mean respectively a tariff item, sub-heading, heading and chapter as specified in the First Schedule to the Customs Tariff Act, 1975 (51 of 1975). Further, The rules for the interpretation of the First Schedule to the Customs Tariff Act, 1975 (51 of 1975), including the Section and Chapter Notes and the General Explanatory Notes of the First Schedule shall, so far as may be, apply to the interpretation of this notification.

Items with * are given here with names by which they are commonly known in market. In Schedules, these names do not appear though.

SCHEDULE-Exempt Goods
S. No.	Chapter / Heading / Sub-heading / Tariff item	Description of Goods	Percentage of GST,(CGST+SGST)
123.	5001	Silkworm laying, cocoon	Effective rate of GST 0, as wholly exempt
124.	5002	Raw Silk	Effective rate of GST 0, as wholly exempt
125.	5003	Silk Waste	Effective rate of GST 0, as wholly exempt
126.	5101	Wool, not carded or combed	Effective rate of GST 0, as wholly exempt
127.	5102	Fine or coarse animal hair, not carded or combed	Effective rate of GST 0, as wholly exempt
128.	5103	Waste of wool or of fine or coarse animal hair	Effective rate of GST 0, as wholly exempt
129.	52	Gandhi Topi	Effective rate of GST 0, as wholly exempt
130.	52	Khadi Yarn	Effective rate of GST 0, as wholly exempt
131.	5303	Jute fibres, ram or processed but not spun	Effective rate of GST 0, as wholly exempt
132.	5305	Coconut, coir fibre	Effective rate of GST 0, as wholly exempt
133.	63	Indian National Flag	Effective rate of GST 0, as wholly exempt

SCHEDULE I- 5%
S. No.	Chapter / Heading / Sub-heading / Tariff item	Description of Goods	Percentage of GST,(CGST+SGST)
202.	5004 to 5006	Silk yarn	5
203.	5007	Woven fabrics of silk or of silk waste	5
204.	5104	Garneted stock of wool or of fine or coarse animal hair, shoddy wool	5
205.	5105	Wool and fine or coarse animal hair, carded or combed	5
206.	5106 to 5110	Yarn of wool or of animal hair	5
207.	5111 to 5113	Woven fabrics of wool or of animal hair	5
208.	5201 to 5203	Cotton and Cotton waste	5
209.	5204	Cotton sewing thread, whether or not put up for retail sale	5
210.	5205 to 5207	Cotton yarn [other than khadi yarn]	5
211.	5208 to 5212	Woven fabrics of cotton	5
212.	5301	All goods i.e. flax, raw or processed but not spun; flax tow and waste (including yarn waste and garneted stock)	5
213.	5302	True hemp (Cannabis sativa L), raw or processed but not spun; tow and waste of true hemp (including yarn waste and garneted stock)	5
214.	5303	All goods i.e. textile bast fibres [other than jute fibres, raw or processed but not spun]; tow and waste of these fibres (including yarn waste and garneted stock)	5
215.	5305 to 5308	All goods [other than coconut coir fibre] including yarn of flax, jute, other textile bast fibres, other vegetable textile fibres; paper yarn	5
216.	5309 to 5311	Woven fabrics of other vegetable textile fibres, paper yarn	5
217.	5407, 5408	Woven fabrics of manmade textile materials/Synthetic Cloth*	5
218.	5512 to 5516	Woven fabrics of manmade staple fibres	5
219.	5705	Coir mats, matting and floor covering	5
220.	5809, 5810	Embroidery or zari articles, that is to say,- imi, zari, kasab, saima, dabka, chumki, gotasitara, naqsi, kora, glass beads, badla, glzal	5
221.	60	Knitted or crocheted fabrics [All goods]	5
222.	61	Articles of apparel and clothing accessories, knitted or crocheted, of sale value not exceeding Rs. 1000 per piece	5
223.	62	Articles of apparel and clothing accessories, not knitted or crocheted, of sale value not exceeding Rs. 1000 per piece	5
224.	63	Other made up textile articles, sets, worn clothing and worn textile articles and rags, of sale value not exceeding Rs. 1000 per piece	5
SCHEDULE II- 12%
S. No.	Chapter / Heading / Sub-heading / Tariff item	Description of Goods	Percentage of GST,(CGST+SGST)
64.	3005	Wadding, gauze, bandages and similar articles (for example, dressings, adhesive plasters, poultices), impregnated or coated with pharmaceutical substances or put up in forms or packings for retail sale for medical, surgical, dental or veterinary purposes	12
82.	3926	Plastic beads	12
118.	4808	Paper and paperboard, corrugated (with or without glued flat surface sheets), creped, crinkled, embossed or perforated, in rolls or sheets, other than paper of the kind described in heading 4803	12
119.	4810	Paper and paperboard, coated on one or both sides with kaolin (China clay) or other inorganic substances, with or without a binder, and with no other coating, whether or not surface-colored, surface-decorated or printed, in rolls or rectangular (including square) sheets of any size	12
120.	4811	Aseptic packaging paper	12
121.	4817 30	Boxes, pouches, wallets and writing compendiums, of paper or paperboard, containing an assortment of paper stationery	12
122.	4819	Cartons, boxes and cases of corrugated paper or paper board	12
124.	4823	Paper pulp moulded trays	12
133.	5601	Wadding of textile materials and articles thereof; such as Absorbent cotton wool	12
134.	5602	Felt, whether or not impregnated, coated, covered or laminated	12
135.	5603	Nonwovens, whether or not impregnated, coated, covered or laminated	12
136.	5604	Rubber thread and cord, textile covered; textile yarn, and strip and the like of heading 5404 or 5405, impregnated, coated, covered or sheathed with rubber or plastics	12
137.	5605	Metallised yarn, whether or not gimped, being textile yarn, or strip or the like of heading 5404 or 5405, combined with metal in the form of thread, strip or powder or covered with metal; such as Real zari thread (gold) and silver thread, combined with textile thread), Imitation zari thread	12
138.	5606	Gimped yarn, and strip and the like of heading 5404 or 5405, gimped (other than those of heading 5605 and gimped horsehair yarn); chenille yarn (including flock chenille yarn); loop wale-yarn	12
139.	5607	Twine, cordage, ropes and cables, whether or not plaited or braided and whether or not impregnated, coated, covered or sheathed with rubber or plastics/Elastic*	12
140.	5608	Knotted netting of twine, cordage or rope; made up fishing nets and other made up nets, of textile materials	12
141.	5609	Articles of yarn, strip or the like of heading 5404 or 5405, twine, cordage, rope or cables, not elsewhere specified or included	12
142.	5701	Carpets and other textile floor coverings, knotted, whether or not made up	12
143.	5702	Carpets and other textile floor coverings, woven, not tufted or flocked, whether or not made up, including “Kelem”, “Schumacks”, “Karamanie” and similar hand-woven rugs	12
144.	5703	Carpets and other textile floor coverings, tufted, whether or not made up	12
145.	5704	Carpets and other textile floor coverings, of felt, not tufted or flocked, whether or not made up	12
146.	5705	Other carpets and other textile floor coverings, whether or not made up; such as Mats and mattings including Bath Mats, where cotton predominates by weight, of Handloom, Cotton Rugs of handloom	12
147.	5801	Woven pile fabrics and chenille fabrics, other than fabrics of heading 5802 or 5806	12
148.	5802	Terry towelling and similar woven terry fabrics, other than narrow fabrics of heading 5806; tufted textile fabrics, other than products of heading 5703	12
149.	5803	Gauze, other than narrow fabrics of heading 5806	12
150.	5804	Tulles and other net fabrics, not including woven, knitted or crocheted fabrics; lace in the piece, in strips or in motifs, other than fabrics of headings 6002 to 6006	12
151.	5805	Hand-woven tapestries of the type Gobelins, Flanders, Aubusson, Beauvais and the like, and needle-worked tapestries (for example, petit point, cross stitch), whether or not made up	12
152.	5806	Narrow woven fabrics, other than goods of heading 5807; narrow fabrics consisting of warp without weft assembled by means of an adhesive (bolducs)	12
153.	5807	Labels, badges and similar articles of textile materials, in the piece, in strips or cut to shape or size, not embroidered	12
154.	5808	Braids in the piece; ornamental trimmings in the piece, without embroidery, other than knitted or crocheted; tassels, pompons and similar articles	12
155.	5809	Woven fabrics of metal thread and woven fabrics of metallised yarn of heading 5605, of a kind used in apparel, as furnishing fabrics or for similar purposes, not elsewhere specified or included; such as Zari borders [other than Embroidery or zari articles, that is to say,- imi, zari, kasab, saima, dabka, chumki, gota sitara, naqsi, kora, glass beads, badla, glzal]	12
156.	5810	Embroidery in the piece, in strips or in motifs, Embroidered badges, motifs and the like [other than Embroidery or zari articles, that is to say,- imi, zari, kasab, saima, dabka, chumki, gota sitara, naqsi, kora, glass beads, badla, glzal]	12
157.	5811	Quilted textile products in the piece, composed of one or more layers of textile materials assembled with padding by stitching or otherwise, other than embroidery of heading 5810	12
158.	5901	Textile fabrics coated with gum or amylaceous substances, of a kind used for the outer covers of books or the like; tracing cloth; prepared painting canvas; buckram and similar stiffened textile fabrics of a kind used for hat foundations	12
159.	5902	Tyre cord fabric of high tenacity yarn of nylon or other polyamides, polyesters or viscose rayon	12
160.	5903	Textile fabrics impregnated, coated, covered or laminated with plastics, other than those of heading 5902	12
161.	5904	Linoleum, whether or not cut to shape; floor coverings consisting of a coating or covering applied on a textile backing, whether or not cut to shape	12
162.	5905	Textile wall coverings	12
163.	5906	Rubberized textile fabrics, other than those of heading 5902	12
164.	5907	Textile fabrics otherwise impregnated, coated or covered; painted canvas being theatrical scenery, studio back-cloths or the like	12
165.	5908	Textile wicks, woven, plaited or knitted , for lamps, stoves, lighters, candles or the like; incandescent gas mantles and tubular knitted gas mantle fabric therefor, whether or not impregnated	12
166.	5909	Textile hose piping and similar textile tubing, with or without lining, armour or accessories of other materials	12
167.	5910	Transmission or conveyor belts or belting, of textile material, whether or not impregnated, coated, covered or laminated with plastics, or reinforced with metal or other material	12
168.	5911	Textile products and articles, for technical uses, specified in Note 7 to this Chapter; such as Textile fabrics, felt and felt-lined woven fabrics, coated, covered or laminated with rubber, leather or other material, of a kind used for card clothing, and similar fabrics of a kind used for other technical purposes, including narrow fabrics made of velvet impregnated with rubber, for covering weaving spindles (weaving beams); Bolting cloth, whether or Not made up; Felt for cotton textile industries, woven; Woven textiles felt, whether or not impregnated or coated, of a kind commonly used in other machines, Cotton fabrics and articles used in machinery and plant, Jute fabrics and articles used in machinery or plant, Textile fabrics of metalized yarn of a kind commonly used in paper making or other machinery, Straining cloth of a kind used in oil presses or the like, including that of human hair, Paper maker's felt, woven, Gaskets, washers, polishing discs and other machinery parts of textile articles	12
169.	61	Articles of apparel and clothing accessories, knitted or crocheted, of sale value exceeding Rs. 1000 per piece	12
170.	62	Articles of apparel and clothing accessories, not knitted or crocheted, of sale value exceeding Rs. 1000 per piece	12
171.	63	Other made up textile articles, sets, worn clothing and worn textile articles and rags, of sale value exceeding Rs. 1000 per piece	12
182.	7319	Sewing needles/ HOSIERY NEEDLES ARE AT 18*	12
187.	8211	Knives with cutting blades, serrated or not (including pruning knives), other than knives of heading 8208, and blades therefor	12
223.	9404	Coir products [except coir mattresses]	12
224.	9404	Products wholly made of quilted textile materials	12

SCHEDULE III- 18%
S. No.	Chapter / Heading / Sub-heading / Tariff item	Description of Goods	Percentage of GST,(CGST+SGST)
51.	3206	Other coloring matter; preparations as specified in Note 3 to this Chapter, other than those of heading 32.03, 32.04 or 32.05; inorganic products of a kind used as luminophores, whether or not chemically defined	18
53.	32110000	Prepared driers	18
54	3212	Pigments (including metallic powders and flakes) dispersed in non-aqueous media, in liquid or paste form, of a kind used in the manufacture of paints (including enamels); stamping foils; dyes and other coloring matter put up in forms or packings for retail sale	18
55.	3215	Printing ink, writing or drawing ink and other inks, whether or not concentrated or solid (Fountain pen ink and Ball pen ink)	18
88.	3809	Finishing agents, dye carriers to accelerate the dyeing or fixing of dyestuffs and other products and preparations (for example, dressings and mordant), of a kind used in the textile, paper, leather or like industries, not elsewhere specified or included	18
100.	3901 to 3913	All goods i.e. polymers; Polyacetals, other polyether, epoxide resins, polycarbonates, alkyd resins, polyallylesters, other polyesters; polyamides; Amino-resins, phenolic resins and polyurethanes; silicones; Petroleum resins, coumarone-indene resins, polyterpenes, polysulphides, polysulphones and other products specified in Note 3 to this Chapter, not elsewhere specified or included; Cellulose and its chemical derivatives, not elsewhere specified or included; Natural polymers (for example, alginic acid) and modified natural polymers (for example, hardened proteins, chemical derivatives of natural rubber), not elsewhere specified or included; in primary forms	18
105.	3919	Self-adhesive plates, sheets, film, foil, tape, strip and other flat shapes, of plastics, whether or not in rolls	18
108.	3923	Articles for the conveyance or packing of goods, of plastics; stoppers, lids, caps and other closures, of plastics	18
111.	3926	Plastic Tarpaulin	18
123.	4015	Articles of apparel and clothing accessories (including gloves, mittens and mitts), for all purposes, of vulcanized rubber other than hard rubber [other than Surgical gloves]	18
124.	4202	School satchels and bags other than of leather or composition leather	18
127.	4202 22 20	Hand bags and shopping bags, of cotton	18
128.	4202 22 30	Hand bags and shopping bags, of jute	18
129.	4202 22 40	Vanity bags	18
130.	4202 29 10	Handbags of other materials excluding wicker work or basket work	18
131.	4301	Raw furskins (including heads, tails, paws and other pieces or cuttings, suitable for furriers’ use), other than raw hides and skins of heading 4101, 4102 or 4103.	18
132.	4302	Tanned or dressed furskins (including heads, tails, paws and other pieces or cuttings), unassembled, or assembled (without the addition of other materials) other than those of heading 4303	18
133.	4304	Artificial fur and articles thereof	18
155.	4821	Paper or paperboard labels of all kinds, whether or not printed	18
158.	5401	Sewing thread of manmade filaments, whether or not put up for retail sale/Polyester Sewing Threads*	18
159.	5402, 5404, 5406	All synthetic filament yarn such as nylon, polyester, acrylic, etc.	18
160.	5403, 5405, 5406	All artificial filament yarn such as viscose rayon, Cup ammonium, etc.	18
161.	5501, 5502	Synthetic or artificial filament tow	18
162.	5503, 5504, 5506, 5507	Synthetic or artificial staple fibres	18
163.	5505	Waste of manmade fibres	18
164.	5508	Sewing thread of manmade staple fibres	18
165.	5509, 5510, 5511	Yarn of manmade staple fibres	18
172.	6501	Hat-forms, hat bodies and hoods of felt, neither blocked to shape nor with made brims; plateau and manchons (including slit manchons), of felt	18
173.	6502	Hat-shapes, plaited or made by assembling strips of any material, neither blocked to shape, nor with made brims, nor lined, nor trimmed	18
174.	6504 00 00	Hats and other headgear, plaited or made by assembling strips of any material, whether or not lined or trimmed	18
175.	6505	Hats and other headgear, knitted or crocheted, or made up from lace, felt or other textile fabric, in the piece (but not in strips), whether or not lined or trimmed; hair-nets of any material, whether or not lined or trimmed	18
176.	6506	Other headgear, whether or not lined or trimmed	18
177.	6507	Head-bands, linings, covers, hat foundations, hat frames, peaks and chinstraps, for headgear	18
182.	6811	Articles of asbestos-cement, of cellulose fibre-cement or the like	18
233.	7319	Sewing needles, knitting needles, bodkins, crochet hooks, embroidery stilettos and similar articles, for use in the hand, of iron or steel; safety pins and other pins of iron or steel, not elsewhere specified or included	18
302.	8213 00 00	Scissors, tailors' shears and similar shears, and blades therefor	18
306.	8308	Clasps, frames with clasps, buckles, buckle-clasps, hooks, eyes, eyelets and the like, of base metal, of a kind used for clothing or clothing accessories, footwear, jewellery, wrist watches, books, awnings, leather goods, travel goods or saddlery or for other made up articles; tubular or bifurcated rivets, of base metal; beads and spangles, of base metal
335.	8443	Printing machinery used for printing by means of plates, cylinders and other printing components of heading 84.42; Printers [other than machines which perform two or more of the functions of printing, copying or facsimile transmission] capable of connecting to an automatic data processing machine or to a network printers [other than copying machines, facsimile machines]; parts and accessories thereof [other than ink cartridges with or without print head assembly and ink spray nozzle]	18
337.	8445	Machines for preparing textile fibres; spinning, doubling or twisting machines and other machinery for producing textile yarns; textile reeling or winding (including weft-winding) machines and machines for preparing textile yarns for use on the machines of heading 8446 or 8447	18
338.	8446	Weaving machines (looms)	18
339.	8447	Knitting machines, stitch-bonding machines and machines for making gimped yarn, tulle, lace, embroidery, trimmings, braid or net and machines for tufting	18
340.	8448	Auxiliary machinery for use with machines of heading 84.44, 84.45, 84.46 or 84.47 (for example, dobbies, Jacquards, automatic stop motions, shuttle changing mechanisms); parts and accessories suitable for use solely or principally with the machines of this heading or of heading 8444, 8445,8446 or 8447 (for example, spindles and spindles flyers, card clothing, combs, extruding nipples, shuttles, healds and heald frames, hosiery needles)/ SEWING NEEDLES ARE AT 12%*	18
341.	8449	Machinery for the manufacture or finishing of felt or nonwovens in the piece or in shapes, including machinery for making felt hats; blocks for making hats	18
342.	8451	Machinery (other than machines of heading 8450) for washing, cleaning, wringing, drying, ironing, pressing (including fusing presses), bleaching, dyeing, dressing, finishing, coating or impregnating textile yarns, fabrics or made up textile articles and machines for applying the paste to the base fabric or other support used in the manufacture of floor covering such as linoleum; machines for reeling, unreeling, folding, cutting or pinking textile fabrics	18
343.	8453	Machinery for preparing, tanning or working hides, skins or leather or for making or repairing footwear or other articles of hides, skins or leather, other than sewing machines	18
442.	9606 21 00, 9606 22 00, 9606 29, 9606 30	Buttons, of plastics not covered with the textile material, of base metals, buttons of coconut shell, button blanks	18
446.	9607	Slide fasteners and parts thereof /Zip*	18
SCHEDULE IV- 28%
S. No.	Chapter / Heading / Sub-heading / Tariff item	Description of Goods	Percentage of GST,(CGST+SGST)
52.	4202	Trunks, suit-cases, vanity-cases, executive-cases, brief-cases, school satchels, spectacle cases, binocular cases, camera cases, musical instrument cases, gun cases, holsters and similar containers; travelling- bags, insulated food or beverages bags, toilet bags, rucksacks, handbags, shopping bags, wallets, purses, map-cases, cigarette-cases, to-bacco- pouches, tool bags, sports bags, bottle-cases, jewellery boxes, powder-boxes, cutlery cases and similar containers, of leather, of sheeting of plastics, of textile materials, of vulcanized fibre or of paperboard, or wholly or mainly covered with such materials or with paper [other than School satchels and bags other than of leather or composition leather, Toilet cases, Hand bags and shopping bags, of artificial plastic material, of cotton, or of jute, Vanity bags, Handbags of other materials excluding wicker work or basket work]	28
53.	4203	Articles of apparel and clothing accessories, of leather or of composition leather	28
54.	4205	Other articles of leather or of composition leather	28
55.	4206	Articles of gut (other than silk-worm gut), of goldbeater’s skin, of bladders or of tendons	28
56.	4303	Articles of apparel, clothing accessories and other articles of fur skin	28
57.	4304	Articles of artificial fur	28
67.	6703	Wool or other animal hair or other textile materials, prepared for use in making wigs or the like	28
68.	6704	Wigs, false beards, eyebrows and eyelashes, switches and the like, of human or animal hair or of textile materials; articles of human hair not elsewhere specified or included	28
SCHEDULE V - 3%
S. No.	Chapter / Heading / Sub-heading / Tariff item	Description of Goods	Percentage of GST,(CGST+SGST)
17.	7117	Imitation jewellery	3

We have tried to compile whole range of goods related to Textiles sector.

Happy Deemed Credit!

The author can also be reached at rks9814214503@gmail.com

The writer of this article is a Chartered Accountant having more than 17 years of experience in the field of indirect tax. He has authored a book on Punjab Value Added Tax, ‘Law and Practice of Punjab VAT’. He has to his credit many papers, published in National Level reputed tax publishers and presented at various National and State Level Forms.

The views expressed herein are the personal views of the writer. Readers are advised to act upon their own understanding /independent advice on the relevant law. This document is based on interpretation of the law. Therefore, the views expressed above are matters of opinion based on the laws prevalent at the time the view being expressed, which may change as the law evolves from time to time. We have no responsibility to update these comments for events and circumstances occurring after the date of this note, unless specifically requested. This note is for the specific purpose of serving as an informative guide and is meant for general guidance and no responsibility for loss arising to any person acting or refraining from acting as a result of any material contained in this presentation will be accepted by us.