Registration under GST Regime

Registration under GST By CMA NAVNEET KUMAR JAIN FCMA, MBA., LL.B., M.COM., PGDTL, AIIISLA, LIII VISITING FACULTY/SPEAKER: CAG, AGCR, EXCISE & SERVICE TAX DEPARTMENT, DVAT, ICAI-CMA, ICSI, PSUs, PHDCCI Ex Consultant: World Bank, WHO Partner; Jitender, Navneet & Co., Cost Accountants Registered Public Accounting Firm (PCAOB-USA) Delhi : Mumbai : Faridabad : Bhiwadi navneetic@yahoo.com, 9810175020 GST Registration What do we want to know Topics to Be covered •Provisions regarding Registration •Liability to be registered under GST •Matters when Govt. shall not be regarded as Taxable Person •Amendment/ Cancellation of registration CMA NAVNEE KUMAR JAIN: FCMA, LL.B., MBA, PGDTL, AIIISLA, LIII Statutes/Documents Governing Registration under GST •Model GST Law (Goods & Services Act 2016) (June 2016) •Report Of The Joint Committee On Business Processes For GST On GST Registration (July 2015) CMA NAVNEE KUMAR JAIN: FCMA, LL.B., MBA, PGDTL, AIIISLA, LIII Some of the Queries •Whether existing registered dealers/assesses are required to get themselves registered again •To whom one has to apply for registration, Central Govt/State Govt or any other agency •Who is liable to get registration •Within how much period one should get registered after he becomes liable to get registration •Is there any casual registration on the lines as are available under various VAT Acts •Will there be any Centralised Registration as is available under service tax CMA NAVNEE KUMAR JAIN: FCMA, LL.B., MBA, PGDTL, AIIISLA, LIII Some of the Queries •Is there any type of LTU registration •Whether there will be any visits by Inspectors before granting registration as is the present practice in many Revenue Acts. •What are the documents required for registration •Under which Act registration will be there •How to go for registration in case of multi locational units within the state •How to go for registration in case of multi locational units in different states •What will be structure of GST Registration No. etc. CMA NAVNEE KUMAR JAIN: FCMA, LL.B., MBA, PGDTL, AIIISLA, LIII Proposed Registration Requirement •A legal person without GST registration can neither collect GST from his customers nor claim any input tax credit of GST paid by him. •The taxable person in the GST regime will be required to take State specific single registration for CGST, IGST and SGST purposes (multiple registrations in a state for business verticals are permitted) CMA NAVNEE KUMAR JAIN: FCMA, LL.B., MBA, PGDTL, AIIISLA, LIII Registration within due date •. CMA NAVNEE KUMAR JAIN: FCMA, LL.B., MBA, PGDTL, AIIISLA, LIII Registration with in 30days •Date of Application as date of registration •ITC available before the date of registration also Registration after 30 days •Date of Application as date of registration •ITC not available before the date of registration. Abbreviations •GST: Goods & Services Tax •GSTN: Goods & Services Tax Network •GSTIN: Goods & Services Tax Identification Number CMA NAVNEE KUMAR JAIN: FCMA, LL.B., MBA, PGDTL, AIIISLA, LIII Person •“person” includes— • an individual; •a Hindu undivided family; •a company; •a firm; •a Limited Liability Partnership; •an association of persons or a body of individuals, whether incorporated or not, in India or outside India; any corporation established by or under any Central, State or Provincial Act or a Government company as defined in section 2(45) of the Companies Act, 2013 (18 of 2013); CMA NAVNEE KUMAR JAIN: FCMA, LL.B., MBA, PGDTL, AIIISLA, LIII Person: contd.. •any body corporate incorporated by or under the laws of a country outside India; •a co-operative society registered under any law relating to cooperative societies; •a local authority; •government; •society as defined under the Societies Registration Act, 1860 (21 of 1860); •trust; and •every artificial juridical person, not falling within any of the preceding sub-clauses; CMA NAVNEE KUMAR JAIN: FCMA, LL.B., MBA, PGDTL, AIIISLA, LIII Taxable Person: Section 9 •Taxable Person means a person who carries on any business at any place in India /State of ____ and who is registered or required to be registered under Schedule III of this Act • Provided further that a person who is required to be registered shall not be considered as a taxable person until his aggregate turnover in a financial year exceeds [Rs ten lakh] (Five Lacs in case of NE States) –Exclusions :Agriculturists, •Central Government, a State Government or any local authority to be considered as taxable person except for the activities given under Schedule IV like services for Passport, Visa etc, activities performed by Municipal corporations/Panchayats(Discussed in next slides) CMA NAVNEE KUMAR JAIN: FCMA, LL.B., MBA, PGDTL, AIIISLA, LIII Persons not to be considered as taxable person Sec 9(3) •Persons providing services as employee •Persons supplying non taxable goods or services exclusively (No other business) •Persons receiving services (taxable under reverse charge mechanism) for personal use below certain limit (Yet to be decided) Section 7(3) CMA NAVNEE KUMAR JAIN: FCMA, LL.B., MBA, PGDTL, AIIISLA, LIII GST through GSTN: Common GST Portal Front End: Centre Registration Return Payment Back End: State •Other processes like Refund •Assessment etc. CMA NAVNEE KUMAR JAIN: FCMA, LL.B., MBA, PGDTL, AIIISLA, LIII GSTN: Gateway to GST •When a taxpayer visits Common GST portal and registers himself, then the information that he files at the portal will be sent to the tax authorities •GST is a dual tax­ the state GST and the Central GST­ so his application would be sent to both, the central government and the state government. •They will approve the application and then GSTN would generate his GSTIN (GST Identification Number) and he becomes the registered taxpayer CMA NAVNEE KUMAR JAIN: FCMA, LL.B., MBA, PGDTL, AIIISLA, LIII GST Model Law Draft Statutes for GST The Integrated Goods And Services Tax Act, 2016 Central / State Goods And Services Tax Act, 2016 CMA NAVNEE KUMAR JAIN: FCMA, LL.B., MBA, PGDTL, AIIISLA, LIII Existing Registration requirement: Primarily •Registration required under Excise for each of the Factory/place of business •VAT required for each of the state where business is carried on •CST Registration in each state •Separate registration for Service Tax (Centralised or Non-Centralised) •Other registrations e.g. luxury tax, entertainment tax etc. CMA NAVNEE KUMAR JAIN: FCMA, LL.B., MBA, PGDTL, AIIISLA, LIII Proposed Registration Requirement •Two Model Acts •Single Registration State Specific (one/Multiple places of business in One State) CMA NAVNEE KUMAR JAIN: FCMA, LL.B., MBA, PGDTL, AIIISLA, LIII Registration Common Registration State specific Registration Nos. for CGST,SGST & IGST IGST CGST SGST CMA NAVNEE KUMAR JAIN: FCMA, LL.B., MBA, PGDTL, AIIISLA, LIII Provisions in Model Law: Chapter VI •Registration : Section 19 (14 subsections 1 to 12 (including 4A & 8A) •Special provisions relating to casual taxable person and non-resident taxable person (Section 19A (3 subsections) • Amendment of registration (section 20, 4 subsections) •Cancellation of registration (Section 21, 8 subsections) •Revocation of cancellation of registration (Section 22, 4 subsections) CMA NAVNEE KUMAR JAIN: FCMA, LL.B., MBA, PGDTL, AIIISLA, LIII Registration: Limitations to discussions •Use of words “as may be prescribed” 23 time from section 19 to section 22 and 159 time in totality CMA NAVNEE KUMAR JAIN: FCMA, LL.B., MBA, PGDTL, AIIISLA, LIII Registration: categories •Existing Registrations & New Registrations •Mandatory & Voluntary CMA NAVNEE KUMAR JAIN: FCMA, LL.B., MBA, PGDTL, AIIISLA, LIII Registration •Every person who is liable to be registered under Schedule III of this Act shall apply for registration in every such State in which he is so liable within thirty days from the date on which he becomes liable to registration, in such manner and subject to such conditions as may be prescribed: –Prescribed where as of now: Can we refer to Business Process Document?? CMA NAVNEE KUMAR JAIN: FCMA, LL.B., MBA, PGDTL, AIIISLA, LIII Registration 19(1) •Liability: Schedule III: within 30days •No fresh registration for ISD 19(2) •Registration for multiple Business verticals in a State 19(3) •Voluntary Registration CMA NAVNEE KUMAR JAIN: FCMA, LL.B., MBA, PGDTL, AIIISLA, LIII Registration 19(4) •Pan No. Must •Every person shall have a Permanent Account Number issued under the Income Tax Act, 1961 (43 of 1961) in order to be eligible for grant of registration under sub-section (1), (2) or (3). 19(4A) •For Non Residents, documents other than PAN may be prescribed 19(5) •Registration by Proper Officer in case of failure by the liable person to get himself registered CMA NAVNEE KUMAR JAIN: FCMA, LL.B., MBA, PGDTL, AIIISLA, LIII Registration 19(6) •Unique Identity Number for UN organisations etc. Multilateral Financial Institution , Embassies, others for refund etc. 19(7) •The registration or the Unique Identity Number, shall be granted or, as the case may be, rejected after due verification in the manner and within such period as may be prescribed 19(8) •Rejection of application for registration No. or Unique identity number only after issuing SCN or giving opportunity of being heard CMA NAVNEE KUMAR JAIN: FCMA, LL.B., MBA, PGDTL, AIIISLA, LIII Registration 19(6) •Unique Identity Number for UN organisations etc. Multilateral Financial Institution , Embassies, others for refund etc. 19(7) •The registration or the Unique Identity Number, shall be granted or, as the case may be, rejected after due verification in the manner and within such period as may be prescribed 19(8) •Rejection of application for registration No. or Unique identity number only after issuing SCN or giving opportunity of being heard CMA NAVNEE KUMAR JAIN: FCMA, LL.B., MBA, PGDTL, AIIISLA, LIII Registration 19(9) •A registration or an Unique Identity Number shall be deemed to have been granted after the period prescribed under sub-section (7), if no deficiency has been communicated to the applicant by the proper officer within that period 19(10) •Automatic Rejection by another authority: any rejection of application for registration or the Unique Identity Number under the CGST Act / SGST Act shall be deemed to be a rejection of application for registration under the SGST Act / CGST Act 19(11) •No Rejection within time means deemed registration: grant of registration or the Unique Identity Number under the CGST Act / SGST Act shall be deemed to be a grant of registration or the Unique Identity Number under the SGST/CGST Act CMA NAVNEE KUMAR JAIN: FCMA, LL.B., MBA, PGDTL, AIIISLA, LIII Power to exempt from Registration •19(12) The Central or a State Government may, on the recommendation of the Council, by notification, specify the category of persons who may be exempted from obtaining registration under this Act •Neither state nor centre has the power to declare any category of persons as exempted CMA NAVNEE KUMAR JAIN: FCMA, LL.B., MBA, PGDTL, AIIISLA, LIII Registration Certificate •Sec 19(8A) : Certificate of registration shall be issued in the prescribed form after completion of the above formalities showing effective date (normally the date of application) CMA NAVNEE KUMAR JAIN: FCMA, LL.B., MBA, PGDTL, AIIISLA, LIII Schedule III (Persons liable to be registered) 1)Turnover Criteria : 9 lacs or 4 Lacs (NE States) 2)Previous registered Assesses (Automatic route) 3)Transfer of business from another person a)Succession or otherwise b)Merger /amalgamation CMA NAVNEE KUMAR JAIN: FCMA, LL.B., MBA, PGDTL, AIIISLA, LIII Schedule III (Persons liable to be registered) •persons making any inter-State taxable supply, irrespective of the threshold specified in previous slide; •casual taxable persons, irrespective of the threshold specified in previous slide; •persons who are required to pay tax under reverse charge, irrespective of the threshold specified in previous slide; •non-resident taxable persons, irrespective of the threshold specified in previous slide; •persons who are required to deduct tax under section 37 (on receipt of Goods or services where contract value exceeds Rs 10 lacs); •persons who supply goods and/or services on behalf of other registered taxable persons whether as an agent or otherwise, irrespective of the threshold specified in previous slide; CMA NAVNEE KUMAR JAIN: FCMA, LL.B., MBA, PGDTL, AIIISLA, LIII Schedule III (Persons liable to be registered) •input service distributor; •persons who supply goods and/or services, other than branded services, through electronic commerce operator, irrespective of the threshold specified in previous slide; •every electronic commerce operator, irrespective of the threshold specified in previous slide; •an aggregator who supplies services under his brand name or his trade name, irrespective of the threshold specified in previous slide ; and •such other person or class of persons as may be notified by the Central Government or a State Government on the recommendations of the Council. CMA NAVNEE KUMAR JAIN: FCMA, LL.B., MBA, PGDTL, AIIISLA, LIII Casual Taxable Person And Non-resident Taxable Person •Registration for ninety days •Extendable for further 90 days •Advance deposit of GST of an amount equivalent to the estimated tax liability at the time of making an application for registration. CMA NAVNEE KUMAR JAIN: FCMA, LL.B., MBA, PGDTL, AIIISLA, LIII Amendment of registration certificate Section 21 •Intimation to proper officer about the changes in the information submitted at the time of registration •Amendments Requiring approval or not requiring approval for modifications •Approval or rejection by proper officer •No rejection without SCN/giving opportunity of being heard •Automatic approval/rejection in other act i.e CGST/SGST CMA NAVNEE KUMAR JAIN: FCMA, LL.B., MBA, PGDTL, AIIISLA, LIII Matters when Govt. shall not be regarded as Taxable Person Schedule IV (Indicative List Only) CMA NAVNEE KUMAR JAIN: FCMA, LL.B., MBA, PGDTL, AIIISLA, LIII •By Govt./Local Authority(LA) to Govt or public Authority (excluding Transportation of goods or persons, by Department of posts in relation to speed post, express parcel post etc, services in relation to aircraft or vessel) •By Govt. or LA to individuals in discharge of statutory power functions like issues of driving licences or certificates of deaths/births. •By Govt./LA/Govt. Authority towards healthcare, education, functions of Municipality etc Matters when Govt. shall not be regarded as Taxable Person Schedule IV (Indicative List Only) contd.. CMA NAVNEE KUMAR JAIN: FCMA, LL.B., MBA, PGDTL, AIIISLA, LIII •Services provided by Government towards- diplomatic or consular activities; citizenship, naturalization and aliens; admission into , and emigration and expulsion from India; •currency, coinage and legal tender, foreign exchange; •trade and commerce with foreign countries, import and export across customs frontiers, interstate trade and commerce; or •maintenance of public order. Matters when Govt. shall not be regarded as Taxable Person Schedule IV (Indicative List Only) contd.. CMA NAVNEE KUMAR JAIN: FCMA, LL.B., MBA, PGDTL, AIIISLA, LIII •Any services provided by a Government or a local authority in the course of discharging any liability on account of any tax levied by such Government or authority •Services provided by a Government or a local authority by way of – –tolerating non-performance of a contract for which consideration in the form of fines or liquidated damages is payable to the Government or the local authority under such contract; or –assignment of right to use any natural resource where such right to use was assigned by the Government or the local authority before the 1st April, 2016: •Exemption only for service tax payable on one time payment not for periodic payment Matters when Govt. shall not be regarded as Taxable Person Schedule IV (Indicative List Only) contd.. CMA NAVNEE KUMAR JAIN: FCMA, LL.B., MBA, PGDTL, AIIISLA, LIII •Services provided by Government by way of deputing officers after office hours or on holidays for inspection or container stuffing or such other duties in relation to import or export of cargo on payment of Merchant Overtime Charges (MOT) •Services provided by Government or a local authority by way of- –registration required under any law for the time being in force; or –testing, calibration, safety check or certification relating to protection or safety of workers, consumers or public at large, required under any law for the time being in force Cancellation of Registration CMA NAVNEE KUMAR JAIN: FCMA, LL.B., MBA, PGDTL, AIIISLA, LIII •By Officer at own or •On application by Registered person or by successor of such person incase of death –the business has been discontinued, –transferred fully for any reason including death of the proprietor, –amalgamated with other legal entity, –demerged or otherwise disposed of; or Cancellation of Registration CMA NAVNEE KUMAR JAIN: FCMA, LL.B., MBA, PGDTL, AIIISLA, LIII •there is any change in the constitution of the business; or •the taxable person is no longer liable to be registered under Schedule III Cancellation of Registration CMA NAVNEE KUMAR JAIN: FCMA, LL.B., MBA, PGDTL, AIIISLA, LIII •By the officer –Contravention of the provisions of the Act by Registered person –Non filing of returns for three consecutive months by persons registered under composition scheme. –any taxable person, other than a person specified above has not furnished returns for a continuous period of six months –any person who has taken voluntary registration has not commenced business within six months from the date of registration Cancellation of Registration with retrospective effect CMA NAVNEE KUMAR JAIN: FCMA, LL.B., MBA, PGDTL, AIIISLA, LIII •In case registration has been obtained by means of fraud, wilful misstatement or suppression of facts, the proper officer may cancel the registration with retrospective effect •What will happen to Input credits taken on the basis of bills issued by that person??? Law of Natural Justice Cancellation only after issue of SCN & giving opportunity of being heard Cancellation under one Act means cancellation under another Act (CGST & SGST) CMA NAVNEE KUMAR JAIN: FCMA, LL.B., MBA, PGDTL, AIIISLA, LIII Documents to be kept ready for Registration (Existing/New) •Scanned documents are required to be filed along with the application for Registration for following, so these should be kept ready 1.Constitution of Business (Partnership Deed, RC etc. For companies data will be fetched from MCA) 2.Details of the Principal Place of business (Electricity Bill, Municipal taxes receipt etc. or lease deed) 3.Details of Bank Account(s) (Opening page of the Bank,Passbook held in the name of the Proprietor / Business Concern – containing the Account No., Name of the Account Holder, MICR and IFS Codes and Branch details) 4.Details of Authorised Signatory. (Resolutions etc) 5.Photograph (Authorised signatory, maximum of 10 partners/ Directors etc) CMA NAVNEE KUMAR JAIN: FCMA, LL.B., MBA, PGDTL, AIIISLA, LIII What Existing Assesses under Excise/Vat/Service tax or other Acts will be required to do •Provisional Certificate of registration will be issued by GSTN •It will be valid for six months only •Desired information/documents will be required to be submitted by existing registered assesses within six months to synchronise the documentation with new assesses. (All registered assesses will have to submit the same set of documents) CMA NAVNEE KUMAR JAIN: FCMA, LL.B., MBA, PGDTL, AIIISLA, LIII Business process •Business process on Registration CMA NAVNEE KUMAR JAIN: FCMA, LL.B., MBA, PGDTL, AIIISLA, LIII Salient Features of Registration Process 4  PAN based Registration: PAN will be mandatory  Unified application to both tax authorities  To be filed within 30 days  State-wise registration for entities having presence in more than one State  Need not apply separately for each State  Deemed approval within three days  Within a PAN, separate registration for separate business verticals within a State possible CMA NAVNEE KUMAR JAIN: FCMA, LL.B., MBA, PGDTL, AIIISLA, LIII Structure of GSTIN 5  15 digit Alphanumeric structure  State-wise  Based on PAN 13th Digit for Business Verticals of entities with same  PAN in same State 14th 15th digit left blank for future use digit – Checksum   State PAN Entity Blank Check 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 CMA NAVNEE KUMAR JAIN: FCMA, LL.B., MBA, PGDTL, AIIISLA, LIII Suppliers under Composition Scheme 6  Suppliers with turnover below a particular threshold eligible for composition scheme  To pay tax on turnover with no input tax credit  To opt at the beginning of the year – applicable eligibility or opting out  Switch from composition to regular scheme voluntarily or on crossing threshold  Suppliers making interstate supplies not eligible till CMA NAVNEE KUMAR JAIN: FCMA, LL.B., MBA, PGDTL, AIIISLA, LIII Obtaining Registration 7  Migration of existing tax payers database  Taxpayers with valid PAN  Online application form through  Documents to be filed for registration  Constitution of Business  Principal Place of Business  Bank Accounts  Authorised Signatory  Photograph to the GSTN Common Portal CMA NAVNEE KUMAR JAIN: FCMA, LL.B., MBA, PGDTL, AIIISLA, LIII Obtaining Registration 8  Applications not submitted through be supported by sending a signed extract of the form Digital Signature to copy of summary  Processing of application and grant of registration even before signed copy received  Cancellation to be initiated if no signed copy received  Email and SMS based alerts to the applicants  No application fee (advance tax in case of casual suppliers)  Applications can be filed through Facilitation Centres (FCs) or through Tax Return Preparers (TRPs) CMA NAVNEE KUMAR JAIN: FCMA, LL.B., MBA, PGDTL, AIIISLA, LIII Approval process 9  Online verification of certain details like PAN, CIN, Bank Account (if possible) and Adhaar  Online communication of application to jurisdictional authority by the backend modules of tax authorities  3 common working days for tax authorities to respond  Deemed approval after 3 days  Single opportunity to tax authorities to raise query, if any – 7 days for response and 7 days for action  Mostly post registration visits based on risk profile CMA NAVNEE KUMAR JAIN: FCMA, LL.B., MBA, PGDTL, AIIISLA, LIII Approval process 10  Online grant of registration  Log-in id and temporary password the tax payer communicated to  Downloadable Registration Certificate to be provided by GSTN  Refusal to register by one tax authority deemed as refusal by both  Communication of reason for refusal of registration CMA NAVNEE KUMAR JAIN: FCMA, LL.B., MBA, PGDTL, AIIISLA, LIII Migration of Existing Tax Payers 11  Existing registrants either with States or with Centre to be migrated to GSTIN - Process already initiated  VAT registration data to be used for migration of dealers in goods  Service Tax registration data to be used for migration of service providers  Validation of existing registration information by GSTN  Verification /updation of migrated data by existing registrants within a specified period  Issuance of GSTIN by GSTN  Verification by Centre/State Authorities after issuance of GSTIN CMA NAVNEE KUMAR JAIN: FCMA, LL.B., MBA, PGDTL, AIIISLA, LIII Amendment to Registration Details 12  On-time amendment essential for efficient tax administration  Most of the details to be amended by the tax payer on self service basis  Some of them like mobile number and email address through online verification  Some critical details like name, principal place of business to be amended after approval from tax authorities CMA NAVNEE KUMAR JAIN: FCMA, LL.B., MBA, PGDTL, AIIISLA, LIII Surrender and Cancellation 14  Cancellation by Tax authorities:  Signed copy of the summary extract of submitted application form not received even after a reminder  Tax payer contravenes specified provision of the GST law  Taxpayer has not filed any return at all during a prescribed period as prescribed under GST Law  Cancellation of registration to be prospective  A person, whose registration was cancelled by tax authority on his own motion, may apply for revocation of registration  Substantial penalty in case registration obtained with fraudulent intentions CMA NAVNEE KUMAR JAIN: FCMA, LL.B., MBA, PGDTL, AIIISLA, LIII Status of Amendment Bill The Constitution (122nd Amendment) (GST) Bill, 2014 Stage Date Introduction Dec 19, 2014 Com. Ref. May 14, 2015 Com. Rep. July 22, 2015 Lok Sabha May 06, 2015 Rajya Sabha CMA NAVNEE KUMAR JAIN: FCMA, LL.B., MBA, PGDTL, AIIISLA, LIII Registration under GST 2 Forms under GST Annexure Particulars III GST Registration Application Form IV Application Form for Surrender / Cancellation of registration V Application Form to opt for Compounding Scheme VI Application Form to withdraw from Compounding Scheme VII Application for Amendment of registration subsequent to Registration CMA NAVNEE KUMAR JAIN: FCMA, LL.B., MBA, PGDTL, AIIISLA, LIII CMA NAVNEE KUMAR JAIN: FCMA, LL.B., MBA, PGDTL, AIIISLA, LIII CMA NAVNEE KUMAR JAIN: FCMA, LL.B., MBA, PGDTL, AIIISLA, LIII CMA NAVNEE KUMAR JAIN: FCMA, LL.B., MBA, PGDTL, AIIISLA, LIII CMA NAVNEE KUMAR JAIN: FCMA, LL.B., MBA, PGDTL, AIIISLA, LIII CMA NAVNEE KUMAR JAIN: FCMA, LL.B., MBA, PGDTL, AIIISLA, LIII CMA NAVNEE KUMAR JAIN: FCMA, LL.B., MBA, PGDTL, AIIISLA, LIII Some other Key Points •Goods and Services Taxes Network (GSTN) is the world's largest open source project. CMA NAVNEE KUMAR JAIN: FCMA, LL.B., MBA, PGDTL, AIIISLA, LIII References •Model GST Law •Report of the Joint Committee on Business Processes for GST on Registration Processes in GST Regime •Presentation by DOR, MOF, GOI CMA NAVNEE KUMAR JAIN: FCMA, LL.B., MBA, PGDTL, AIIISLA, LIII Thanks CMA Navneet Kumar Jain 9810175020 cmanavneetjain@gmail.com CMA NAVNEE KUMAR JAIN: FCMA, LL.B., MBA, PGDTL, AIIISLA, LIII