Budget 2018 – Analysis of Direct Tax Proposals

UNION BUDGET 2018-2019

HIGHLIGHTS OF THE FINANCE BILL, 2018

The Honorable Finance Minister of India, Mr. Arun Jaitley, delivered the fifth Union Budget of NDA Government, last full budget before the upcoming general elections in 2019 amidst various challenges, compelling the Government to do a balancing act of revival of economic growth, laying greater emphasis on people centric measures, to keep moving the drive against black money, consolidating the formal economy and managing fiscal prudence to maintain and further improve India’s rating in the world.

Keeping in mind the Government’s long term commitments; to reduce the fiscal deficit to 3.3% next year, to ensure increase public spending to boost demand, focus on agriculture and less advantaged groups like poor and senior citizens and at the same time deal with unprecedented expectations from all quarters, the Finance Minister had limited avenues to navigate the way forward, which is evident from the fine print of the proposals.

This required the Finance Minister to raise revenues and at the same time tone up the environment of business, economy and to create a vibrant atmosphere for the people.

The Finance Minister’s proposals are inspired by Prime Minister’s vision “Minimum Government and Maximum Governance”.

As an annual event, we once again make effort in this note to elucidate and analyze the major and important amendments proposed in the Direct Tax (not Service Tax Laws, as it has been subsumed into the recent levy of Goods and Service Tax) with their implications; and are sure that the same would be handy to you.

As of date, these are proposals only, and if adopted by the Parliament and passed as Finance Act; will come into force for and from Assessment Year 2019-2020 relevant to Financial Year 2018-2019, unless specifically provided otherwise.

I. DIRECT TAXES

Amendments proposed under the Income-tax Act, 1961 (hereafter referred to as “the Act”).

A. Rates of Tax

1. Basic Exemption Limit, Income Slabs and Surcharge unaltered; Cess increased for all Assessee:

Income thresholds, basic tax rates and Cess

The rates of Basic Tax, as well as the Basic Exemption Limits and income slabs have been kept unaltered for all Assessees other than Company.

However, in lieu of current Education Cess and Higher Education Cess on Income Tax, The Finance Minister has proposed a new Cess “Health and Education Cess” to be levied at the rate of 4% against earlier Cess of 3%; for all the Assessees.

The applicable Basic Exemption and Income Slabs as well as basic tax rates, are given in the below Table for your ready reference:

Assessee	Basic exemption and Income Slabs for Financial Year 2018-19
	Total Income	Tax Rate
All Individuals, HUF, AOP and BOI (except those stated below)	upto Rs.2,50,000/-	Nil
	Rs.2,50,001/- to Rs.5,00,000/-	5% of income above Rs.2,50,001/-
	Rs.5,00,001/- to Rs.10,00,000/-	Rs.12,500/- plus 20% of income above Rs.5,00,001/-
	Above Rs.10,00,000/-	Rs.1,12,500/- plus 30% of income above Rs.10,00,001/-
Individuals, being resident, and above 60 years upto the age of 80 years	upto Rs.3,00,000/-	Nil
	Rs.3,00,001/- to Rs.5,00,000/-	5% of income above Rs.3,00,001/-
	Rs.5,00,001/- to Rs.10,00,000/-	Rs.10,000/- plus 20% of income above Rs.5,00,001/-
	Above Rs.10,00,000/-	Rs.1,10,000/- plus 30% of income above Rs.10,00,001/-
Individuals, being resident, and age 80 years and above	upto Rs.5,00,000/-	Nil
	Rs.5,00,001/- to Rs.10,00,000/-	20% of income above Rs.5,00,001/-
	Above Rs.10,00,000/-	Rs.1,00,000/- plus 30% of income above Rs.10,00,001/-

Further, the rate of Surcharge for all other Assessee is kept unaltered (with marginal relief as stated in the preceding paragraph).

2. Turnover threshold for reduced Rate of Tax increased for domestic Company:

Keeping up to the promise in the last Budget, this time the Finance Minister has proposed to extend the benefit of reduced Corporate Tax of 25% (plus Surcharge and Cess as applicable) for domestic companies having turnover or gross receipts less than Rs.250 Crores in the Financial Year 2016-17.

B. Measures impacting Individuals, HUF’s and Small Businesses

3. Standard deduction on Salary income:

In the Budget Speech, the Finance Minister has said that to provide relief to salaried taxpayers, he has proposed to allow a standard deduction of Rupees 40,000/- or the amount of salary per annum, whichever is less in lieu of the present exemption in respect of Transport Allowance and reimbursement of miscellaneous medical expenses.

Hence, the net benefit for the employees already claiming deduction for transport allowance and medical reimbursement will be Rs. 5,800/- {Rs. 40,000 – (Rs. 19,200 + Rs. 15,000)}.

Also, it is clarified that Transport allowance will continue for differently abled persons.

4. Increased deduction in respect of Health Insurance Premia under Section 80D for Senior Citizen:

In view of continuous rise in the cost of medical expenditure, it is proposed to amend section 80D of the Act, to raise the limit of deduction from Rs. 30,000/- to Rs. 50,000/- per annum in respect of any health insurance premium and/or any general medical expenditure incurred by senior citizen.

Further, in case of single premium health insurance policies covering more than one year, the deduction shall be allowed on proportionate basis, subject to the specified monetary limit.

For your easy reference, we give here under an Illustration showing Deduction under section 80D, as proposed:

Age of Individual	Deduction for self and family (Rs.)	Age of Parents	Deduction for parents (Rs.)	Total Deduction (Rs.)
	(a)		(b)	(c) = (a) + (b)
below 60 years	25,000	below 60 years	25,000	50,000
below 60 years	25,000	above 60 years	50,000	75,000
above 60 years	50,000	above 60 years	50,000	1,00,000

 5. Higher deduction to Senior Citizens for medical treatment of specified diseases:

Considering the continuous rise in cost of medical expenditure for specified diseases, the Finance minister has proposed to amend section 80DDB of the Act, to raise the limit of deduction for medical expenditure in respect of certain critical illness from present Rupees 60,000/- in case of senior citizens and Rupees 80,000/- in case of very senior citizens, to Rupees 1,00,000/- in respect of all senior citizens.

6. Higher deduction in respect of Interest income and increased threshold for TDS to Senior Citizens:

The Finance Minister has proposed to insert a new section 80TTB so as to allow a deduction upto Rs. 50,000/- in respect of interest income from deposits held by senior citizens; from the current limit of Rs. 10,000/- under section 80TTA of the Act.

Needless to state that, no deduction under section 80TTA shall be allowed in above cases.

There apart, it is also proposed to amend section 194A of the Act to raise the threshold for deduction of tax at source on interest income payable to senior citizens from current Rupees 10,000/- to Rupees 50,000/- per annum.

(The above amendment would take effect from Assessment Year 2018-19.)

7. Rationalization of tax treatment of NPS to non-employee subscribers:

In order to provide a level playing field to employee as well as non-employee subscribers of National Pension Scheme (‘NPS’), it is proposed to amend clause (12A) of section 10 of the Act to extend the said benefit to all subscribers.

C. Compliance, Governance and Rationalization

8. Rationalization of Deduction in respect of income of Farm Producer Companies:

In order to encourage professionalism in post-harvest value addition in agriculture, and bring parity in taxation of income of co-operative societies and Producer Companies providing assistance to its members engaged in primary agricultural activities; the Finance Minister has proposed to insert new section 80PA to allow 100% deduction of profits attributable from eligible business to such companies having annual turnover up to Rupees 100 Crores for a period of five years from Financial Year 2018-19.

9. Widening the scope of ‘Accumulated Profits’ for the purpose of Dividend:

In order to prevent the abuse of amalgamation route by companies, to avoid liability of Dividend Distribution Tax (‘DDT’); it is proposed to amend section 2(22) of the Act so as to provide that for computing accumulated profits of amalgamated company, whether capitalized or not, the accumulated profits of amalgamating company shall be included therein.

(The above amendment would take effect from Assessment Year 2018-19.)

10. Rationalization of Deduction to eligible Start-up company:

In order to improve the effectiveness of the scheme for promoting Start-ups in India, it is proposed to make following changes in the existing taxation regime per section 80-IAC:

> The benefit of deduction would also be available to start-ups incorporated on or after the 1^st April 2019 but before 1^st April, 2021;

> The requirement of the Turnover being less than or equal to Rupees 25 Crores applicable to seven previous years commencing from the date of incorporation;

> The definition of eligible business has been expanded to provide that the benefit would be available if it is engaged in innovation, development or improvement of products or processes or services, or a scalable business model with a high potential of employment generation or wealth creation.

(The above amendment would take effect from Assessment Year 2018-19.)

11. Extension of Incentives for employment generation:

In order to encourage creation of new employment to footwear and leather industry, it is proposed to extend the relaxation of minimum period of employment of new workers of 150 days which is currently provided to the apparel industry.

Further, it is also proposed to rationalize the deduction of 30% by allowing the benefit for a new employee who is employed for less than the minimum period during the first year but continues to remain employed for the minimum period in subsequent year.

12. Rationalization of Tax treatment of transactions in respect of trading in Agricultural Commodity Derivatives:

With a view to encourage participation in trading of agricultural commodity derivatives, the Finance minister has proposed to amend section 43(5) of the Act to provide that a transaction in respect of trading of agricultural commodity derivatives, which is not chargeable to Commodities Transaction Tax (‘CTT’), in a registered stock exchange or registered association, will be treated as non-speculative transaction.

13. Rationalization of treatment on difference in Stamp valuation of immovable Property-Welcome move:

In order to minimize hardship in case of genuine transactions in the real estate sector, leading variation in the valuation of immovable property as per Stamp Duty Ready Reckoner and Sale Consideration of the property; it is proposed to provide that no adjustments shall be made in a case where the variation is not more than 5% of the Sale Consideration.

Consequential amendments are proposed in section 43CA, section 50C and section 56(2)(x) of the Act.

14. Rationalization of provision relating to conversion of stock-in-trade into Capital Asset:

In order to provide symmetrical treatment and discourage the practice of deferring the tax payment by converting the inventory into capital asset, the following amendments are proposed:

> section 28 would provide that any profit or gains arising from conversion of inventory into capital asset or its treatment as capital asset shall be charged to tax as business income at fair market value;

> Fair market value of the inventory on the date of conversion or treatment to be determined in the prescribed manner;

> Definition of income in clause (24) of section 2 to include such fair market value, as above;

> section 49 to provide that for the purposes of computation of capital gains arising on transfer of such capital assets, the fair market value on the date of conversion shall be the cost of acquisition;

> clause (42A) of section 2 so as to provide that the period of holding of such capital asset shall be reckoned from the date of conversion or treatment.

15. Rationalization of provision related to certain transfers among Holding and Subsidiary companies -Welcome move:

In order to further facilitate the transaction of money or property between a wholly owned subsidiary company and its holding company, it is proposed to amend the section 56 so as to exclude such transfer from its scope.

16. Rationalization of the provisions of section 54EC:

To restrict the scope of the section only to capital gains arising from long-term capital assets, being land or building or both and to make available funds at the disposal of eligible bond issuing company for more than three years, it is proposed to amend the section 54EC so as to provide that land or building or both would only be eligible assets.

Also, for investments made in specified Bonds upto 31^st March 2018, the lock in period would be 3 years and for investments made thereafter, it would be 5 years.

17. Rationalization of provisions of Income Computation and Disclosure Standard (‘ICDS’):

With a view to provide parliamentary accent and constitutional validity to the ICDS, in wake of recent judgment of Delhi High Court in case of Chamber of Tax Consultants challenging validity of ICDS; the Finance Minister has given now proposed to introduce the relevant provisions in the Income Tax Act, 1961.

This step of the Finance Minister may be an indicator for introduction of more ICDS in the years to come, under the guise of resting litigation and bringing in consistency in tax administration.

Salient features of the new proposal, is as under:

• Deduction for Marked to Market loss or other expected loss calculated in accordance with the provisions of ICDS to be allowed;
• Gains or Loss arising from foreign exchange fluctuations (except transactions relating to imported capital assets) to be computed in accordance with ICDS;
• Percentage of Completion Method (‘POCM’) to be applied while computing profits and gains from construction contract;
• Profits and gains from service contracts to be determined under POCM with following exceptions:
  • If the project duration is upto or more than ninety days, Project Completion Method to be used;
  • If the project involves indeterminate number of acts over a specific period of time, Straight Line Method (SLM) would have to be used;
• Unlisted securities or listed securities (not quoted on a recognized stock exchange) held as inventory to be valued at actual cost initially determined in accordance with ICDS.
• In other cases, inventory including securities other than those referred above shall be valued at lower of actual cost or net realizable value computed in accordance with ICDS.
• Valuation of inventory to include duty, tax, cess or fee, etc. incurred to bring such goods or services to the place of its location / condition on the valuation date.
• The following are to be taxed in the year of receipt:
  • Interest on any compensation or enhanced compensation;
  • Government Grants (including subsidy, cash incentive and duty drawback) if not charged to tax in an earlier year
• A claim for escalation of price in a contract / export incentive will be taxable in the previous year when its realization is reasonably certain

(The above amendments are applicable retrospectively and would take effect from Assessment Year 2017-18.)

18. Rationalization of additions by Assessing Officer on account of unexplained cash credits etc.:

As per the existing provisions of section 115BBE of the Act, Income referred to in section 68 /69 /69A /69B 69C and 69D of the Act are taxed at a higher rate of sixty percent.

Further, sub-section (2) of section 115BBE of the Act provides that no deduction in respect of any expenditure or allowance or set-off of any loss shall be allowed to the assessee under any provision of the Act in computing his income referred to in clause (a) of sub-section (1).

As Additions of income including under section 68 /69 /69A /69B 69C and 69D of the Act by the Assessing officer were outside the purview of Sub Section (2), the Assessee could claim deductions and/ or set –off losses against the same, thereby creating anomaly.

Therefore, it is proposed to amend sub section (2) to also include therein the additions made by the Assessing Officer.

(This amendment would apply retrospectively from Assessment Year 2017-18 onwards)

19.Tax on income distributed by an Equity Oriented Fund

Hitherto, Equity Oriented Mutual funds were exempt from paying taxes on the income distributed to the unit holders.

To have level playing field, given the new era of taxability of Long Term Capital Gains as per section 112A, it is now proposed to amend section 115R and section 115T to provide that where any income is distributed by a Mutual Fund being, an equity oriented fund, the Mutual fund shall be liable to pay additional income tax on distribution of income at the rate of 10% (plus applicable Surcharge and Cess).

D. Mobilization of Resources

20. New regime for taxation of Long-term Capital Gains on sale of Equity shares etc.:

In order to garner additional resources, to support the Governments reforms and initiatives, the Finance Minister has made out a strong case to bring back tax on Long-term Capital Gain arising on transfer of listed Equity shares, unit of an Equity Oriented Fund or a unit of a Business Trust (all are collectively referred to as ‘specified asset’), given the buoyancy in equity market and returns delivered by equity as an asset class.

The Finance Minister has proposed to insert new section 112A to tax above Long Term Capital Gains in excess of Rupees One Lakh, at concessional rate of 10% (Without indexation), provided Securities Transactions Tax (‘STT’) has been paid at the time of acquisition and transfer of specified asset.

Needless to state that, in case acquisition of listed equity share is done without STT, then the applicable tax rate for long term capital gain would be 20% as per section 112 of the Act.

The Government is likely to notify specified instances wherein the condition of payment of STT at the time of acquisition of equity share or on transfer of Units through recognized stock exchange in any International Financial Services Centre (‘IFSC’) would not be applicable for concessional rate of 10%.

The other salient features of the new regime are as under:

> Benefit of indexation and conversion in foreign currency in case of non-resident, done away with;

> Grandfathering of Long Term Capital Gains earned upto 31^st January 2018;

For specified assets acquired before 1^st February 2018; cost of acquisition shall be deemed to be to be the higher of –

a) the actual cost of acquisition of such asset; and

b) the lower of –

(I) the fair market value of such asset on 31^st January 2018; and

(II) the full value of consideration received or accruing as a result of the transfer of the capital asset.

> Benefit of exemption under section 10(38) stands withdrawn;

> Deductions under Chapter VI-A of the Act are not eligible on above gains;

> Rebate under section 87A not available on tax payable under Section 112A.

> Concessional rate of 10% to also apply to Foreign Institutional Investors-consequential amendment proposed in section 115AD of the Act.

Illustration on how Long Term Capital Gains on equity shares or equity oriented mutual fund will be Taxed under section 112A:

Date of Investment	Actual Cost (Rs.)	Market Value as on 31/01/2018	Date of Sale	Sale Proceed (Rs.)	Actual Gain (Rs.)	Taxable Gain (Rs.)	Taxability
(a)	(b)	(c)	(d)	(e)	(f) = (e) – (b)	(g) = (e) – (c)
31/01/2017	1,00,000	1,30,000	Upto 31/03/2018	2,50,000	1,50,000	1,50,000	No tax will be payable as the amendment is with effect from 1st April, 2018
31/01/2017	1,00,000	1,30,000	After 01/04/2018	2,00,000	1,00,000	70,000	No tax will be payable since the gain is below threshold of Rs. 1,00,000
31/01/2017	1,00,000	1,30,000	After 01/04/2018	3,00,000	2,00,000	1,70,000	Tax will be levied at 10% on gains over Rs. 1,00,000 taking cost of acquisition as FMV as on 31st January, 2018 i.e. on Rs. 70,000. Tax liability will be Rs. 7,000

21. Restriction of exemption in case of payments by Trust and other one exempt entities:

In order to bring trusts and institutions under the ambit of Tax Deduction at Source (‘TDS’) mechanism, encourage a less cash economy and to reduce the generation and circulation of black money, it is proposed to provide that the relevant expenditure would not be considered as application of income under section 10(23C) and section 11 of the Act, if TDS thereon is not done by the payer.

There apart, it is also proposed that if payment for any expenditure is made in cash exceeding the limit prescribed under section 40A (3) or Section 40A(3A) of the Act i.e. Rupees Ten Thousand in a day, then the same would not qualify as application of income.

22. Rationalization of scope of ‘business connection’ in line with BEPS Action Plan 7 and MLI:

With a view to prevent abuse of the Double Taxation Avoidance Agreements (‘DTAA’s) by base erosion and profit shifting, the Finance Minister has proposed to amend section 9 of the Act so as to align it with the provisions in the DTAA, as modified by Multilateral Convention to Implement Tax Treaty Related Measures (‘MLI’), to which India is also a signatory; so as to make the provisions in the DTAA effective.

Accordingly, clause (i) of sub-section (1) of section 9 is proposed to be amended to provide that “business connection” shall also include any business activities carried through a person who, acting on behalf of the non-resident, habitually concludes contracts or habitually plays the principal role leading to conclusion of contracts by the non-resident.

23. Expansion of scope of ‘business connection’ to meet challenges of digital economy in line with BEPS Action Plan 1:

To keep pace with the emerging business models such as digitized businesses, which do not require physical presence through any entity or agent in India, and yet meet challenges to have the right to tax business profits derived from Indian economy such that there is no base erosion or profit shifting; it is proposed to amend clause (i) of sub-section (1) of section 9 of the Act to provide that ‘significant economic presence’ of non-resident in India shall also constitute ‘business connection’.

The above provisions will apply irrespective of whether the non-resident has a residence or a place of business in India or renders services in India

Further, the Government would notify the threshold of ‘revenue’ and ‘users’ after consultation with the stakeholders.

Needless to state that benefits of DTAA would continue to apply to non-residents who are entitled to claim treaty benefits.

24. Taxability of Compensation in connection to business or employment:

With the objective of bringing to taxation the gamut of compensation receipts in connection with business and employment, the Finance minister has proposed to amend section 28 and section 56 of the Act appropriately, such that above compensation whether in the nature of revenue or capital would become taxable.

25. Deduction under Chapter VI-A eligible only if return of income is filed in time:

The Finance Minister has proposed to extend the scope of section 80AC to provide that the benefit of deduction under the entire class of deductions under the heading “C.-Deductions in respect of certain incomes” in Chapter VIA shall not be allowed unless the return of income is filed by the due date prescribed.

(The above amendment would take effect from Assessment Year 2018-19.)

26. Taxation of Deemed Dividends

Hitherto, Deemed Dividend as per section 2(22)(e) was taxable in the hands of the recipient as per the slab rate of taxation of the recipient.

In order to bring clarity and certainty as to time of the collection and rate, amendments have been proposed to section 115O and 115 Q to provide that Deemed Dividend would be subject to Dividend Distribution Tax under section 115-O at the rate of 30 % (without grossing up), and all other provisions of Chapter XII- shall be applicable to such Deemed Dividend.

E. Easing of compliance burden and dealing with the Department

27. Enhancing Productivity of Tax Administration and increased thrust on E-assessments:

With a view to restrict the scope of adjustments, it is proposed to provide that no adjustment under sub-clause (vi) of the section 143(1) shall be made on account of discrepancy in total income reported in return of income vis-à-vis Form 26AS or Form 16/16A; in respect of any return furnished on or after the assessment year commencing on the first day of April, 2018.

(The above amendment would take effect from Assessment Year 2018-19.)

In order to promote E Assessments, reduce the interface between the Assessee and the tax administrators, the Government proposes to have the assessments be done by a team so as to be productive and efficient.

Notifications regarding the same shall be issued separately.

So, be ready for the faceless team coming your way in assessments.

F. Futuristic Measures-promoting investments and clarity on taxation

28. Welcome Clarification-Benefit of Carry Forward Losses available to company seeking Insolvency resolution:

To remove the hurdle for restructuring and rehabilitation of companies seeking insolvency, it is proposed to relax the rigors of section 79 in case of such companies, whose resolution plan has been approved under the Insolvency and Bankruptcy Code, 2016; such that the change in the beneficial ownership of shares beyond the permissible limit under section 79 does not come in way of carry-forward and set-off of losses.

(The above amendment would be applicable from Assessment Year 2018-19)

29. Relief for Insolvency Companies under Minimum Alternate Tax (‘MAT’)

To remove the hurdle for restructuring of companies seeking insolvency, it is proposed to allow the reduction of loss brought forward (excluding unabsorbed depreciation) and unabsorbed depreciation for the purposes of computing book profit under section 115JB of the Act, in case of a company whose application has been admitted by the Adjudicating Authority under the Insolvency and Bankruptcy Code, 2016.

(The above amendment would be applicable from Assessment Year 2018-19)

Further, there is another welcome clarification that MAT will not apply to a non-resident covered by a presumptive tax regime (i.e oil and gas, shipping, aircraft operations,)

(This amendment would apply retrospectively from Assessment Year 2001-02 onwards)

30. Incentive to conducting business in International Financial Service Centers

In order to promote the development of world class financial infrastructure in India, it is further proposed to amend the section 115JC so as to provide that in case of a unit located in an International Financial Service Center, the alternate minimum tax under section 115JC shall be charged at the rate of 9 percent.

Consequential amendment in section 115JF is also proposed to be made.

G. Others

31. Rationalization of Presumptive income under section 44AE for goods carriage:

To meet the ultimate objective of presumptive taxation scheme to small transporters, reduce their compliance burden, and maintain equity for small and large transporters, it is proposed to reduce the deemed income of small transporters to Rupees 1,000 per ton of gross weight, per month for each vehicle, or amount actually earned, whichever is higher; from the current rate of Rupees 1,000 per month for each vehicle.

32. Increased Penalty for failure to furnish Statement of Financial Transaction or Reportable Account:

The existing penalty for failure by an Assessee to submit the Financial transaction or reportable account as per the provisions of section 271FA within the time limit prescribed is Rupees One hundred for every day of default, which is now proposed to be raised to Rupees Five Hundred for every day of default.

Further in case such person fails to furnish the statement of financial transaction or reportable account within the period specified in the notice issued under sub-section (5) of section 285BA, currently he shall be liable to pay penalty of Rupees Five Hundred for every day of default which is now being proposed to be raised to Rupees One thousand for every day of default.

33. Transfer Pricing – Rationalization of provisions relating to Country-by-Country Report (‘CbCR’):

The due date for filing CbCR by an Indian ultimate holding company or an Indian alternate reporting entity is proposed to be extended to Twelve months i.e. 31 March of the following accounting year (as against current due date of 30 November set out in the Finance Bill, 2017)

Further, Indian entity is required to file CBCR if it is not filed by ultimate parent entity or alternate reporting entity

(The above amendment would be applicable from Assessment Year 2018-19)

34. Miscellaneous:

> Companies would be prosecuted for non-filing of returns even if no tax is due;

> Assessee, other than an Individual, having financial transactions exceeding Rupees Two Lakhs Fifty Thousand in a financial year would be required to obtain a Permanent Account Number (PAN).

(Compiled By Partners of ‘B. S. Shah & Co., Chartered Accountant’ Namely (i) Bhupendra Shah -B.Com., L.L.B. (SP.), A.C.S., F.C.A. (ii) N. Krishnakumar- B.Com., F.C.A., Grad CWA and (iii) Shreyam Shah -B.Com. A.C.A.,DISA)