BARODA BRANCH
of the
WIRC of The Institute of Chartered
Accountants of India
&
CREDAI
Issues under FEMA Act for Real Estate
Presented by
CA Natwar G. Thakrar
April 27, 2013
1
AGENDA
• Introduction
• Meaning of NRI/PIO
• Investment (other than FDI) by
NRI/PIO and a Branch of a Foreign
Company, Transfer & Repatriation
of Sale Proceeds
• Investment abroad in Real Estate
by Individuals/ Companies
• FDI in Real Estate (including by
NRI/PIOs)
• Investment abroad in Real Estate
Developments by Person
Resident in India
• Q&A
April 27, 2013
2
Introduction
• Regulation of Acquisition & Transfer of Immovable Properties –
– For Properties in India- S. 6(3)(i) of FEMA Act alongwith
• FDI Policy of the Government of India / Notification No. 20 of FEMA in respect of Construction Development Projects in India
• Notification No. 21 in respect of purchase by NRIs/ POIs in India except for a lease not exceeding 5
years
– For Properties abroad – S. 6(3(h) of FEMA Act alongwith
• Notification No. 7 in respect of purchase of Immovable Property abroad by Indian Residents except
for a lease not exceeding 5 years
• Notification No. 120 in respect of Investments in immovable property abroad by an Indian company
• Unlike FERA, the thrust is on residential status of a person determined under
Section 2(v) of FEMA and not on citizenship of a person subject to
– The person concerned would have to obtain the approvals and fulfil the requirements, if
any, prescribed by other authorities, such as, the State Government concerned, etc. The
onus to prove his/her residential status is on the individual as per the extant FEMA
provisions, if required by any authority.
– General restrictions on citizens of eight countries (viz. citizen of Pakistan or Bangladesh
or Sri Lanka or Afghanistan or China or Iran or Nepal or Bhutan) irrespective of their
residential status and
– Restriction on buying agricultural land / plantation property / farm house.
April 27, 2013
3
Meaning of NRI/ PIO/Person Resident in India
How do I
interpret
these
provisions??
April 27, 2013
4
Non Resident Indian (NRI)
•
The term NRI has not been defined in FEMA, 1999. Section 2(w) defines a “person
resident outside India” as a person who is not resident in India.
•
The term “NRI” has different meanings under different Notifications, e.g.– Under Notification No. 13- Remittance of AssetsAn “NRI” is defined to mean a person residing outside India, who is a citizen of India.
– Under Notification No. 5 – Deposits “An “NRI” is defined as a person resident outside India who is a citizen of India or is a Person
of Indian Origin (PIO)”
•
Therefore, meaning of NRI could change due to different PIO definitions under
various Notifications issued by the RBI
•
For the purpose of Immovable property, meaning given under Notification 13 shall
be relevant as NRI does not include PIO.
•
It is possible that a person may be an NRI under FEMA, yet may be a resident of
India under Income tax laws.
April 27, 2013
5
Person of Indian Origin (PIO)
• The term PIO is also not defined in FEMA, 1999 but it is defined differently
under several Notifications and hence the meaning of PIO is contextual
•
The relevant definition of “PIO” for investment in Immovable Property is given
in Regulation 2(c) of the Notification 21 to mean an individual (not being a
citizen of Pakistan or Bangladesh or Sri Lanka or Afghanistan or China or Iran or
Nepal or Bhutan) who – at anytime he has held an Indian passport; or
– he or either of his parents or grand parents was a citizen of India by virtue of
Constitution of India or the Citizenship Act 1955; or
April 27, 2013
6
Definition of PIO- Notification 5 Vs. 21
PIO
Who is
citizen
of
India
Whose
spouse
is a
citizen
of
India
Who held
Indian
Passport
at any
time
Whose father,
grand father,
mother or
grand mother
was citizen of
India
Whose spouse
held Indian
Passport or
whose
spouse’s
parents or
grand parents
were citizen
of India
Scope of PIO defined under Notification – 5 is wide. The scope of PIO is restricted under
Notification – 21 and also excludes citizens of 8 neighboring countries
April 27, 2013
7
Person Resident in India
Defined under Section 2(v) of FEMA :
A person (being an individual) residing in India for more than 182 days during the
course of the preceding financial year but does not include:—
(A) A person who has gone out of India or who stays outside India, in either
case—
(a) for or on taking up employment outside India, or
(b) for carrying on outside India a business or vocation outside India, or
(c) for any other purpose, in such circumstances as would indicate his intention
to stay outside India for an uncertain period;
[RBI Clarification on Residential Status of Students Abroad- Refer AP 45 dated 8.12.2003]
(B) A person who has come to or stays in India, in either case, otherwise than—
(a) for or on taking up employment in India, or
(b) for carrying on in India a business or vocation in India, or
(c) for any other purpose, in such circumstances as would indicate his intention
to stay in India for an uncertain period;
For Acquisition of Immovable Property, RBI considers stay of 182 days in India during preceding
financial year as essential requirement before examination of other conditions under S. 2(v)(B)
April 27, 2013
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Individual leaving India: Conditions
for residence
• Mr. X leaves India on 1st January 2013 for taking up employment
outside India for the first time. What will be his residential status?
Can he acquire agricultural land in India before 30th June, 2013?
-------------------------• Mr. X will be considered a non-resident, w.e.f. 1st January, 2013
irrespective of the fact that he was residing in India for more than
182 days in the preceding financial year 2011-2012 in view of
Exception (A) (a) of the definition.
• Therefore, Mr. X will not be eligible to purchase agricultural land in
India.
April 27, 2013
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Individual coming to India:
Conditions for residence
• Mr. Y, staying in Dubai for past several years came to India on 1st
May 2012 for medical treatment. He has not visited India during F.Y.
2011-2012. He is planning to return to Dubai after medical treatment.
Doctors have advised him to stay in India up to 31st October 2013.
What will be his residential status under FEMA for the financial years
2012- 2013 & 2013-2014?
---------------------------------• Notwithstanding his stay exceeding 182 days in India during the
current year, Mr. Y was not present in India for 183 days or more
during the preceding financial year 2011-2012. Hence he continues to
be a non-resident during the financial year 2012-2013. His situation is
also covered by Exception B(b) of the definition.
• His situation for financial year 2013-2014 is covered by Exception B(b)
of the definition since Mr. Y’s stay in India will be for a specific purpose
and not for uncertain period. Hence he will continue to be a nonresident during the financial year 2013-2014 as well.
April 27, 2013
10
Individual coming to India:
Conditions for residence
• Mr. Mark, a foreign citizen of non-Indian origin comes to India for the
first time and sets up a proprietary concern in India on 1st November
2012 for carrying on business. What will be his residential status for the
financial year 2012-2013?. Can he acquire Immovable property in India
during Financial year 2013-2014?
----------------------• Mr. Mark will be considered resident in India, w.e.f. 1st November, 2012
as he came to India for carrying on business, irrespective of the fact that
he had not at all stayed in India during the preceding financial year 2011 2012. His situation is covered by Exception B(c) of the definition.
• However, since he was not in India for a period of 182 days during the
preceding financial year 2012-2013, he will not be entitled to acquire
immovable property during Financial Year 2013-2014.
April 27, 2013
11
Investment in Real Estate in India (other
than FDI) by NRIs/PIOs/ Branch Offices
April 27, 2013
12
Acquisition through Purchase
• General permission to purchase immovable
property in India by:
– Non-Resident Indian (NRI)
– Person of Indian Origin (PIO)
• General permission covers only purchase of
residential and commercial property
– Not available for purchase of agricultural land /
plantation property / farm house in India.
April 27, 2013
13
Acquisition through Gift
• NRIs and PIOs can freely acquire immovable property by way of gift
either from –
– a person resident in India; or
– an NRI; or
– a PIO.
• However, the property can only be commercial or residential in
nature.
• Agricultural land / plantation property / farm house in India cannot
be acquired by way of gift.
• A foreign national of non-Indian origin resident outside India cannot
acquire any immovable property in India by way of gift.
April 27, 2013
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Acquisition through Inheritance
• NRI / PIO / Foreign national of non-Indian origin can inherit and hold
immovable property in India from a person who was resident in India.
• However, a citizen of Pakistan, Bangladesh, Sri Lanka, Afghanistan, China,
Iran, Nepal and Bhutan should seek prior approval of the Reserve Bank for
inheriting immovable property in India.
• NRI /PIO /Foreign national of non-Indian origin can inherit immovable
property from
(a) a person resident in India
(b) a person resident outside India
However, the person from whom the property is inherited should have
acquired the same in accordance with the foreign exchange law in force or
FEMA regulations, applicable at the time of acquisition of the property.
April 27, 2013
15
Transfer of immovable property by
NRI/ PIO/ Foreign nationals
• NRI can sell property in India to
– a person resident in India; or
– an NRI; or
– a PIO.
• PIO can sell property in India to
– a person resident in India; or
– an NRI; or
– a PIO – with the prior approval of the RBI
• Foreign national of non-Indian origin including a citizen of Pakistan or
Bangladesh or Sri Lanka or Afghanistan or China or Iran or Nepal or Bhutan
can sell property in India with prior approval of the Reserve Bank to
– a person resident in India
– an NRI
– a PIO
April 27, 2013
16
Transfer of immovable property by NRI/
PIO/ Foreign nationals through Gift
• NRI / PIO can gift residential / commercial property to –
– person resident in India or
– an NRI or
– PIO.
A foreign national of non-Indian origin requires the prior approval
of the RBI for gifting the residential / commercial property.
• NRI / PIO can gift an agricultural land / a plantation property / a
farm house in India only to a person resident in India who is a
citizen of India.
A foreign national of non-Indian origin would require the prior
approval of the Reserve Bank to gift an agricultural land / a
plantation property / a farm house in India.
April 27, 2013
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Mode of Payments
• Payment by NRI / PIO for Immovable Property:
(a) funds remitted to India through normal banking channels or
(b) funds held in NRE / FCNR (B) / NRO account maintained in India
No payment can be made either by traveller’s cheque or by foreign
currency notes or by other mode except those specifically mentioned
above.
• Repatriation of application money for booking of flat / payment made to
the builder by NRI/ PIO when the flat or plot is not allotted or the
booking / contract is cancelled
NRIs / PIOs are allowed to credit refund of application/ earnest money/
purchase consideration on account of non-allotment / cancellation of
bookings for purchase of residential/commercial property, together with
interest, if any, net of income tax payable thereon, to NRE/FCNR account if
originally paid out of NRE/FCNR account / Remittance from outside India
provided AD is satisfied about the genuineness of the transaction.
April 27, 2013
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Other Aspects
•
Renting of residential / commercial property purchased out of foreign
exchange / rupee funds
NRI/PIO can rent out the property without the approval of the RBI. The rent
received can be credited to NRO account / NRE account or remitted abroad
based on an appropriate certification by a Chartered Accountant subject to
payment/ provision of applicable taxes.
•
Holding of immovable property bought immovable when a resident after
becoming an NRI/PIO
A person who had bought the residential / commercial property / agricultural
land/ plantation property / farm house in India when he was a resident, can
continue to hold the immovable property without RBI approval even after
becoming an NRI/PIO.
However, agricultural/ plantation activities can not be undertaken.
April 27, 2013
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Acquisition by a Foreign Company
• General permission to purchase immovable property in India
by Branch or Office or other Place of Business (excluding a
liaison Office) approved by RBI under Notification No. 22
which is necessary or incidental to carrying on the approved
activity provided– All applicable laws, rules, regulations or directions for the time being
in force are duly complied with; and
– It files a declaration in the form IPI within ninety days from the date of
such acquisition with RBI.
April 27, 2013
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Investment in Real Estate by NRIs/PIOs (Other
than FDI under Notification No. 21)
Reg
NRIs
Reg
PIOs
Acquire
Agricultural Land,
Plantation, Farm
House
Other Property
Reg
5
3(a)
3(a)
No except Inheritance
from PROI/PRII.
Restriction on use/
repatriation possible
4(c)
Yes
4(a)
4(c)
4(b)
No except Inheritance from
PROI/PRII
Restriction on use/
repatriation possible
Purchase
Inheritance of property acquired
in accordance with FEMA*
Gift from NRIs, PIOs & PRII
Others
Branch
• In accordance with
applicable law
• Remittances from
abroad
5(a)
• Form IPI has to be
filed with RBI within 90
days
Transfer
Agricultural Land
3(b)
Other Property
Repatriation
6(a)
&(b)
Sale or Gift to PRII only
4(e)
Sale & gift to PRII who is Citizen
of India
Gift, Sale or inheritance
to NRIs, PIOs & PRII
4(d)
4(f)
Sale to PRII
Gift to NRIs, PIOs & PRII
Sale to PIO - with prior RBI
approval
Up to Original
Investment in FC and
for Residential
Property- maximum for
2 houses
Balance under US $ 1
Million Scheme
Up to Original Investment in FC
and for Residential Propertymaximum for 2 houses
Balance under US $ 1 Million
Scheme
Diplomatic offices of
Foreign Government
• Remittances from
abroad
• Approval from
Ministry of External
Affairs
Repatriation
• Allowed
April 27, 2013
Including foreign nationals excluding citizens
of 8 neighboring countries – RBI FAQ-10
21
Investment abroad in Immovable
Property by Individuals & Companies
April 27, 2013
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Immovable Property abroad by
Individuals
• An Indian citizen resident in India cannot acquire or transfer immovable
property outside India without RBI approval except
– out of foreign exchange held in Resident Foreign Currency (RFC) account maintained
in accordance with FEMA
– under US $ 200,000 Scheme.
• Payments can be made in installments. However, no loan can be taken.
• Foreign citizens who are Indian residents, are free from any restrictions
regarding immovable property transactions outside India.
• Acquiring property on lease up to 5 years is freely permitted.
• An Indian resident can acquire property:
– as gift or inheritance from Returning Indian. He can not acquire by way of
gift from other persons.
– by purchase out of RFC account funds, or out foreign funds acquired as a
NR.
• An Indian resident can transfer the above property as gift to his relative
who is also an Indian resident.
Relative means - Spouse, brother or sister, lineal ascendant or descendant.
April 27, 2013
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Immovable Property abroad by
Companies
•
Within the limits of remittance for overseas branches, an Indian company can
acquire:
- immovable property for its business.
- residence of its staff.
April 27, 2013
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FDI in Real Estate Development
April 27, 2013
25
Entry Routes & Compliances
FDI in India
Automatic Route
Prior Permission
General rule
• Inform RBI within 30 days of inflow
in Annex (Advance Reporting & KYC)
• Issue shares within 180 days of inward
remittance and file FC-GPR within one
month thereafter
• Pricing: FEMA Regulations
•Unlisted – DCF Valuation except initial
investment through Subscription of A&MA)
•Listed – As per SEBI Guidelines
By exception
•Approval of Foreign
Investment Promotion
Board (FIPB) needed.
•Subsequent procedures
are same as under Automatic
route
• File Annual Return of Foreign Liabilities
& Assets by 31st July every year
April 27, 2013
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Relevant Statutory Regulations
•
Consolidated FDI Policy:
– Latest FDI Policy - DIPP Circular No. 1 dated
April 5, 2013.
•
RBI Notifications / Circulars:
– Notification No. 20 - Schedule 1- Annexure B –
Updated from time to time in accordance with
the FDI Policy of the Government of India
– AP. Dir Circulars issued from time to time
– Master Circular issued in July every year.
April 27, 2013
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General Restrictions
•
Investors who require prior FIPB approval:
– Citizen of Pakistan/Entities incorporated in Pakistan
can invest (excluding defence, space & atomic
energy and other sectors/ activities prohibited for
foreign investment) only with prior FIPB approval
subject to sectoral caps.
– Citizen of Bangladesh/Entities incorporated in
Bangladesh can invest in all the sectors where FDI is
permitted upon prior FIPB approval subject to
sectoral caps.
•
Activities Prohibited:
– Real Estate Business (RBI Master Circular 2012)
•
“real estate business” means dealing in land and
immovable property with a view to earning profit or
earning income therefrom and does not include
development of townships, construction of
residential / commercial premises, roads or bridges,
educational institutions, recreational facilities, city
and regional level infrastructure, townships.
– Construction of Farm Houses
– Trading in Transfer Development Rights (TDRs)
April 27, 2013
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Entities in which FDI can be made
• FDI in an Indian Company:
– General FDI Guidelines - discussed separately
– Certain Relaxations in FDI policy (including Investments by NRIs/PIOs) – discussed
separately
• FDI in Partnership Firm / Proprietary Concern:
– NRIs/ PIOs can invest under automatic route. Others will require prior RBI approval
– The firm or proprietary concern with FDI cannot engage in agricultural/plantation
activities or real estate business or print media sector
– Original investment on repatriation basis is possible only with the prior RBI approval
– Current Income freely repatriable after payment of taxes
• FDI in Limited Liability Partnerships (LLPs):
– Permissible with prior FIPB approval in sectors where 100% FDI is permitted and no
performance related conditions are attached
– Therefore, FDI in LLP in Real Estate Sector is not permissible (Except by NRIs/ PIOs as
they are not affected by performance related conditions).
April 27, 2013
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Entities in which FDI can be made
(Contd..)
• FDI in Venture Capital Fund (VCF):
– Investments subject to General FDI policy.
– If the domestic VCF is set up as a trust, investment requires prior FIPB
approval
– A SEBI registered Foreign Venture Capital Investor (FVCI) can make 100%
investment in • Indian Venture Capital Undertaking (IVCU) and also set up a domestic AMC to manage the
fund.
• Domestic Venture Capital Fund (VCF) registered under the SEBI (Venture Capital Fund)
Regulations, 1996
– SEBI registered FVCIs can invest under the FDI Scheme, as non-resident
entities, subject to FDI Policy and FEMA regulations.
• FDI in Trusts:
– FDI in Trusts other than VCF is not permitted
April 27, 2013
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Types of Projects Included
• Township, Housing & Built-Up Infrastructure and Construction
Development Projects
• To include projects such as Housing, Commercial Premises,
Hotels, Resorts, Hospitals, Educational Institutions, Recreation
Facilities & City and Regional Level Infrastructure.
• Objects
– Generate economic activity
– Create New Employment Opportunities
– Add to the available Housing Stock and Built-up Infrastructure
April 27, 2013
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Mandatory Guidelines
• Minimum Area:
– In case of Development of Serviced Housing Plots- Minimum of
10 Hectares of Land
– In case of Construction-Development Projects- Minimum builtup Area of 50,000 sq. mts
– In case of a combination project, compliance with any one of
these condition would suffice
• Minimum Capitalization:
– For WOS
 US $ 10 million
– For JV with a resident in India
 US $ 5 million
– Funds (USD 10/5 Million as the case may be) should be brought
in within 6 Months of the commencement of the business
April 27, 2013
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•
Project Development/ Repatriation / Exit
Policy
Project Development:
– At least 50% of each of the project must be developed within a period of 5 years
from the date of obtaining statutory clearances
– Investor is not allowed to sell undeveloped plots
• “Undeveloped plots” will mean where roads, water supply, street lighting, drainage,
sewerage, and other conveniences, as applicable under the prescribed regulations,
have not been made available.
• Investor is required to provide stipulated infrastructure and obtain completion
certificate from the concerned local body/service agency before he is allowed to
dispose of these serviced housing plots.
•
Repatriation / Exit Policy:
– Original Investment [entire amount brought in as FDI] can not be repatriated
before a period of 3 years from the date of completion of minimum
capitalization. Earlier exit permitted only with Prior FIPB approval
– The lock-in period will apply from the date of receipt of each installment /
tranche of FDI or from the date of completion of minimum capitalization,
whichever is later
April 27, 2013
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Other Conditions
• The project shall conform to the norms and standards, including land
use requirements and provision of community amenities and common
facilities, as laid down in the local building control regulations, byelaws, rules and regulations .
• It will be the responsibility of the investor & investee company to– Obtain all the approvals (including those of the building/layout plans,
developing internal and peripheral areas and other infrastructure facilities)
– Pay development, external development and other charges
– Comply with all other requirements prescribed under rules/byelaws/regulations of the State Government/ Municipal/Local Body concerned.
• The State Government/ Municipal/ Local Body concerned, which
approves the building / development plans also required to monitor
compliance of these conditions by the developer.
April 27, 2013
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Relaxations in FDI Conditions
• Types of FDI Projects/ Investors entitled for relaxations
–
–
–
–
–
–
FDI in Hotels & Tourism
Hospitals
Special Economic Zones (SEZs),
Education Sector
Old age Homes
Investment by NRIs/ PIOs
• Relaxation in respect of 4 conditions relating to –
–
–
–
Minimum Area
Minimum capitalisation & 6 Months Capitalization Period
50% Project development within 5 years, and
Lock in period on repatriation of initial investment
April 27, 2013
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FDI in Real Estate Development
Certain critical
Issues
April 27, 2013
36
Meaning of Township, Housing, Built up
Infrastructure, Construction – Development Projects
• Townships –
– In Maharashtra- Area specified under Bombay Tenancy and Agricultural Land
Act, 1948
– In Other States – Area Notified under regional town planning acts of the
respective states
•
•
•
•
Housing
Built up Infrastructure &
Construction-Development projects.
Can company give land to a builder under development agreement
where consideration is received in terms of certain constructed
areas?
• Whether FDI guidelines relating to real estate is applicable to
Road, Ports, Bridges, etc?
– Annexure A- Notification No. 20 – Earlier Separate entry No. 12 permits
100 % FDI in Roads and Highways, Ports & Harbors.
April 27, 2013
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Built Up Area
• Meaning?
The Plinth area – Length x Breadth x Floors?
-
Area up to outer wall of the premises?
Carpet area?
• Will it include Balconies, Parking space and Open areas?
• DIPP – Area as certified as salable by local authorities.
April 27, 2013
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Joint Venture/ Project Development
• JV at what level – Company or Project Level?
• Project?
– FIPB view - Greenfield project at the early stage of implementation
• Commencement of business?
– Date of signing of property purchase agreement /Shareholders Agreement
• 50% Project Development?
– Should this mean 50% of the constructed area should be ready with
occupation certificate?
– Depends upon local laws
• All statutory approvals? – Completion certificate/ Occupation Certificate/ Part- occupation certificate?
April 27, 2013
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Minimum Capitalization & Lock-in
• Minimum amount – Face value or total investment (including
share premium)?
• Lock-in starts when?
• Lock-in – will it apply to the entire investment brought in as FDI
or to minimum capitalization amount?
– Entire amount brought in as FDI
– Tranche by trench lock-in – Staggered Lock-in
• Subsequent projects
– Lock in?
– Further investment?
April 27, 2013
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Purchase/ Sale of shares
• Can NR purchase shares from a resident / another nonresident in FDI Compliant project?
• NR to NR transfer- does this amount to repatriation?
– Two main conditions to be fulfilled for exit:
• Lock-in period of 3 years.
• 50% project completion within 5 years of obtaining statutory clearances.
April 27, 2013
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Other issues
• Can a Company receive FDI in when – It has both FDI compliant and FDI non-compliant projects?
– It has FDI compliant real estate project along with other FDI permitted
business?
• Is it necessary to sale premises before exit?
– The condition is “development” and not “sale”.
• Purchase of Agricultural Land for Real estate development?
•
•
Depends upon State Policy
In Maharashtra- Possible if approved under S. 63(1)(a) of Bombay Tenancy and Agricultural
Land Act, 1948
• Construct and lease – is it permitted?
• Can builder offer a minimum return to the non-resident investor?
• Call and Put options?
April 27, 2013
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Investment in Real Estate Development
Projects abroad
April 27, 2013
43
Outbound Investment in Real Estate
Development Projects
• Investment in foreign entities involved in real estate business is
prohibited – Notification No. 120- Regulation 5(2).
– "Real estate business" means buying and selling of real estate or trading in
Transferable Development Rights (TDRs) but does not include development of
townships, construction of residential/commercial premises, roads or bridges Regulation 2(p)
• Investment in foreign entities doing development of townships,
construction of residential/commercial premises, roads or bridges – Individuals under US $ 200,000 Scheme ?
– Others can invest up to 400% of their Net worth
– Mode of Funding • Under Regulation 4 of the Notification No. 120 - from RFC Account or out of funds
held outside India by persons not permanently resident in India
• Drawal of Foreign Exchange permissible under Regulation 6 -Notification No. 120
April 27, 2013
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Outbound Investment in Real Estate
Development Projects
• Drawal of Foreign Exchange
– Total permissible Financial Commitment - Up to 400% the Net Worth of the
Indian Party.
– To include remittances from India, ECB, Capitalization of Exports and 100% of
Guarantees
• Other Conditions
– Foreign entity to carry on bonafide business activities only
– Investor is not on RBI’s Caution List/ investigation by ED.
– Investor submits request in Form ODI to the AD and remits the fund only after
obtaining UIN
– Investor to route all remittances though a designated branch of an AD.
– Investor to file Annual Performance Report (APR)
– Investor to submit Annual Return of Foreign Liabilities and Assets by 31st July
every year
April 27, 2013
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Thank
You
N. G. Thakrar & Co
Chartered Accountants
4, Big Three Building, 1st Floor,
88, Anandilal Poddar Marg,
Mumbai- 400 002
Tel: 2201 8184/ 2207 9094
Mobile: 98210-21841
Email: natwarthakrar@gmail.com
April 27, 2013
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