C.V.O. CA'S · members, expanding our network horizons, bringing real talent hidden within every...

NEWS & VIEWSFOR MEMBERS / SUBSCRIBERS / VOL. 23 - NO. 6 - JANUARY 2020

From President's Desk...Dear Professional Colleagues and Readers,

CA Sanjay Visanji Chheda

Thank you all..... Always in Gratitude

C.V.O. CA'S

Follow us on , , LinkedIn@cvocain Join Yahoo group : [email protected]

After busy days of Audits, hectic seasons of sitting and waiting at Aaykar lobby are over and now that various ministries have been feeling heat of Revenue Collection, that heat will pass on to our clients and equally affecting our members who would be running pillar to post for getting stay on demand.

Yes. Over a period, now its way of life. Yes. It hurts. It pinches clients as well as our professional conscience, but little can be done overnight, but lot can be done gradually. We have been witness to too many officers in various department, who were corrupt or aggressive or were not working within four corners of law have been shown the door. Democracy with the help of Social Media has gained new highs (including new lows, when it comes to spreading of rumours, etc.). Let's see the silver line which these tough times have and work for the betterment of our profession.

Year 2019 is ending and its beginning of new decade. By the time, you will be reading this communication, we all would have entered year 2020. Catchy numbers of years and hope and wish that it has all the thrills of a 20-20 along with fun of a One Day and at the same time patience of a Test Match.

Upcoming Events:

As we have been discussing since end of October for rejuvenating, recreation and all, lets come together at few such CVOCA gatherings, like CVOCA connect with National Park, almost every Sunday, CVOCA Box Cricket on

st rdSaturday, January 25, 2020 and last but not the least, CVOCA Picnic from Friday, 21 February to Sunday, 23 February 2020. Each of these endeavours have multiple objectives including recreation, connect with our own members, expanding our network horizons, bringing real talent hidden within every one of us.

As we had started with dynamic vision of Each One Reach One, hope, wish and desire that we all endeavour and connect with new professional friends, strengthen bonding among our family members and foster better ties within our kids.

Latest issue of CVOCA News & Views

Present issue of “CVOCA News & Views” as per vision and dream of News & View Team was, to make it “Hatke”. I don't know, whether my communication for this “Hatke” Newsletter was “Hatke” or not, but yes, the issue would be.

Present issue revolves around topics ranging from 'Chartered Accountants being virtual CFO' to the Infinite Possibilities in the 'World of Technology - Automation, Digital, Fintech and Chartered Accountants' and it evolves towards "Hatke" with some enlightening articles like 'Trade Opportunities in Africa' and 'Disruption in the Shipping sector'. Also going with our trend, articles on general interests like 'It's all state of mind' and 'Assertiveness' are well presented in the current issue.

Wish you all, wishes of new year 2020 along with this Unique Newsletter themed "Hatke", which is Mouthpiece of CVOCA. Hatke Reading. Happy Reading.

December 31, 2019.

FROM THE DESK OF CHAIRMAN

NEWS BULLETINNEWS BULLETINCOMMITEECOMMITEE

PresidentCA Sanjay Visanji Chheda

Chairman CA Hasmukh Bhavanji Dedhia Convenor CA Parin Dinesh Gala Jt. Convenor CA Umang Lalit Soni Sp. Invitees CA Rakesh Maganlal Vora

Members CA Dharmi Mulchand Kenia CA Hitesh Keshavji Pasad CA Kunjesh Raju Shah CA Nihar Suresh Dharod CA Nisha Ninad Gala CA Priten Bhupendra Shah CA Ankur Kishor Sangoi CA Nainit Digesh Savla

CONTENTSCONTENTS

CA Hasmukh Bhavanji Dedhia

ASSOCIATIONASSOCIATION

C.V.O. CA'S NEWS & VIEWS

Upcoming Events .........................3

Events in Retrospect .....................4

International Trade Opportunities Series North Africa ‐ Djibouti .......5

Shipping Sector ............................7 A Decadal Opportunity

World of Technology ..................11Automation, Digital, FinTech and Chartered Accountants Opportunities: Infinite

Chartered Accountants ...............15As Virtual CFO

It's all a State of Mind!................19

Assertiveness ..............................24

Capitalytic ‐ Put Call Ratio (PCR) ....................27 Brief Update On

SEBI & Corporate Law.................30

FEMA Updates............................32

Direct Taxes Law Update.............34

GST Updates ...............................36

VOL. 23 - NO. 6 - JANUARY 2020

2

National Financial Reporting Authority (NFRA), the new regulator for

financial reporting and audit quality, set up under the provisions of

Companies Act, 2013 (the Act) conducted an Audit Quality Review (AQR) of

statutory audit by Deloitte Haskins & Sells (DHS or audit firm) of IL&FS

Financial Services Limited for F.Y. 2017-18.

The report thereof dated December 12, 2019 gives broad idea about

regulatory expectations from the auditors. The report, first of its kind in

India, makes an interesting reading for those audit professionals who are in

constant pursuance of enhancement of the audit quality and meeting the

expectations of the stakeholders.

Although, the subject matter is too large to cover in brief write-up like this, an

attempt is made to summarise the salient and some far-reaching aspects of

the said report:

The AQR concludes, based on the records/documents reviewed by

NFRA, that audit firm has failed to comply with requirements of the

Standards on Auditing (SAs) and of Standard on Quality Control 1

(SQC).

The major anomalies/lapses noted in the order pertain to (i)

compromising of independence by audit firm by providing of such

services to the client, as alleged to be conflicting (ii) numerous instances

of alleged non-compliance by Engagement Partner and audit team of

requirements of SAs (iii) lack of professional scepticism and adequate

questioning by the audit firm in course of their audit (iv) failure on part

of the audit firm to identify, categorize and minimize the Risk of

Material Misstatement (ROMM) (v) failure to detect incorrect reporting

of Net owned Funds (NOF) and Capital to Risk Assets Ratio(CRAR)

under the guidelines of RBI as applicable to NBFC's.

The report concludes that the audit firm did not have adequate

justification for issuing the audit report asserting that audit was

conducted in accordance with SAs. NFRA advised DHS to revamp its

quality control systems and processes. Though, the decision on

initiation of disciplinary actions, if any, u/s 132(4) of the Act on the audit

firm has been reserved for the time being by NFRA.

Order of NFRA on Audit Quality Review of Statutory audit

in case of IFIN for FY 2017-18


3


In arriving at aforesaid conclusions, NFRA claims to have duly considered the submissions made by the

audit firm; the deliberations in the order pertaining to prohibited services by a statutory auditors u/s 144

of the Act and under Code of Ethics are worth pondering by audit professionals (especially of large and

listed companies and Banks etc), though some of the conclusions are debateable.

The discussion about 'independence in mind' and 'in appearance' assumes high relevance in today's

environment of corporate scams and business failures. The Order appears to have blurred the distinction

between 'management consultancy services' and 'management services.' Further, it lays down that even for

permissible services, prior approval of audit committee or Board of Directors of the auditee company

should have been obtained.

The order questions DHS's policy, practice, documentation etc about role of engagement partner and

about rotation of not only engagement partner after 7 years as mandated by SAs (3 years in case of audit of

systemically important NBFC), but also of the audit team.

Interesting deliberations on communication by auditor to management/TCWG and appropriate

documentation thereof.

Deliberations and conclusion on identification of ROMM and determining consequent audit process

provides some learnings for the audit professionals in pursuance of their quality enhancement.

Even if one may not fully endorse the conclusions arrived at in the order, it makes immensely useful reading

for enhancement in audit quality/documentations. More importantly, it provides insights into the regulatory

thinking.

CA Hasmukh B. Dedhia

Forthcoming Event - Programme Committee

Topic

Direct Taxes Analysis

Impact on Capital Market

Speaker

CA Nitin Maru

CA Nilesh Shah

Union Budget 2020

Date : February 8, 2020

Time : 9:30 A.M. to 1:00 P.M.

Venue : King George, Matunga



Wealth Creation through Mutual Fundth

Date : 20 December 2019Venue : Damodar Hall, ParelNo of Participants ‐ 200Speaker - Mr. Sharad Sharma, CFP (USA) & RIA with SEBI

EVENT IN RETROSPECT - Programme Committee

4

Compiled by:


5

International Trade Opportunities – Series North Africa - Djibouti


CA Viren Manilal Dedhia

As the flight from Dubai descends into Djibouti airspace, it is hard to ignore Djibouti's strategic location and

importance. Located at the horn of Africa, Djibouti is the entry route from the sea for African countries such as

South Sudan and Ethiopia. It lies on a gateway to the Suez Canal, which is one of the world's busiest shipping

routes.

Ethiopia being a land locked country, it's imports and exports account for more than 65% of the Djibouti's port

and container terminal operations.

Djibouti is a welcoming city, with locals generally speaking French, Arabic and Somali with few of them

sparingly speaking English. Accustomed to a large foreign presence, locals often want to socialize and ask

where you are from.

From a business perspective, Djibouti is a young country that presents untapped opportunities. With an

approximate population of one million as of 2019, Djibouti has military bases of many important countries

like USA and France. The US paid $63m annually in rent for its military base and the Chinese bring in $100m

for theirs, in addition to their ongoing infrastructure projects by China.

The Djiboutian lawful environment is favorable to the businesses. You can create your company in Djibouti

whatever your nationality or your place of residence is. The registration of your company in Djibouti can be

done in less than a week. Foreign investor does not need a Djiboutian local partner to start a business in

Djibouti. However they have to prefer employment to the locals. The taxation structure in Djibouti is very

simple and easy. In 2018 Djibouti inaugurated Africa's largest free trade zone. Djibouti free zone provides

various options for warehousing, office set up and land on annual rental or lease along with the licensing and

registration.

1 Djiboutian Franc (DJF) is equivalent of 0.40 Indian rupee (Dec 2019). DJF is pegged to the USD with 1 USD

is equivalent of 177.77 DJF. Djibouti allows free currency transfers and no exchange control. It is politically

stable and strategically located to serve hub for land locked countries. Djibouti is a geographical gateway to a

market of over 400 million inhabitants. Entry Visa on arrival costs 10,000 DJF and is valid for a month.

NATIONAL INVESTMENT PROMOTION AGENCY (NIPA) provides advice and support for new and foreign

promoters in Djibouti. It's neighbor Ethiopia's import is routed from Djibouti's ports. Ethiopia's trade import

include food, cereals, animals, textiles, tools, machinery, transport equipment, vehicles, spare parts and

major raw materials for paper and packaging industries. The top exports of Ethiopia are coffee, oilseeds, gold,

dried legumes and cut flowers. Ethiopia faces a growing trade deficit with total imports steadily increasing on

average by 12.5% per year during the previous 10 years. The Addis Ababa–Djibouti Railway is a new

international railway that serves as the backbone of the Ethiopian National Railway Network and was

inaugurated on January 1, 2018.


6


Djibouti welcomes countries and companies that invest in infrastructure projects, trade, transportation,

education and provide employment to their citizens. The laws of Djibouti are easy to understand and follow.

The average Djiboutian is middle class and crime rate in Djibouti is very low. Djibouti's status as a model of

stability in an otherwise unstable region is its greatest asset. The residents of Djibouti come from countries

like Ethiopia, Yemen, Somalia, US, France, India and China.

Djibouti with a small population and more than 60 percent are of working age. The Université de Djibouti is

the only college level education institution in Djibouti. Along the coast, where the capital is located, it's hot all

year round. In the period that we call winter, from December to February, the temperature is , around 29 °C

during the day. The rains are rare, and the air is humid. Whereas neighboring Ethiopia have spring season and

harvesting in Sep to Nov and winter season in Dec to Feb. From March to May temperatures are on the rise

again. The accommodation in Djibouti can be found with airbnb, booking.com and rentbyowner.com. Its

connectivity by air is easy and accessible from Dubai, Ethiopia, Kenya and Turkey.

The bi-lateral relations between India and Djibouti have existed since the ancient times. The port of Adulis was

the hub of maritime trade where Indian seafarers traded in spices and silk for gold and ivory.

Given the small size of Djibouti, so far there has been no direct Indian investment in Djibouti by Indian

companies, except for Indian owned businessmen from Dubai increasingly investing in the logistics sector of

Djibouti.

Value added tax in Ethiopia is 10%, tax on services is 7% and net profits are subjected to 25% income tax. The

electricity supply in Djibouti is from power generated from Diesel and hence costs more. So overall it has

opportunities in Logistics, Transport, Tourism, Trade, Infra, Power, Financial Services, human resource, IT,

training and education sector. In the next article we will look at how the Indians can benefit from trade between

India and Ethiopia. Exactly a year ago proxy conflicts between Ethiopia and Eritrea that spread over decades

caused by disputed border was ended and peace was established. That opened up trade gateways between

these two countries. Eritrea has reaped many gains from the rapprochement with Ethiopia.


Shipping Sector – A Decadal Opportunity


Compiled by:

CA Jeet Rasik Gala

7

About Shipping

Shipping is a global commodity, presently growing at 2.00%. 83% of the world trade is sea-borne. Global sea-

borne trade has increased 40% in last 10 years, to 11.8bn tonnes in 2018.

The previous bull cycle started from 2003 until 2008 and it was a demand led boom. Shipping sector has been

under water since 2008 bust. I think, 12-year-old bear market has all the signs of cyclical bottoming:

‐ Longest downcycle among any commodity

‐ 70% of the players are bankrupt

‐ 75% of the shipyards are shut and most of them are not coming back

‐ Finance is not readily available

‐ Order book of new ships at decadal low

‐ Scrappage is expected to increase

‐ IMO related disruptions

Size of the Shipping Industry (2018)

Categories Mn Dwt % No. of Vessels

Crude Tankers 396.00 20% 2,044.00

Product Tankers 225.90 11% 12,710.00

Dry Bulk 846.50 43% 11,413.00

LPG / LNG 69.60 3% 2,003.00

Containers 266.40 13% 5,267.00

Others 185.20 9% 62,413.00

Total 1,989.60 100% 95,850.00

What is the disruption?

In the past, disruption has always disturbed the trading pattern, which has led to havoc in supply side

resulting in a massive increase in freight rates. IMO2020 requires to comply with certain carbon emission

norms to reduce emission of Sulphur w.e.f. 01.01.2020. There are only 2 ways of complying to this:

‐ Use Low Sulphur Fuel Oil (higher Opex) (LSFO)

‐ Fit scrubber (higher Capex) and then continue to use present High Sulphur Fuel Oil (HSFO)

Further, all the ships have to get themselves treated for Ballast Water whenever they go for dry docking.



Presently, HSFO consumption is approx. 4mn bpd. To produce LSFO, HSFO may be used which will reduce

the availability of HSFO. Also, I am not sure if appropriate quantities of LSFO can be produced at the

refineries. The present spread between LSFO-HSFO is approx. $30-50 per tonne. Scrubber economics favor

large ships majorly. Further, there is queuing up of ships for fitting scrubber at ship yards. The above options

are like a see-saw: if you give too much weightage to LSFO, the resulting choice might favor scrubber and vice-

versa; because there is simply no clarity what the preferred choice is: fitting a scrubber or using LSFO?

While it looks like a very easy compliance, it is a pure disruption (at a global level).

How to play a Shipping Cycle?

An average age of the ship is around 20 years, but it earns extraordinary returns in only few years of its life.

Average lag in ordering a ship and its delivery is approx. 2.5 years. Please remember, there is NO terminal value

to this business. You may own 50 ships at one point in time, and you may own 5 ships at some other point in

time. Fixed assets are highly fluctuating, and since you do not have a perpetual asset, there is NO terminal

value attached to it. It's a get-on get-off business.

Bookish way to play a shipping cycle is:

‐ During the long down cycle: Cash Management

‐ Buy the Ships right (1 dollar is usually available for 60 cents)

‐ Ride the Ships well (60 cents ship can generate cash flows of about 3-4 dollars)

‐ Sell the Ships right (In euphoria, you will find a buyer for your ships at 1.50 dollar or so)

‐ End of the cycle: Cash Management

Hence, it is not a buy and forget sector. Timing of entry and exit is the most crucial part.

Drivers of Shipping Industry

Demand Drivers

Crude Oil Of the 100mn bpd production, approx. 41% is exported i.e. subject to sea freight. With US

shale oil / gas export of approx. 1.5mn bpd expected to increase to 4mn bpd, the tonne mile

demand is expected to increase dramatically. Further overall oil demand is expected to either

grow minutely or remain constant. Solar replacing oil is still distant.

Oi l Products

(Refined)

Approx. 24mn bpd of refined oil products are subject to sea freight. This number is expected

to increase post 01.01.2020 once demand for LSFO/HSFO increases. The product tankers,

along with crude tankers, are expected to see big benefits as tonne mile demand is expected

to increase because the same amount of fuel will be subject to more tonne miles.

Iron Ore & Coal One of the key reasons for movement of Iron Ore and Coal is because of capacities of Steel

plants, majorly in China, Japan and Korea. They don't have Iron Ore and Coal, but they

make steel. Iron Ore movement constitutes approx. 28% of tonnage in Dry Bulk segment,

while coking coal is 5% & steam coal (power plants) constitutes around 20%.

Major Iron Ore and Coal movement is from Brazil and Australia. I do not foresee substitution

of Steel capacities from say China to Brazil / Australia.

Grain & Minor

Bulk

This segment constitutes about 48% of dry bulk segment and majorly includes: forest

products, steel products, wheat, soybean, fertilizers, grains, and others.

With US-China trade war, the trade continues to happen via-different countries effectively

increase tonne mile demand. I believe this segment will NOT decline.

Gas & Chemicals It is only 3% of the total shipping capacity; however, the demand for LNG / LPG as alternate

fuel is increasing across the world. This segment grew at 8% in last 6 years, and in my view

this segment will continue to give firm growth at minimum 4%.

Containers This segment grew at 5% in last decade and again my view is that containers will continue to

grow at 3%.

8



The above chart shows break up of “ships in water” by their date of birth i.e. approx. 9% of the ships in water

today are born in 2011, and so on.

Scrappage Scrappage means ships getting scrapped. In scrap, usually you get 15% of

your original cost. The decision to scrap comes from negative operating cash

flows (during a down cycle), no support from balance sheet, and no strategy

to tide out the bear phase to be alive in the bull phase. Also, higher steel

scrap prices also drive the decision to scrap the older ships.

Presently, scrappage is around 2% of fleet capacity, and has dropped in last 6

months mainly in anticipation of IMO effect because everyone believes the

freight rates are going up. A 6-month delay in rates going up, will lead to

increased scrapping.

Also, as per the chart above, pre-2000 born ships are approx. 10% of the

total present capacity which is expected to be scrapped gradually owing to

higher regulation costs of complying to IMO.

Order Book Order book of 8% is at decadal low reason being the carbon emission norms.

Since the life of a ship is around 20 years, a new ship ordered today will have

to go through tough emission standards and may become completely

redundant going forward, if a particular technology is banned or some new

technology comes up.

Deliveries are happening at the rate of 3.50% of present fleet capacity i.e.

approx. 75mn dwt.

Steaming Speed Slow steaming help to increase profitability by increasing the number of

days but effectively reducing the fuel costs. At present dull freight rates and

with IMO costs coming in, ships will resort to slow steaming i.e. average

speed of the ship will be reduced from 14 knots to 12 knots which will

effectively tighten supply to the tune of 7.50%-10% of the present fleet.

9

Source: Clarksons Research Report

Supply Drivers



Shipyards Shipyards are down from 950 (in 2008) to 320 (in 2019). Of these 320

shipyards, 125 shipyards don't have order in hand of more than 1 ship.

Shipyards are finding it very difficult to survive and most of the mothballed

capacity is not going to come back easily.

Shipyards will also be faced with technological barriers, since they will have

to deliver new ships with advanced fuel and emission standards, for which

capability and delivery issues can come up.

Compliance IMO2020 and farther carbon emission norms 2030 is going to keep the new

ships under control and will make older ships scrap. IMO2020 is a big

disruption and unknowingly 2030 norms will be a bigger disruption. Hence

to my view, the upcycle this time will be longer and sustainable.

Finance Most of the European & US banks which financed this sector have suffered

big NPAs. However, this time, a lot of Asian banks are financing the shipping

companies. Financing has become very dry and capital is not easily available

to this sector. Number of deals happening today has more than halved than

what it was in 2008 (comparing absolute numbers of 2008 with today on

today's size of industry). Thus, low financing will also restrict addition of

new ships.

Off-Hire time Scrubber fitment take around 2-3 months; using of LSFO also requires

cleaning to fuel tanks which take around similar time. Due to scarcity of

shipyards / dry docks, this procedure will also contribute in tightening of

supply.

Number of ships in water is the math I want running in your mind i.e.

Net addition of ships = new born ships – dead ships

Demand-Supply Imbalance Impact

For any cycle to turn, you always need a trigger. I believe IMO2020 is going to be the trigger for the next upcycle.

In the table above, I firmly believe that the demand is not going to decline, if not grow. My entire thesis lies on

substantial supply tightness.

Even a 1% imbalance in demand supply is needed for good swing in freight rates. A recent news on US banning

COSCO ships, which is approx. 3% of VLCC markets, created such an upswing that the freight rates went up to

5 times. Each of the individual supply drivers can create tightness in supply, and then it is up to you to

calculate how explosive the upside can be.

Conclusion

All bull markets in cyclical sectors start with long periods of investor losses, disgust with the sector and lack of

capital for companies to add new supply. The 12-year bear market has all pre-requisites of a gigantic bull

market. Remember, shipping has tremendous Operating leverage on a substantial Financial leverage.

Shipping is the most under-followed, most hated, most boring, no fun sector. If you are not following it,

you are probably missing the trade of the decade. So, please do your homework :)

10


Compiled by:


CA Rajiv Gangji Gada

11

Traditionally and to a major extent Chartered Accountants [CA's] are focused on professional opportunities in

Audit, Finance, Accounting, Tax [Direct / Indirect] and consulting. Also within consulting opportunities their

core value add is related to above areas of strength. Last couple of decades have seen increased percentage of

our fellow CA's move to Industry, capitalizing on their core strengths in related functions.

Changing landscape and increased use of technology everywhere has motivated and forced us to adopt tech

in every aspect of work and life. Today every business demands speed, accuracy, quick time to market,

differentiation from competition and connectivity with the world [Global Market place] and this is not possible

without adoption of technology. Hence being Tech Savvy from business view point is not a choice but necessity.

In last couple of decades CA's have also been moving to technology related careers like:

Implementation, Development, Testing (Quality Assurance - QA) and Support in below areas:

Enterprise solutions in Manufacturing / BFSI like SAP, Oracle Financials, NetSuite, etc. In house for a

business entity or with System Implementer [ Software companies ]

Industry specific licensed software solutions like Finacle, Flexcube [ Banking ] , Credence , Kastle,

Murex, Calypso, etc.[ Treasury and Capital Markets – Multi Asset ] , ODIN, Omnesys [Share Trading

Software ], MFund, MoneyWare [ Asset Management ], etc.

Custom Software development incl. solutions for Risk management, regulatory compliance, reporting,

dashboard, etc.

Aspects and Strengths of CA's which have enabled this logical transition of their careers are:

Sound Base Knowledge of Finance, Accounting, Audit, Tax [Direct / Indirect], Treasury Operations

Exposure to Multiple industries – Banking, Manufacturing, Capital Markets, IT, etc. and business

processes within each industry

Regulatory and compliance Knowledge – Local [RBI, FEMA, SEBI, FIMMDA, etc.], Global [SEC,

GDPR, Dodd Frank Act, MiFID II, EMIR, PSD2, etc.]

These above areas today also represent a huge opportunity for CA's to venture into these aspects of technology

and make successful global careers.

However the pace of change of technology is electrifying. We all have experienced Digital, Omni Channel and

newer buzz words like Automation, Blockchain, Artificial Intelligence [AI] / Machine Learning [ML], Natural

Language Processing [NLP], FinTech, etc. keep on haunting us. These newer aspects of technology represent

tectonic shift and also present an enormous opportunity for CA's, which is elaborated in detail in below

sections:

World of Technology – Automation, Digital, FinTech and Chartered Accountants Opportunities: Infinite



12

Automation – Robotic Process Automation [RPA]

I am sure everyone has heard of RPA, BOT's, etc. but what does that mean. In simple terms in the world of

Data / Process Automation, RPA is a standardized short form used to explain a creation of BOT i.e. Automation

Robot – with the help of technology and software that helps in automating certain business process so that

data / tasks can be carried out automatically on software's without human intervention. To explain in lucid

language, these bots work on the GUI / display layer of software and process data seamlessly as if any Human

being would do. Only exceptions are alerted for review and human intervention. The advancement of

Technology and availability of software's that enable easy of creation of BOTS are available today. Few

Examples of companies that have licensed software's that enable RPA are Automation Anywhere, Blue Prism,

UI Path, etc.

Advancement in this technology to have intelligence [Which these days is termed as AI – Artificial Intelligence]

built into these software's for prudent and multiple decision making is increasing and error handling

capability have increased the adoption and adaptability of these software's.

Today anything that a human being can do / process on software's can practically be attempted by creating

BOTS for a particular function.

So are we right in assuming that everything we do today will be taken over by BOTS. Not exactly, since in any

Business decision, creation of BOTS for handling a particular function is a software build activity with the use

of licensed software products and involves time and effort. Hence maximum advantage or ROI for this can be

realized by creating BOTS for processes which are repetitive and voluminous. In addition speed, accuracy, no

human error, 24 x 7 availability and scalability are other advantages.

Some example in the financial world where RPA is implemented are:

Invoice Processing – Accounts Payable – Accounting / Finance Function

Customer On boarding / Know your client – KYC - Banking

Loan Application Processing – Lending Function – Banking / NBFC

Trade Processing / Trade Reconciliation – Capital Markets

Policy Issuance / Claims Processing – Insurance

Trade Finance - Banking

Logical steps in implementing RPA and those steps marked with $$ are where CA's can immediately get

involved and @@ are those where based on CA's interest, can learn the RPA Tools - BOTS creation and venture

into entire chain of RPA

Based on cost benefit analysis and ROI, determine the processes that need to be Automated $$

Create an as is scenario / current state - Documentation of this process $$

Standardize the process and steps which can handle this function covering various permutation

combinations and freeze before implementing RPA $$

Conduct a Proof of Concept [PoC] with Multiple RPA product vendor to find out which product is best

suited with your processes and software. @@

Implement RPA – Create BOTS @@

Run Business as usual $$

Blockchain – Distributed Ledger Technology [DLT]

As soon as you hear of Blockchain, people start thinking of Bitcoin – Cryptocurrency and relate to it. But that is

not true, since the underlying technology or backbone of Bitcoin or any Cryptocurrency is Blockchain or

Distributed Ledger Technology [DLT]. Blockchain loosely is also interchangeably terms as Distributed Ledger

Technology [DLT]. However in strict parlance every Blockchain is DLT but all DLT are not Blockchain.

Blockchain is a distributed database to record transaction / data, which is spread across different computers

on a network. The data is stored in blocks and all blocks are connected to each other using a unique

cryptographic sign called # Hash, thereby creating a chain. Technically there are Permissioned Blockchain

where users have specific permission w.r.t. to actions and access to specific set of data and Permissionless

Blockchain which operate publicly available applications.

Some advantages of Blockchain technology which has made this popular:

Single records of truth – Centralized single database, thereby eliminating maintain multiple data sets

and hence No errors / discrepancy across entities.

Immutability – The records cannot be altered/ changed / tampered – Since everyone is connected in a

chain via Hash and hence requires multiple level of authorization for alterations.

Substantial advancement in Blockchain Technology in last couple of years has attracted higher focus and

attention from industry participants to experiment this and have operational use case:

Higher Performance – Transactions at greater of 10000 tps

Enhanced Security

Interoperability – Industry collaborations leading to greater success of PoC

Permissioned Blockchain

Investments by VC's in Blockchain and related Start Up's in 2018 has been substantial.

Regulatory approval and recognition by Multiple countries

Establishment of Regulatory Sandbox

Today due to the above highlighted aspects, Blockchain use cases are being experimented across industries

like Banking, Financial Services, Capital markets, Logistics, Real Estate – Land Records, etc. Just to highlight

a few cases concentrated on Capital Markets can be:

Trading [Real Time Trades and Settlement – Tokens, Coins, etc.]

Settlement [Smart contracts, Post Trade, etc.]

Issuance of Securities [Multi Asset Issuance – Bonds, SME Private Companies, etc.]

E Voting – RTA [ Corporate Actions ]

E Kyc

Smart Contracts - OTC Derivatives Contracts

Custody – Digital Assets / Token

Payments

How can CA's participate in this revolutionary technology:

Identification of use cases with their areas of operation where Blockchain DLT can be used

Business Requirement Specification [BRS] Preparation for Use Cases

Close collaboratio with Development team during development phase for domain orientation and

clarifications



13



14

Functional / User acceptance testing of developed application

Business as Usual – Run in live environment post development

Data Science – Business Use of Big Data – Artificial Intelligence and Machine Learning

Data science is the practice of extracting meaning insights and knowledge from multiple data sets Structured

and unstructured - Using scientific algorithms, processes and systems. Today importance of data is like Oil,

for coming decades. Competition and corporate battles will be won based on collection, availability and

interpretation of Data and its optimal use.

This field uses the latest concepts of Artificial intelligence along with machine learning to extract

information which is helpful in making various business decisions. This science has advanced to make

predictive analysis in regard to human behavior patterns, decision making, sentiment analysis, etc.

To give you a an example, these days there are custom applications developed in advanced economies which

listen to listed companies management calls and discussion and based on their various aspects of confidence,

promptness, clarity of response, detailed data shared, etc. give different predictions about the company's

future.

It will be hugely advantageous for young CA's to develop a data lead decision making mindset and while they

definitely need to know Excel Macros, its use, etc., but also short courses done in Python and R language will

provide additional advantage in Data Analysis.

In Capital Markets, algorithmic trading / High Frequency trading is an excellent example of Artificial

intelligence and Machine learning.

CA's will be called in every aspect of their work to get involved with teams to suggest what are criteria to extract

relevant data sets for determining a particular outcome / decision.

FinTech – Startup – Entrepreneurship

CA's interact with a wide variety of audience during their professional life and are banked for providing advice /

solutions for many aspects where software's fail.

Hence FinTech can be an entrepreneur opportunity. The key is to identify a gap in the current offerings

available in the market and design a solution to cater it.

Today you would have heard of multiple startup disrupting many established businesses and models and

some of the areas of focus for FinTech are:

Payments – Flip given by NPCI post release of UPI 2

Wealth - Robo Advisors - Auto Portfolio Construction based on Risk Profile

Lending – Micro Loans - Finance / SME finance / P2P lending

Regulatory - Reporting

Aggregator Model – Market Place for BFSI products

While it is undisputed that importance of CA's and its core domain of Audit, Tax and Accounting are the

immediate opportunities.

But changing times call for an open mindset to embrace the digital and data mindset, within its own areas and

also opens up plethora of opportunities to contribute to this sunrise industry either as consumer, service

provider, applications owners and entrepreneur and embark on this journey into the world of infinity.


Compiled by:


CHARTERED ACCOUNTANTS

AS VIRTUAL CFO: CA Dharmi Mulchand Kenia

15

Introduction:

The new economy keeps throwing new challenges viz., crypto currency revolution, documentations moving to

smart contracts and block chain, artificial intelligence, changes in taxation laws viz., introduction of GST, etc.

With this challenges, all the small and mid sized firms have to update and innovate themselves to maintain a

foothold in the changing environment. Also, there is a huge competition in industry due to increased number

of service providers that too at a minimum possible amount. Further there is increase in the number of

consultants and graduates providing compliance and accounts maintenance services which are been hired by

the companies instead of paying premium to prices to CA's which they otherwise used to do. This forces CA's to

innovate and specialise themselves rather than just doing plain vanilla and compliance work. Lets not be just a

number cruncher or a taxman. Lets take a step and move inside a Company's Board room for management

level discussion and be a part of Company's decision making process.

With the increase in number of changes in government policies, rules and regulations, changes in economy,

there is an increased requirement of some strong financial expert in the decision making process. This role

can very well be performed by a Chartered Accountant who is already a well versed finance professional can

designated as a “Virtual CFO” of a Company.

What is Virtual CFO?

Virtual CFO services have been around for some years, but the awareness of their benefits is now on rise with

changes in economy and with cloud technology opening up. In the modern world, Startups, SMEs and small

Corporates don't need a full time CFO to help them manage their business. Also, SMEs don't often have access

to the luxury of full time, well-rounded CFOs that larger entities do. As routine tasks become automated, skills

and tasks that can't be done by machines increase in Value. Virtual CFO provider delivers a level of service that

helps the client focus on successful business models, strategies and managing performance through

accountability and self-awareness. Virtual CFO shall be responsible for managing a business's finance,

accounts, compliances, corporate governance, reporting and also the strategic requirements and many more

such functions. �

Why a Virtual CFO?

Virtual CFO is a service that is provided to businesses who have not appointed an in house CFO. In the present

scenario many challenges are being faced by the organizations in terms of growth, financial aspects,

accounting as well as management. For this an officer is required who can be primarily responsible for

managing the financial risks, financial reporting, record keeping as a higher management of the Company. It is

a true fact that a CFO being one of the recognized management authority is sometimes out of budget for small

enterprises, startups and SMEs.



16

A start-up business is basically starting from scratch, so they may need a business plan and financial forecasts

and then ongoing monitoring of those forecasts.”

Therefore there is a requirement to facilitate the need to have a professional very well termed as a Virtual

CFO

How is Virtual CFO is Different from Full time CFO:

Full Time CFO Virtual CFO

Designation

On Company’s Pay roll Not on Company’s Pay roll, not a full timeservice provider

Economical

Since on Company’s Payroll, huge salary cost to Company

As compared to Full time CFO, it is more economical but equally efficient.

Flexibility

Lesser flexibility since it’s an employee of the company,

It offers flexibility according to your business requirements

Exposure to Various Industries

In house CFO, being employee of the Company has in depth knowledge its own employee company only.

Experience of working with multifarious organizations in various industries. Therefore, they are able to handle complicated financial challenges more efficiently.

Team effort in problem solving

Individual CFO being an employee brings in individual experience towards problem solving of Company

A Virtual CFO brings knowledge of a professional team. A team thus can provide myriad of solutions for a single problem

Problem Based Solutions

The in house CFO is more involved in day to day finance activities & other functions

A team of V irtual CFO will weigh upon focusing on the core areas and main problem areas which gives him edge over the convention CFO

Business Networking

An in house CFO may not always be having stong network of invest ors & experts since he being an employee of company is not that exposed to outside company networks.

The outsourced virtual CFO services have strong networks of key investors and experts in the industry which enables you to make an informed decision.



17

Services which a Virtual CFO can provide:

1. One stop shop offering end to end finance, business consultancy and management services.

2. Financial Planning and Cash Flow forecasting.

3. Cost Management, cost effectiveness and assistance in deploying cash efficiently for greater production

or expansion.

4. Debt reduction through proper funds managements services.

5. Provide customised solutions to all the financial and business issues. It all depends on how many

contact points the client wants. If they need phone calls every week and an actual face-to-face once a

month, it's not necessarily always virtual. “It's all tailored to each individual client, what stage of

business they're at, and what they actually need in the business at that time.

6. Advice Resources planning and allocation.

7. Interpretation of financial results on a regular basis & advising management for corrective actions

wherever required instead of waiting till the year end.

8. Fundraising. Virtual CFOs may create the financial story and can do some light pitching.

9. Manage finance-related IT system.

10. Participate in board meetings. Virtual CFOs may prep and coach the CEO and can be requested for a

presence in meetings.

11. Mergers and acquisitions decision making by advisory and thorough analysis.

12. A CFO can be a much-needed sounding board, coach, or guide. A seasoned veteran who you can be

trusted for finance and management level decisions.

What a Virtual CFO should avoid:

1. Shouldering legal burden of all things which a company faces.

2. Managing HR/payroll/Admin (benefits, insurance, hiring/firing of non-finance staff).

3. Daily, in-person participation with executive management team.

4. Entering in to the routine accounts and finance work of the client since this may not serve the purpose of

CFO.

How the Service benefits to the Profession:

1. Being in Practise, a Chartered Accountant can play the role as a CFO and get the honour & respect from

Management.



18

2. A new vertical of Practise from a traditional Compliance work which opens up even more avenues of

earning.

3. A new learning opportunities to the team of Chartered accountants which may not be obtained through

tax and compliance work.

4. Increase in earning capacity and knowledge of firms by giving various level of services.

5. Building of Client Loyalty and often client referrals because you are so valuable to the businesses.

6. Much of the value provided by a virtual CFO comes from the fact that they're virtual – i.e., there's a healthy

degree of separation.

Some point of Cautions:

1. For entering in to this area of service, one should have a proper team of people inclined to learn new

areas of company.

2. One should set proper outcome and deliverable which will be a parameter for work done and raising of

invoices based on the deliverable.

3. A properly written engagement letter which will clearly define a scope of work in detail, frequency of

services to be rendered, deliverables, invoicing and reporting mechanism.

4. It should be kept in mind that it should not be mixed with internal audit services or compliance services

which is also delivered to the same client else the very purpose of being a CFO will be defeated.

Accordingly, one should also divide its team properly which should be distinct & not the same for audit,

compliance & CFO services.

Keeping all this in view, a Virtual CFO can take utmost benefit of upcoming Cloud technology to give best value

to their clients and also benefit itself from the new area of practise.


Compiled by:

CA Henik Dilip Shah

It's all a State of Mind!


19

Think big and your deeds will growThink small and you'll fall behindThink that you can and you will

It's all a state of mind!-Walter D. Whintle

1. Poverty is a state of mind.

[1]A research conducted by Priya Fielding-Singh, a doctoral candidate in sociology at Stanford University,

suggested that families' socio-economic status affected not just their access to healthy food, but

something even more fundamental- the meaning of food.

She interviewed 73 Californian families, i.e. more than 150 parents and kids, and spent more than 100

hours observing their daily dietary habits.

Most of the parents that she interviewed, whether poor or affluent, wanted their kids to eat nutritious food

and believed in the importance of a healthy diet.

But parents were also constantly bombarded with requests for junk food from their kids. Across

households, children asked for foods high in sugar, salt and fat. They wanted to eat Cheetos and not

vegetables. While both wealthy and poor kids asked for junk food, the parents responded differently to

these pleas.

An overwhelming majority of the wealthy parents told her that they routinely said “no” to requests for

junk food. In 96% of high-income families, at least one parent reported that they regularly decline such

requests.

Parents from poor families, however, almost always said “yes” to junk food. Only 13% of low-income

families had a parent that reported regularly declining their kids' junk food requests.

One significant reason for this disparity, as she observed, was that kids' food requests meant drastically

different things to the parents.

For parents raising their kids in poverty, having to say “no” was a part of daily life. Their financial

circumstances forced them to deny their children's requests, like a new pair of branded shoes or a trip to

amusement parks, all the time. This wasn't tough for the kids alone; it also left the poor parents feeling

guilty and inadequate. So junk food was something they could often say “yes” to. Honouring requests for

junk food allowed poor parents to show their children that they loved them, heard them and could meet

their needs. Junk food purchases not only brought smiles to kids' faces, but also gave parents something

equally vital- a sense of worth and competence as parents in an environment where those feelings were

constantly jeopardized.

To wealthy parents, kids' food requests meant something entirely different. Raising their kids in affluent

environment, wealthy parents were regularly able to meet most of their children's material needs and

wants. Wealthy parents could almost always say “yes,” whether it was to the latest gadget or an expensive

education course. With an abundance of opportunities to honour their kids' desires, high-income parents



20

could more readily digest saying “no” to requests for junk food. Doing so wasn't always easy, but it also

wasn't nearly as distressing for wealthy parents as for the poor ones. These parents also saw withholding

junk food as an act of responsible parenting.

Both wealthy and poor parents used food to care for their children. But the different meanings they

attached to food shaped how they pursued this goal.

Wealthy parents who denied their kids processed foods did so to teach them healthy lifelong habits, such

as portion control, as well as more general values, such as willpower.

Poor parents honoured their kids' junk food requests to nourish them emotionally, which in turn may

harm their health.

Kids have the same behaviour worldwide, so what research is done in the USA is relevant for India.

Brands like Coca-Cola and McDonalds are already making huge sums because of this behaviour, as [2]highlighted in my article “Perception and Influence” published in the October 2019 edition. However, a

more noteworthy mention is this specific advertisement of Maggi noodles- showing a poor family's son,

who didn't get good marks. But because he conveys this truth to his mother, she rewards him by [3]preparing Maggi and they share an emotional moment together.

What is interesting here, is that since poor parents have repeatedly symbolised cheap junk food with

rewards and happiness, their kids, when grown up, will continue to believe in this symbolism. Now when

time comes to expand their horizons and work hard to achieve something significant, they might simply

lack the willpower to do so, (unlike kids from affluent families) and go back to find happiness in junk,

which they have been habituated.

It is not only restricted to food, but also covers other basic necessities, i.e. clothing and shelter. Coupled

with other factors, this habit affects the various choices made in life. As they observe the outside world,

the life of the affluent, they notice one thing- Inequality of incomes.

2. Inequality is a state of mind.

As per World Inequality Report, in 2016, Top 10% of India's rich held 55% share of national income. This [4]share was around 30-35% in the year 1980, and has only risen on an average. The same has happened

almost everywhere in the world, as per the chart below:



21

The NSSO report, released in May 2019, had shown India's joblessness across all ages to be at a 45 year

high to 6.1% in 2017-18. The unemployment rate among the rural male youth (persons of age 15-29

years) was 17.4% while the unemployment rate among the rural female youth was 13.6% during 2017-18.

The unemployment rate among the urban male youth was 18.7% while the unemployment rate for urban

female youth was 27.2%.

For educated (highest level of education secondary and above) rural males and rural females of age 15

years and above, unemployment rates were 10.5% and 17.3% respectively. The same for urban educated [5]was 9.2% for males and 19.8% for females.

Further, Indian banks have also seen a rise in education loan defaults, from 7.3% as on March 2016, to [6]9% in March 2018.

Apart from unemployment, there is a serious under-employment. Every now and then you will find news

of professionals applying for posts where the minimum education criteria would be matriculation. The

latest one came from Bihar where around 5 lakh youth including MBAs, engineers, and post graduates [7]applied to become gardeners and watchmen.

Further, let's also understand the impact social media has, especially on youth. While youth starts to

spend more and more time on such media, it gets more and more disconnected from reality, and starts

experiencing an increasing level of stress due to self-validation points, i.e. likes and comments. The more

one is active on social media, the more one stays relevant or trendy in one's circles.

To get more likes and comments, one has to post a better picture, preferably with branded clothing of

latest trend. Going to fancy restaurants, flaunting expensive stuff also helps. But all this requires one to

spend more, probably more than what one earns. Buying on credit, paying in instalments has also

become a norm.

However, going a step further, MobiKwik, a mobile wallet and payment gateway service provider,

introduced the concept of “Boost loan”, wherein the user of MobiKwik app can avail an instant loan of [8]upto Rs 1,00,000, with minimal documentation. Further advertisements of this loan scheme are done

by 'Tik Tok' stars (Tik Tok is a social media platform for creating short videos, often recreating a song or a [9]movie dialogue.). 41% of Tik Tok's users are aged between 16 and 24 years.



22

(A screenshot from Tik Tok star

Bhavika Motwani's video posted on her Instagram account. She has around 19 lakh

Tik Tok followers. & 4 lakh Instagram followers.)

(This is a screenshot from the Boost loan webpage of MobiKwik's website. Take special note of the things shown on

which one can spend this loan money.)

Advertisements of getting into debt being done on a target clientele who probably has just started

understanding how the world works.

The choice of rewarding and finding happiness in junk food, in cheap stakes, in buying something only to

flaunt and getting into debt for these choices, will only aggravate the person's bad finances. A 2016 Forbes

article, highlighting USA's bad finances problem, stated “If a person owns $10 only and has no debt, then [10]he/she is richer than 15% of American households.”

When such people observe their neighbourhood, the life of the affluent, after absorbing the inequality,

they feel that some sort of injustice has been done to them. Although it cannot be denied that the powerful

may keep a section of society deprived of opportunities and knowledge, but people don't realise that

majority of times it is the choices which they make, that start defining them and deciding their future.

Injustice is being done by them, on themselves.

3. Injustice is a state of mind.

In his book “The White Tiger”, Arvind Adiga had very aptly portrayed the state of injustice. He noted that

even though people are given an opportunity to really excel in life, really break the shackles of poverty and

injustice, and be on the other side of the road, majority will simply not accept, for fear of the unknown. He

further states that such people, instead of thinking hard on their current situations, will prefer escaping

from reality, by watching television.

Television (and any media as a matter of fact) can mould its viewers' opinions to great extent. While this

article is being written, there are protests happening all over the country over the Citizenship

(Amendment) Act. Whether the protests are done for a right cause or not is a different issue, but the

intensity with which these protests are being held, does concern me. What people should be really be

thinking on, is increasing prices of key food items like onions and daal, employment woes and the current

state of Indian economy, and preferably engage in a dialogue with their elected representatives. Instead,

they are busy showing their patriotism, secularism or religious hatred.



23

Politicians make the most out of it, by diverting attention from really important issues to not so important

issues.

A United Nations report has found that wealthy communities will be able to buy their way out of the

unfolding climate crisis while the poorest will suffer most. An example was cited of the 2012 hurricane

Sandy. “Vulnerable New Yorkers were stranded without power, but the Goldman Sachs headquarters was [11]lit by power from its own generators.” All those who chose to buy a power backup or a generator were

obviously protected like Goldman Sachs. Everything boils down to choice.

Point to Ponder:Our lives are defined by the choices we make. These choices depend on our thoughts. If we don't think big,

someone else will, and will make us fall behind. Ultimately, isn't it all a state of mind?

Think over it. Think different!

References:

1. https://www.latimes.com/opinion/op‐ed/la‐oe‐singh‐food‐deserts‐nutritional‐disparities‐20180207‐\

story.html

2. http://www.cvoca.org/web4/news_views/oct‐2019/full‐issue.pdf

3. https://www.youtube.com/watch?v=X24xeOdLHqc

4. https://wir2018.wid.world/files/download/wir2018‐full‐report‐english.pdf

5. http://www.mospi.gov.in/sites/default/files/publication_reports/Annual%20Report%2C%20PLFS%202017‐

18_31052019.pdf

6. https://www.businessinsider.in/study‐abroad‐education‐loans‐in‐india‐see‐rise‐in‐

defaults/articleshow/68095265.cms

7. https://www.indiatoday.in/mail‐today/story/5‐lakh‐including‐mba‐engineers‐post‐graduates‐apply‐to

become‐gardener‐and‐watchman‐in‐bihar‐1623159‐2019‐11‐28

8. https://www.mobikwik.com/loans

9. https://www.oberlo.in/blog/tiktok‐statistics

10. https://www.forbes.com/sites/timworstall/2016/08/02/if‐you‐have‐10‐and‐no‐debt‐you‐are‐richer‐

than‐15‐of‐american‐households‐put‐together/#654a1c22989e

11. https://www.independent.co.uk/environment/climate‐change‐crisis‐rich‐poor‐wealth‐apartheid‐

environment‐un‐report‐a8974231.html?fbclid=IwAR0igaZhQQcBD9EMBfy9IhOwfeQd7hhvmd ZPNOdLmp

CT4oc4gj5bfloLy0


Compiled by:

CA Nisha Ninad Gala

Assertiveness

24


# Have you come across situations where you :-

Are unable to say NO

Have a suggestion but don't want to speak up in the group

Share a view different from the rest of the group and feel pulled down

Accept other people's viewpoints just to please them

Find yourself in a self doubting situation most of the times

Want to have things your way and get annoyed if they don't

Find others thinking you are dominating

Aspiring to be a winner and lead at all times

Do not tend to bother about the others point of view or feelings

Think you are always right

These are examples of either passive behaviour or aggressive behaviour.

Passive behaviour is a characteristic of people who seek to avoid conflict or criticism. These people

most likely allow others to make choices or take decisions for them. Aggressive behaviour is opposite of

passive behaviour.

Aggressive behaviour is shown through a loud voice and /or actions, demanding tone, dominating

roles assumed. People with such characteristic need to have control with themselves, ensure that their own

wishes and demands are fulfilled, even at the cost of others discomfort. These behaviours may work in some

situations, but are not desirable for a long term and overall for the group or team and even for the individual

personally.

Extreme passive or aggressive behaviours are often the triggers or possible reasons why there are

situations where

Tasks do not get done as desired or in the time frame required.

barriers in communication lead to rifts

meetings are ineffective because participants do not speak up

there are team disputes and environment of discontent

there is a lack of ownership and responsibility in the organisation

the performance levels are low

there is a lack of motivation ……and so on


25


Assertiveness is a positive

quality that strikes a perfect

balance between passive

behaviour and aggressive

behaviour.

Being Assertive means feeling good about yourself and looking after your own interests as well as those

of others

It is about a direction that you are taking rather than being at someone else's beck and call.

It is also about being more self confident , standing up for your own point of view , valuing your own

judgement

Being assertive does not mean being aggressive , nor does it mean bottling u

Assertive people tend to be

Less stressed

More confident 'Good at dealing with others

Better members of a team

� � � � � People with assertiveness skills can

Present their view more confidently and have their voices heard

Deal more effectively and aggressive people

Get things done their way and earn greater respect

Know how to tell people bad things about themselves

Know how to criticise constructively

Be more relaxed and have more energy

Here are some everyday situations. Take a dive at these questions and identify your possible behaviour in

these situations. Look for the most likely behaviour:

1. You get tele-callers calling and selling you insurance and mutual funds practically every other day.

How do you respond ?

2. You are out at a restaurant with your friends. One of your friend mocks at you making demeaning

remarks in a fun way . What will be your reaction?

3. You are catching up with your favourite television series, when your sibling comes up demanding the

remote. Would you give away your remote ?


26


4. At work, there is an interesting assignment which has come up. Your senior asks your team if anyone

interested to take up. Two of your other colleagues also show interest. You too think it's a great

opportunity not to be missed. How do you ensure you are involved ?

5. It is your first meeting at a new office. At the meeting, there is a discussion about a topic you are

proficient at. However, the other team members are not aware of the fact. Would you make your

presence felt ?

6. At a society meeting, a proposal for collection is shared by the secretary which you are not convinced at

all. The majority raise their hands in approval. Would you speak up?

7. You bought a gift for someone, and the person out rightly expressed an honest view that reflected that

he /she did not like the gift too much. What would be your reaction?

8. There is thought you have expressed about a particular issue on a social media platform. It has had

many negative comments and feedback. Would you counter argue?

There are no right or wrong answers to the above situations. The answers would be mere indicators of a

particular behavioural pattern and behaviours can be changed or modified.

Assertiveness is a behavioural pattern which can be learnt through practice and techniques.

In the next article we will delve more into the assertiveness techniques.

Source : Assertiveness a practical guide by David Bohman-Carter


Compiled by:

CS Keyur Jitendra Furia

capitalytic


27

Put Call Ratio (PCR)Put/Call ratio (PCR) is a popular derivative indicator, specifically designed to help traders to gauge the overall

sentiment (mood) of the market. The ratio is calculated either on the basis of options trading volumes or on

the basis of the open interest for a particular period.

Put/Call ratio is a derivative indicator, it looks at option build-up, helping trader to understand whether a

recent rise or fall in the markets is excessive and if the time is correct to make a contrarian call. It's an

indicator that's best made use of during market extremes, traders try to identify periods where a reversal

could occur in the markets. It is also essential to know how to read put call ratio charts as the shifts are critical

indicators of the likely market movement. Most traders use the PCR as a fairly reliable indicator of the

direction of the market

How to calculate Put call ratio?

Total open interest of Puts / Total open interest of Calls

If the ratio is more than 1, it means that more puts have been traded during the day and if it is less than 1, it

means more calls have been traded.

Example:

Strike Call OI Put OI Here Put Call ratio is more than 1

12000 1856250 2687050

12100 852550 1029100 i.e 54733375 / 3855050

12200 963900 1442175 12300 182350 315050 PCR is 1.49

Total

3855050

5473375



28

How to analyse Put call ratio?

Let's see how PCR analysis can be interpreted taking option sellers into consideration who are the major

players in the market as compared to the retail public who are usually on the buying side of the trade.

Interpretation

If put-call ratio increases as minor dips getting

bought in during an up trending market

Bullish Indication. It means the put writers are

aggressively writing at dips expecting the uptrend

to continue

If put-call ratio decreases while markets testing the

resistance levels

Bearish Indication. It means call writers are

building fresh positions, expecting a limited

upside or a correction in the market.

If put-call ratio decreases during down trending

market

Bearish indication. It means option writers are

aggressively selling the call option strikes.

Put / Call Ratio

Put/call ratio help traders decide the price movement of an underlying security and guides them to place

directional bets on the stocks. Being a contrarian indicator, it helps traders not to get trapped with Herd

Mentality. As the ratio is calculated both in terms of open interest and volume, the entire trading behaviour of

market participants can be analysed using the Put/call ratio.

Strike, Total Volume or Open Interest

There are a few ways to look at PCR; using a single strike price, the total volume for expiry/underlying or open

interest per expiry/underlying.

1. Per Strike

2. Aggregated Volume

3. Total Open Interest

Traders can combine options data including the Put Call ratio with implied volatility to gauge if long or

short positions have been created in the market

Sr. No

O.I (Open Interest)

IV

PCR

Position Indication

View

1

Increase in Put O.I

Increases

Increases

Buying of Put Option

Bearish

2 Increase in Put O.I

Decreases

Increases

Writing of Put Options

Bullish

3 Increase in Call O.I Increases Decreases Buying of Call Options Bullish

4 Increase in Call O.I Decreases Decreases Writing of Call Options Bearish

5 Decrease in Call O.I Decreases Increases Call Unwinding Bullish

6 Decrease in Put O.I Decreases Decreases Put Unwinding Bearish

7 Decrease in Put O.I Increase Decreases Short Covering in Put Option Bearish

8 Decrease in Call O.I Increase Increases Short Covering in Call Option Bullish



29

PCR as a Contrarian Indicator

Put / Call Ratio Interpretation

If put-call ratio is increasing during correction in up-

trending market and Implied volatility is falling

Bullish Indication. It means the put writers are

aggressively writing at dips.

If put-call ratio is steadily rising during the day along

with Nifty spot.

Bullish Indication.

If put-call ratio is increasing with sharp rise in

Implied volatility while Nifty spot is near resistance

level.

Bearish Indication.

If put-call ratio decreases during down trending

market

This is a very bearish indication. It means call writers

are aggressively writing at every rise or put writers

are building bearish positions.

Nifty movement & PCR comparative data chart


BRIEF UPDATE ON SEBI AND CORPORATE LAW

by CA IP Neha Rajen Gada and CA IP Rajen Hemchand Gada


30

SEBI

A. NOTIFICATIONS

1. Resignation of statutory auditors from listed

entities and their material subsidiaries

[Issued by the Securities and Exchange Board

of India vide Notification Circular No.

SEBI/LAD-NRO/GN/2019/42 dated December

06, 2019]

IPO / Offer / Issue related offer documents will

now be required to be filed with the jurisdictional

regional office of SEBI which oversees the area

wherein the registered office of the company is

situated as enlisted in SEBI Circular No. Circular

No.: CFD/DIL1/CIR/P/2019/0000000154 dated

December 10, 2019.

B. CIRCULARS

1. Disclosures by listed entities of defaults on

payment of interest/ repayment of principal

amount on loans from banks / financial

institutions and unlisted debt securities


of India vide Circular No. SEBI/HO/CFD/CMD1

/CIR/P/2019/140 dated November 21, 2019]

SEBI has directed Companies which listed

specified securities (equity and convertible

securities), Non Convertible Debentures and non

convertible Redeemable Preference Shares to

give disclosure in case the entity has defaulted in

payment of interest / instalment obligations on

loans, including revolving facilities like cash

credit, from banks / financial institutions and

unlisted debt securities.

The disclosure has to be made in prescribed

format and within the time limit specified by

SEBI in this regard. The disclosures have been

made effective from January 01, 2020.

2. Guidelines for preferential issue of units and

institutional placement of units by a listed

Real Estate Investment Trust (REIT)


of India vide Circulars No. SEBI/HO/DDHS

/DDHS/CIR/P/2019/142 dated November 27,

2019]

The guidelines prescribe the eligibility conditions

and manner of issuance of units including the

disclosure requirements post issuance.

3. Guidelines for preferential issue of units and

institutional placement of units by a listed

Infrastructure Investment Trust (InvIT)


of India vide Circulars No. SEBI/HO/DDHS

/DDHS/CIR/P/2019/143 dated November 27,

2019]

The guidelines prescribe the eligibility conditions

and manner of issuance of units including the

disclosure requirements post issuance.

4. Framework for issue of Depository Receipts [Issued by the Securities and Exchange Board

of India vide Circulars No. SEBI/HO/MRD2/

DCAP/CIR/P/2019/146 dated November 28,

2019]

SEBI has permitted issuance of DRs. In certain

permitted jurisdictions in line with Central

Government vide notification dated November

28, 2019, has notified the list of Permissible

Jurisdictions in pursuance of notification dated

September 18, 2019. September 18, 2019.



31

Accordingly, for the purpose of Para 2.7 of the

abovementioned Circular dated October 10,

2019, a list of Permissible Jurisdictions and

International Exchange(s) is placed at:

1. United States of America - NASDAQ, NYSE

2. Japan - Tokyo Stock Exchange

3. South Korea - Korea Exchange Inc.

4. United Kingdom excluding British Overseas

Territories- London Stock Exchange

5. France - Euronext Paris

6. Germany - Frankfurt Stock Exchange

7. Canada - Toronto Stock Exchange

8. International Financial Services Centre in India -

India International Exchange, NSE International

Exchange

CORPORATE LAW

A. CIRCULARS

1. Extension of last date of filing NFRA-2

[Issued by Ministry of Corporate Affairs vide

General Circular No. 14/2019 dated November

27, 2019]

The time limit for filing of Form NFRA-2 as

required to be filed under rule 5 of National

Financial Authority Reporting Rules, 2018 has

been relaxed. The revised time limit for filing

Form NFRA-2 will be 90 days from the date of

deployment of this form on the website of

National Financial Reporting Authority (NFRA).

2. Extension of last date of filing Form PAS-6

[Issued by Ministry of Corporate Affairs vide

General Circular No. 16/2019 dated November

28, 2019]

MCA has extended the time limit for filing of PAS-

6 for the year ended 30-09-2019. This date has

now been extended till 60 days from the date of

deployment of the Form.

CA Manoj Chunilal Shah CA Viral Vinod Satra

Compiled by:FEMAUPDATES



32

Amendments to Foreign Exchange Management (Non Debt Instruments) Rules 2019thFollowing amendments have been made to Non Debt Instrument Rules 2019 by Central Government on 5

December 2019:

a. Change in Definition of Investment Vehicle:

Definition of Investment vehicle has been modified. Mutual Funds which invest more than fifty percent in

equity governed under SEBI Mutual Fund Regulations will no longer fall under definition of an Investment

Vehicle.

b. Change in Definition of Sectoral Cap:

Earlier for determination of sectoral cap, investment in debt instruments was included. This has now

been omitted.

c. Amendment to Rule 9(4) – Earlier transfer by a person resident in India to a person resident outside

India on non repatriation basis by way of gift was with prior RBI approval.

Now the words 'non-repatriation basis' have been omitted.

d. Transfer of equity instruments by FPI (Rule 11) – In terms of amendment, FPI cannot transfer equity

instruments of Indian Company by way of gift to any person resident outside India.

e. Pricing guidelines – Rule 21:

Following explanation has been added to Rule 21(2):

“Explanation: In case of convertible equity instruments, the price or conversion formula of the

instrument should be determined upfront at the time of issue of the instrument. The price at the time of

conversion should not in any case be lower than the fair value worked out, at the time of issuance of such

instruments, in accordance with these rules.”

f. Changes in Sector Specific Conditions:

In the principal rules, in Schedule 1, in the Table,-

i. against Sl. No. 3.2, in column (2), under the heading Coal and Lignite,-

a. for entry (a), the following entry shall be substituted, namely:

“(a) Coal and Lignite mining for captive consumption by power projects, iron and steel and cement

units and other eligible activities permitted under and subject to the provisions of the Mines and

Minerals (Development and Regulation) Act, 1957 (67 of 1957) and the Coal Mines (Special

Provisions) Act, 2015 (11 of 2015).”;

b. after entry (b), the following entry shall be inserted, namely:-

“(c) For sale of coal, coal mining activities including associated processing infrastructure subject to the

provisions of the Mines and Minerals (Development and Regulation) Act, 1957 and the Coal Mines

(Special Provisions) Act, 2015 and as amended from time to time and other relevant Acts on the

subject.”;

ii. against Sl. No. 3.4, in column (2), under the heading Other Conditions, clauses (a) and (b) shall be re-

lettered as clause (b) and (c) respectively and before clause (b) as so re-lettered, the following clause



33

shall be inserted, namely:-

“(a) Associated Processing Infrastructure” as contained in 3.2 (c) includes coal washery, crushing, coal

handling, and separation (magnetic and non-magnetic)”;

iii. Sr. No. 5.1: For “A manufacturer is permitted to sell its products manufactured in India through

wholesale and/ or retail, including through e-commerce without Government approval.” the following

shall be substituted, namely:

“Manufacturing activities may be either self manufacturing by the investee entity or contract

manufacturing in India through a legally tenable contract, whether on Principal to Principal or

Principal to Agent basis. Further, a manufacturer is permitted to sell his products manufactured in

India through wholesale and/or retail, including through e-commerce, without Government

approval.”

iv. against Sl. No. 7.2, Sl. No. 7.2.3, shall be renumbered as Sl. No. 7.2.4 and before Sl. No. 7.2.4 as so

renumbered, the following Sl. No. shall be inserted, namely:-7.2.3Uploading/Streaming of News and

Current Affairs through Digital Media26%Government

v. against Sl. No. 15.2.3, for entry (p), the following entry shall be substituted, namely;-

“(p) e-commerce marketplace entity with FDI shall have to obtain and maintain a report of statutory

auditor by 30th of September every year for the preceding financial year confirming compliance of the

e-commerce guidelines.”;

vi. against Sl. No. 15.3, in column (4), under the heading Entry Route, for the entries, the following entry

shall be substituted, namely:-

“Automatic.”;

vii. against Sl. No. 15.3.1, for the entries (e), (f) and (g), the following entries shall be substituted, namely:

“(e) In respect of proposals involving foreign investment beyond 51 per cent, sourcing of 30 percent of

the value of goods procured, shall be done from India, preferably from MSMEs, village and cottage

industries, artisans and craftsmen, in all sectors. The quantum of domestic sourcing shall be self-

certified by the company, to be subsequently checked, by statutory auditors, from the duly certified

accounts which the company shall be required to maintain. The procurement requirement is to be met

in the first instance as an average of five years total value of goods procured beginning 1st April of the

year of the commencement of SBRT business (i.e. opening of first store or start of online retail,

whichever is earlier). Thereafter, SBRT entity shall be required to meet the 30 per cent local sourcing

norms on an annual basis. For the purpose of ascertaining the sourcing requirement, the relevant

entity would be the company incorporated in India, which is the recipient of foreign investment for the

purpose of carrying out single brand product retail trading.

(f) For the purpose of meeting local sourcing requirement laid down at entry (e), all procurements

made from India by the SBRT entity for that single brand shall be counted towards local sourcing,

irrespective of whether the goods procured are sold in India or exported. SBRT entity is also permitted

to set off sourcing of goods from India for global operations against the mandatory sourcing

requirement of 30 per cent. For this, purpose, 'sourcing of goods from India for global operations' shall

mean value of goods sourced from India for global operations for that single brand ( in INR terms) in a

particular financial year directly by the entity undertaking SBRT or its group companies ( resident or

non-resident), or indirectly by them through a third party under a legally tenable agreement.

(g) A SBRT entity operating through brick and mortar stores, can also undertake retail trading

through e-commerce. However, retail trading through e-commerce can also be undertaken prior to

opening of brick and mortar stores, subject to the condition that the entity opens brick and mortar


Compiled by:

CA Haresh Padamshi Kenia

DIRECT TAXES

LAW UPDATE


34

1. Prescribed class of persons under clause (XI) of the proviso to section 56(2) (x) of the Income Tax Act- New Rule 11 UAC - [ 267 Taxman (St.) 15 ]

The Central Government, in exercise of powers

conferred by clause (XI) of the proviso to section

56(2) (x) r.w.s 295, vide Notification No. G.S.R.

836 (E) [NO. 96/2019(F. NO. 370142/29/2019-

TPL)], DATED 11-11-2019, gives the Income tax th(13 Amendment), Rules, 2019. It shall come in

force from 01/04/2020. It shall be applicable stfrom assessment year commencing on the 1 day

of April, 2020 and subsequent assessment years.

It inserts new Rule, 11UAC. It gives the

prescribed class of person for the purpose of

clause (XI) of the proviso to section 56 (2) (x) of

the Income Tax Act.

It provides that the provision of section 56(2)(x)

does not apply to any immovable property, being

land or building or both, received by a resident of

an unauthorized colony in the National Capital

Territory of Delhi, where the Central Government

by notification in the Official Gazette, regularized

the transaction of such immovable property

based on the latest Power of Attorney, Agreement

to Sale, Will, possession letter and other

documents including documents evidencing

payment of consideration for conferring or

recognizing right of ownership or transfer or

mortgage in regard to such immovable property

in favour of such resident. It also defines the term

“resident” & ”unauthorized colony”.

2. Sect ion 194M and sanct ion 194N –

Amendment in Rule 30,31,31A, from 26Q and

Form No. 27Q, New Form No. 16D and Form

No. 26QD - [ 267 Taxman (St.) 16 ]

The Central Board of Direct Taxes, in exercise of

powers u/s. 295 r.w. section 194M & section

194N, vide Notification No. G.S.R. 858 (E) [NO.

98/2019(F.NO. 370142/30/2019-TPL)], DATED t h18 -11 -2019 , g i v e s I n come Tax ( 14

Amendment), Rules, 2019. It came into force

from the date of its publication in the Official

Gazette.

It inserts new rule (2C) to rule 30, prescribing

the time limit of payment of 30 days from the

end of the month in which deduction u/s. 194M

is made and also prescribes a challan-cum-

statement in Form No. 26QD for the payment of

TDS.

It inserts new rule (6C) to rule 30 prescribing

the mode of payment being amount to be paid

electronically within the time limit prescribed

under rule (2C) in respect of tax deducted u/s.

194M of the Income tax Act.

It inserts new rule (3C) to rule 31 of the Income

tax Rules prescribing Form No. 16D being

certificate of tax deducted at source u/s. 194M

and also prescribing the time limit of 15 days

from the due date for furnishing the challan-

cum-statement in Form No. 26QD.

It inserts new clause (ix) to rule 31A(4) of the

Income tax Rules requiring deductor to furnish

particulars of amount paid or credited on which

tax was not deducted in view of exemption

provided in clause (iii) or clause (iv) of the

proviso to section 194N or in view of the



35

notification issued under clause (v) of the

proviso to section 194N.

It inserts new rule (4C) to rule 31A requiring

every person responsible for deduction of tax

u/s. 194M to furnish to the Principal Director

General of Income-tax(Systems) and others, a

challan-cum-statement in Form No. 26QD

electronically within 30 days from the end of the

month in which deduction is made.

It inserts new Form No. 16D in Appendix – II of

the Income tax Rules.

It amends Form No. 26Q in Appendix – II of the

Income tax Rules.

It inserts new Form No. 26QD in Appendix – II of

the Income tax Rules.

It amends Form No. 27Q in Appendix – II of the

Income tax Rules.

3. Double Taxation Agreement section 90- DTAA

with Morocco- Amendment in Notification No.

GSR 245(E), dated 15-03-2000 [ 267

Taxmann (St.) 1]

The Central Government vide Notification No.

S.O. 3789(E) [NO. 84/2019 (F.NO. 503/09/2009-

FTD-II)], DATED 22-10-2019, notifies the

Protocol amending the Convention between the

Republic of India and the Government of the

Kingdom of Morocco for the avoidance of double

taxation and the prevention of fiscal evasion with

respect to taxes on income has been signed at thNew Delhi on the 8 day of August, 2013, and the

thdate of entry into force of the said Protocol is 15

July, 2019.

One may refer to above citation for further

details.

4. Section 194N of the Income tax Act – Payment

of certain amount in cash-Notified other

person and class of persons. [ 266 Taxmann

(St.) 54]

The Central Government, in exercise of the power

conferred by section 194N (v) of the Income tax

Act, vide Notification No. S.O. 3719(E) [NO.

80/2019 (F.NO. 370142/12/2019 - TPL

(PART2) ) ] , DATED 15 -10 -2019 , a f t e r

consultation with Reserve Bank of India, hereby

specifies,-

the authorized dealer and its franchise agent and

sub-agent; and

Full-Fledged Money Changer (FFMC) licensed by

the Reserve Bank of India and its franchise agent;

maintaining a separate bank account from which

withdrawal is made only for the purposes of,-

(i) purchase of foreign currency from foreign

tourists or non-residents visiting India or from

resident Indians on their return to India, in cash

as per the directions or guidelines issued by

Reserve Bank of India; or

(ii) disbursement of inward remittances to the

recipient beneficiaries in India in cash under

Money Transfer Service Scheme (MTSS) of the

Reserve Bank of India;

and a certificate is furnished by the authorized

dealers and their franchise agent and sub-agent,

and the Full-Fledged Money Changers (FFMC)

and their franchise agent to the bank that

withdrawal is only for the purposes specified

above and the directions or guidelines issued by

the Reserve Bank of India have been adhered to.

It also defines the term “authorized dealer”, This

notification deemed to have come into force with steffect from the 1 day of September, 2019.


Compiled by:GST UPDATES

CA Nitin Dhanji Kenia CA Bharat Kalyanji Gosar


36

NOTIFICATIONS - CENTRAL TAX:

Notification No. 57/2019 - Central Tax dated th26 November, 2019.


Notification No. 63/2019 - Central Tax dated th12 December, 2019.


The time limit for furnishing the details of

outward supplies in Form GSTR-1 of the Central

Goods and Services Tax Rules, 2017, by

registered persons whose principal place of

business is in the State of Jammu and Kashmir

having aggregate turnover of more than 1.5 crore

rupees in the preceding financial year or the

current financial year, for each of the months

from July, 2019 to September, 2019 & October,

2019 is extended to 20/12/2019. The

Notifications are effective from 15/11/2019,

11/11/2019, 30/11/2019 & 30/11/2019

respectively.



The due date of furnishing the return by a

registered person, whose principal place of

business is in the State of Jammu and Kashmir,

required to deduct tax at source under Section

51 of CGST Act in Form GSTR-7 for the months

July, 2019 to October, 2019 is extended to

20/12/2019. The Notifications are effective from

10/11/2019, 30/11/2019 respectively.





The return in Form GSTR-3B, for registered

persons whose principal place of business is in

the State of Jammu and Kashmir, for the months

from July, 2019 to September, 2019 & October,

2019 shall be furnished electronically through

the common portal, on or before 20/12/2019.

The Notifications are effective from 20/11/2019,

20/11/2019, 30/11/2019 & 30/11/2019

respectively.


The Notification Seeks to notify the transition

plan with respect to Jammu and Kashmir

reorganization w.e.f. 31.10.2019.


Vide this Notification, following Rules are

amended in the Central Goods & Services Tax thRules, 2017. Amendment is effective from 13

December, 2019.

Rule 23(4) & (5): It is now provided by inserting

these new sub rules that specified registered

persons shall have to prepare invoice in Form

GST INV-01 including specified particulars after

obtaining an Invoice Reference Number by

uploading information contained therein on the

Common Goods and Services Tax Electronic

Portal. Invoice issued other than this manner

shall not be treated as Invoice.


The Notification seeks to notify the common

portal for the purpose preparing of e-invoice in

terms newly inserted Rule 48(4). The Notification

is effective from 01/01/2020.




37

The registered person whose aggregate turnover

in a financial year exceeds 100 crore rupees, is

required to prepare invoice in terms Rule 48(4)

in respect of supply of goods or services or both

to a registered person. The Notification is

effective from 01/04/2020.


By Notification No. 31/2019 - Central Tax dated th28 June, 2019 Sixth proviso was added to Rule

46 related to tax invoice to provide that from the

date to be notified, tax invoice shall have Quick

Response (QR) code. This was subject to

conditions and restriction to be notified. Vide

this Notification Government has made it

effective from 01/04/2020.


The Notification seeks to provide that an invoice

issued by a registered person whose aggregate

turnover in a financial year exceeds 500 crore

rupees, to an unregistered person (i.e., for B2C

invoice), shall have Quick Response (QR) code.

The Notification is effective from 01/04/2020.

NOTIFICATIONS - CENTRAL TAX- RATE:

Notification No. 26/2019 - Central Tax (Rate) nddated 22 November, 2019.

Notification No. 25/2019 - Integrated Tax nd(Rate) dated 22 November, 2019.

The Notification explains the term “bus body

building” and it shall include building of body on

chassis of any vehicle falling under Chapter 87 in

the First Schedule to the Customs Tariff Act,

1975.

CIRCULARS - CGST:nd

Circular No. 126/45/2019 - GST- dated 22

November, 2019.

The Circular clarifies the scope of the Notification

entry at item (id), related to job work, under

heading 9988 of Notification No. 11/2017-

Central Tax (Rate) dated 28-06-2017. It explains

that Entry at item (id) covers only job work

services as defined in Section 2(68) of CGST Act,

2017, that is, services by way of treatment or

processing undertaken by a person on goods

belonging to another registered person. On the

other hand, the entry at item (iv) specifically

excludes the services covered by entry at item

(id), and therefore, covers only such services

which are carried out on physical inputs (goods)

which are owned by persons other than those

registered under the CGST Act.

th Circular No. 127/46/2019 - GST- dated 4

December, 2019.

Vide Circular No. 107/26/2019-GST dated

18.07.2019, certain clarifications were given in

relation to various doubts related to supply of

Information Technology enabled Services (IT-e-

services) under GST. Vide this Circular, Circular

No. 107/26/2019-GST dated 18.07.2019 is

withdrawn.

ORDERS: CGST:rd

Order No. 9/2019 - Central Tax – dated 3

December, 2019.

The order seeks to extend the last date for filing of

appeals before the GST Appellate Tribunal

against orders of Appellate Authority on account

of non-constitution of benches of the Appellate

Tribunal.

The appeal under section 112(1), 112(3) is to be

filed within three/ six months respectively from

the date on which the order sought to be appealed

against is communicated to the person. It is

clarified that the start of the three/ six months

period shall be considered to be the later of the

following dates :- (i) date of communication of

order; or (ii) the date on which the President or

the State President, as the case may be, of the

Appellate Tribunal after its constitution under

Section 109, enters office.

Disclaimer: The views / opinions expressed in the articles are purely of the writers. The readers are requested to take proper professional guidance before abiding the views expressed in the articles. The publisher, the editor and the association disclaim any liability in connection with the use of the information mentioned in the articles.

PRINTED AND PUBLISHED BY MANOJ SHAH ON BEHALF OF C.V.O. CHARTERED AND COST ACCOUNTANTS' ASSOCIATION - 304, JASMINE APARTMENT, DADA SAHEB PHALKE ROAD, DADAR (EAST), MUMBAI - 400014.TEL: 022-24105987. EDITOR: RAMESH CHHEDA

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