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Transcript of Trade facilitation – Surmounting the Deadlock Erudition ‘ 06, 11th Annual Convention, Department...
Trade facilitation –Surmounting the Deadlock
Erudition ‘ 06, 11th Annual Convention, Department of commerce, Delhi School of Economics,28 October 2006, PHD Chambers of Commerce & Industry, New Delhi
Karnika Seth,
Attorney at law & Partner
SETH ASSOCIATES
ADVOCATES AND LEGAL CONSULTANTS
Introduction
Trade facilitation (TF) aims to make trade procedures as efficient as possible through the simplification and harmonization of documentation, procedures and information flows
Includes several inter-related factors such as customs and border agencies, transport infrastructure services and IT (as it relates to better logistics), regulatory environment, product standards, tariff rates etc.
Easier movement of goods and services has several benefits Reduced costs for businesses Increased predictability and transparency Better revenue collection, and improved security and
control by governments
Introduction (contd.)
Systematic rationalization of procedures and documentation for international trade (UN ECE definition).
In WTO context, it means issues covered under GATT Articles V, VIII and X.
Would essentially cover subjects relating to importation and exportation: fees and charges; formalities; documentation; publication of laws; judicial and administrative tribunal; transit.
GATT Article V
GATT Article V deals with freedom of transit of goods.
The term “traffic in transit” implies movement of goods and means of transport (other than aircraft) across the territory of the country, where both the starting and the terminating point of the journey lies beyond it.
There should be freedom of transit via the routes most convenient for international transit.
GATT Article V (contd.)
No distinction shall be made on the basis of flag of vessels, the place of origin, departure, entry, exit or destination, ownership of goods or means of transport.
The charges imposed on traffic in transit shall be reasonable and will be on MFN basis.
GATT Article VIII
GATT Article VIII deals with fees and formalities connected with importation and exportation. Its important elements are:
All fees and charges (other than import and export duties) imposed in connection with importation and exportation shall be limited to the approximate cost of services rendered. It should not represent an indirect protection to domestic products or a taxation of imports or exports.
The number and diversity of fees for above purposes should be reduced.
GATT Article VIII (contd.)
There is a need to minimize the incidence and complexity of import/export formalities and to decrease and simplify import/export documentation requirements.
Substantial penalties should not be imposed for minor breaches of customs regulations or procedural requirements
The provision of this Article shall extend to fees, charges, formalities and requirements imposed by government authorities in connection with importation and exportation.
Illustrative list of areas where this would be applicable: consular transactions, such as consular invoices and certificates; quantitative restrictions; licensing; exchange control; statistical services; documents, documentation and certification; analysis and inspection; quarantine, sanitation and fumigation.
GATT Article X
GATT Article X deals with publication and administration of trade regulations. It lays down:
Various laws, regulations, judicial decisions and administrative rulings relating to various customs related issues for clearance of goods (classification or valuation; rates of duties; requirements, restrictions or prohibitions on imports/exports) shall be published promptly by the contracting parties to enable governments and traders to become acquainted with them.
GATT Article X (contd.)
No increase in rate of duty or a more burdensome requirement, restriction or prohibition on imports shall be enforced before such measure has been officially published.
Each contracting party shall administer the laws of the above kind in a uniform, impartial and reasonable manner
GATT Article X (contd.)
The contracting parties shall maintain judicial, arbitral or administrative tribunals for prompt review and correction of administrative action relating to customs matters.
Such tribunals shall be independent of the agencies entrusted with administrative enforcement
Barriers to Trade Facilitation
excessive data /documentation requirements Red-tapism High release and clearance times Antiquated customs techniques and inefficiencies leading to
high logistics costs Absence of co-ordination between customs and other agencies Inadequate transit regimes Corruption Regulatory/administrative barriers in establishing and operating
new businesses Port congestion Scarce use of IT Lack of quick legal redress Unattractive tariff regimes
The import timeline…
Only 25% of time taken to import
(in days) is consumed in transportation
12
13
16
59
Port and TerminalHandling
Inland Transport
Customs andInspection
Prearrival documents
Source: World Bank Doing Business 2006
Typical Cargo Dwell TimeInternationalIndia
Less than 24 hrs7-14 daysImport Dwell Time
Less than 18 hrs3-5 daysExport Dwell Time
Less than 6 hrs3-5 daysShip Waiting Time
Less than 12 hrs8 daysImport
Less than 12 hrs2.5 daysExport
MumbaiContainerized Sea Freight
Delhi airportAir Freight
NormLocationTransaction
Source: Jayanta Roy “ Towards International Norms for Indirect Taxes and Trade Facilitation in India” Background paper prepared for the Task Force on Indirect Taxes, Government of India, October 2002
Trade Facilitation-GATT-Important Proposals Made94 written contributions made so far- about 60 deal with the first
aim proposals made by countries like EC, US, Canada, Japan,
Switzerland, China, Korea, Uganda, Rwanda, Paraguay, Mongolia, Argentina, India etc. Compiled in TN/TF/W/43/Rev.5
Transparency Publication of all border related laws, regulations, procedures
and practices (Gazettes, Internet) Time interval between publication of rules and entry into force Prior consultation and commenting on new and amended rules Information on policy objectives Enquiry point Advance Ruling Right of appeal/Release of goods in event of appeal Maintenance of integrity amongst officials
Important Proposals Made (Contd.)Simplification of fees fees be relatable to service provided and not
be ad valorem Publication/Notification of fees/charges Prohibition on collection of unpublicized
fees Periodic review of fees/charges Automated payment Reduction/minimization of the number and
diversity of fees and charges
Important Proposals Made (Contd.)Simplification of procedures and documentation Risk management Post clearance audit Single Window/one time submission Border agency coordination Authorized trader system Automation of customs Acceptance of commercially available information and
copies of documents Use of international standards Pre arrival clearance Expedited procedures for express shipments Separating Release from Clearance Procedures Periodic Review of Formalities and Requirements
Important Proposals Made (Contd.) Establishment and publication of
average release and clearance times Abolition of pre-shipment inspection,
consular invoices and compulsory use of brokers
Objective criteria for tariff classification Publication of fees and charges and
prohibition of unpublished ones Periodic review of fees and charges
Important Proposals Made (Contd.)
Transit formalities and documentation requirements
Give choice of route to operators Reduction/Simplification of procedures Harmonization/Standardization Promotion of regional transit
arrangement Simplified and preferential clearance for
certain goods
Important Proposals Made (Contd.) Whether transit of oil and gas through pipeline
and electricity through grid could come under Article V (in addition to air, road, rail and boat)
Non-discrimination between individual carriers and types of consignments for transit procedures
Movement of goods from one part of a country to another through a foreign country be recognised as movement in transit
Proposals made by India
GATT Art. VIII Members of a Customs Union (CU) should
adopt the same border procedures- this should include adoption of same standards, including specifications, terminologies, and definitions, inspection, sampling, and test methods, for border clearance of agriculture and food products
Testing methods should be based on specific product features and its physical state at the point of consumption, such as ‘fresh’, ‘dehydrated’, or ‘otherwise processed’.
Proposals made by India
All forms and documentation requirements relating to import clearance should be uniform for all members of a CU
In case of rejection of a consignment to meet certain standards, an option would be first given to return the rejected good to the exporter and only upon failure to exercise this option within a reasonable period of time, any other course of action, including destruction of goods could be considered
Norms of authorised trader system shall be applied uniformly across a CU
Proposals made by India
To the extent possible, a harmonised risk management system would be adopted across the entire CU
GATT Article X Import alert/rapid alert be imposed all across a
CU only if all members apply uniform standards Rapid alert be lifted if [x] successive
consignments imported from a country/exporter fulfill the prescribed standard
The speed and standard of publicity of denotification of such alert shall be of same level as its issuance
Proposals made by India
When goods are detained for inspection by customs or any other authority, there should be a mechanism to inform the importer regarding such detention-either by issuing detention memo or through an on-line system
Each member should allow importer or exporter a right of a second confirmatory test of a sample where the first test result has given an adverse finding
Technical Assistance/Capacity Building-India's recommendation
Identify important areas where a large number of developing countries require TA
Prepare an inventory of current TA work being done by donors in these identified areas-ascertain willingness of donors to extend TA-put up the information on specially created WTO website
Attempt a coordinated approach to achieve coherence
Indian Economy – An Overview Economic Performance
Sustained economic growth Average last 10 years 6.5% 2004-05 6.9% Forecast up to 2006-07 >7.0% Forecast till 2050 – Goldman Sachs 5 % p.a.
Services share in GDP over 50% (52.4% share in GDP in 2004-05) Manufacturing sector grew at 8.8% in 2004-05 (17.4% share in GDP in
2004-05) Foreign Trade
Merchandise exports grew by 25% in 2004-05, now US$80 billion Imports grew by 36%, now US$106 billion
Investment Foreign Investment – over US$14 billion in 2004-05 (FDI US$5.5
billion, FII US$8.9 billion) Mature Capital Markets
NSE third largest, BSE fifth largest in terms of number of trades A well developed banking system
Economic Reforms- Fiscal
Rationalization of tax structure – both direct and indirect
Progressive reduction in peak rates Peak Customs duty reduced to 15% Corporate Tax reduced to 30% Customs duties to be aligned with ASEAN levels
Value Added Tax introduced from 1st April 2005-
Fiscal Responsibility & Budget Management Act, 2003 Revenue deficit to be brought to zero by 2008
Economic Reforms: Liberalisation of Investment & Trade Policies Industrial Licensing
Progressive movement towards delicensing and deregulation
Licensing limited to only 5 sectors (security, public health & safety considerations)
Foreign Investment Progressive opening of economy to FDI Portfolio investment regime liberalised Liberal policy on technology collaboration
Trade Policy Most items on Open General License, Quantitative
Restrictions lifted Foreign Trade Policy seeks to double India’s share in
global merchandise trade in 5 years
Trade Policies in India
Exim Policies
Streamlined trade procedures
Liberalised import regime
Thrust on export orientation
Medium Term Export Strategy, 2002
1% share in global exports by 2007
Foreign Trade Policy 2004-2009
To double India’s share in global
merchandise trade by 2009
International Trade and India
International Trade of Select Countries in 2003
Country Exports Imports GDP Trade as % of GDP(US$ bn.) (US$ bn.) (US$ bn.)
Korea 197.6 175.5 605.0 61.7China 438.3 393.6 1446.9 57.5Mexico 165.4 171.0 626.1 53.7Russia 135.9 75.4 433.5 48.7South Africa 38.7 35.0 160.1 46.0Argentina 29.4 13.1 129.7 32.8Brazil 73.1 48.3 492.1 24.7India 57.0 74.3 588.8 22.3Source: Economist Intelligence Unit
India’s share in global merchandise exports: 0.8% (2003)
India’s Export Performance
India's Export Performance (1999-2000 to 2003-04)
63623
47742
52856
439764414736760
29751
0
10000
20000
30000
40000
50000
60000
70000
1999-2000 2000-01 2001-02 2002-03 2003-04
Years
US$
mill
ion
All Commodities Agricultural & allied productsOres & minerals Manufactured goodsPetroleum & crude products
Source: DGCIS, MOC&I
Foreign Trade Policy 2004-2009
Simplifying procedures and bringing down transaction costsTransaction costs are incurred at the pre and post-production stages, and arise out from several procedural complexities associated with administrative processes, availability of finance and transportation problems.
For enhancing the growth of exports it is important to reduce the transaction costs involved. Exim Bank Study on Transaction Costs of Indian Exports
Findings of Exim Bank’s Study
Sector No. of Firms
Transaction costs as % of export revenue (2003
Survey)
Transaction costs as % of
export revenue (1998 Survey)
Textile/Garments 23 3-10 15
Engineering goods 18 < 5 10
Pharmaceuticals 9 8 10
Chemicals 7 < 5 14
Computer software 9 1-5 10
Agro-Industries 2 1-2 7-8.5
Electronic & Electrical machinery
3 5 -
Plastic components 2 5-10 -
Paper Industry 2 5-7 -
Others 7 1-2
India’s Import Performance
Source: DGCIS, MOC&I
India's Import Performance (1999-2000 to 2003-04)
77237
566135158850056
61572
49799
37172
0
10000
20000
30000
40000
50000
60000
70000
80000
90000
1999-2000 2000-01 2001-02 2002-03 2003-04
Years
US$
mill
ion
All Commodities Petroleum crude & products Non-POL items
Potential for Increased exports
Exim Bank Study “Strategy for Quantum Jump in Exports: Focus
on Africa, Latin America and China”
India could aim to achieve:
US$ 18 billion in Africa’s Imports by 2007 from US$ 3.8 bn
in 2003-04
US$ 4 bn in China’s imports by 2007 (in 64 identified
groups) from US$ 0.86 bn in 2000
US$ 1.8 bn in LAC’s imports by 2007 (in 100 identified
groups) from US$ 0.6 bn in 2000
Share in India’s Exports in 2003-04: Africa (6%); Latin
America (1.8%); China (4.7)
Advantages
IT –ITES Industry Exports US$17.2 billion in 2004-05, growth of
34% over previous year 2008 exports target : US$60 billion, to be
35% of India’s total exports
High quality standards 76 SEI/CMM level 5 companies, two third of
world’s total, are Indian Over 250 of the Fortune 500 companies are
clients of Indian firms R&D base of over 100 FORTUNE 500
companies
Investment Opportunities • Collaborative ICT research • Joint Software development in a variety of
applications Source: NASSCOM
IT- ITES ExportsIn US $ Billion
6.2
10
12.8
17.2
8
0
2
4
6
8
10
12
14
16
18
20
2000-01 2001-02 2002-03 2003-04 2004-05
Evolution of FDI Policy
1991
1997
2000
Allowed selectively up to 40%
Up to 74/51/50% in 112 sectors under theAutomatic Route 100% in some sectors
Up to 100% under Automatic Route in all sectors except a small negative list
More sectors opened ; Equity caps raised in many other sectors Procedures simplified
FDI Policy
Liberalization
FDI up to 51% allowed under the Automatic route in 35 Priority sectors
Factors facilitating FDI
Availability of skilled manpower Politically stable economy Strong macroeconomic fundamentals Effective legal and regulatory system Flexible labor laws Trade Facilitation businesses rank customs procedures as most important impediment to
trade, followed by administrative regulations, and then tariffs Simple and predictable customs procedures Sound infrastructure network Reliable Logistics
Ability to maintain reliable, low-cost flow of raw materials and components
An effective distribution system efficient transport and logistic services are crucial for export competitiveness
and FDI- Increased private-public sector collaboration
Recent changes in FDI Policy
FDI up to 74% is permitted for the following telecom services subject to licensing and security requirements:
a. Internet service providers with gateways; b. Radio paging; and c. End-to-end bandwidth Proposals with FDI beyond 49% shall require
prior Government approval. FDI up to 49% from all sources is permitted in
the banking sector on the automatic route subject to conformity with guidelines issued by RBI from time to time.
Recent changes in FDI Policy
FDI up to 100% is permitted on the automatic route for Mass Rapid Transport Systems in all metropolitan cities, including associated commercial development of real estate.
NRI investment in foreign exchange is made fully repatriable whereas investments made in Indian rupees through rupee accounts shall remain non-repatriable.
Recent changes in FDI Policy
FDI up to 100% is permitted for development of integrated townships, including housing, commercial premises, hotels, resorts, city and regional level urban infrastructure facilities such as roads and bridges, mass rapid transit systems; and manufacture of building materials. Development of land and providing allied infrastructure will form an integral part of township’s development, for which necessary guidelines/norms relating to minimum capitalisation, minimum land area, etc., will be notified separately by the Government. FDI in this sector would be permissible with prior Government approval.
FDI up to 100% is permitted on the automatic route in hotel and tourism sector.
Recent changes in FDI Policy
FDI up to 100% is permitted on the automatic route for manufacture of drugs and pharmaceutical, provided the activity does not attract compulsory licensing or involve useof recombinant DNA technology and specific cell / tissue targeted formulations. FDIp roposals for the manufacture of licensable drugs and pharmaceuticals and bulk drugs produced by recombinant DNA technology and specific cell / tissue targeted formulationswill require prior Government approval.
FDI up to 100% is permitted in airports, with FDI above 74% requiring prior approval of the Government.
Economic Reforms: Exchange Control & Taxation
Exchange Control All investments are on repatriation basis Original investment, profits and dividend can be freely
repatriated Foreign investor can acquire immovable property
incidental to or required for their activity Rupee made fully convertible on current account
Taxation Companies incorporated in India treated as Indian
companies for taxation Convention on Avoidance of Double Taxation with 65
countries
Manufacturing competitiveness Second most attractive destination for manufacturing
ATKearney’s FDI Confidence Index 2004 Indian industry globally competitive in a wide range of
manufacturing skill-intensive products: Apparels, electrical and electronics components;
speciality chemicals; pharmaceuticals; etc. Automotive components: Major MNC’s & their OEMs
sourcing high-quality components from India Volvo, GM, GE, Chrysler, Ford, Toyota, Unilever,
Cliariant, Cummins, Delphi Indian companies now having manufacturing presence in
many countries Over 55% of approved outward investment by India
companies in manufacturing activities
India: FDI Outlook
2nd most attractive investment destination among the Transnational Corporations (TNCs) - UNCTAD’s World Investment Report, 2005
3rd most attractive investment destination – AT Kearney Business Confidence Index, 2004
Up from 6th most attractive destination in 2003 and 15 th in 2002 2nd Most attractive destination for manufacturing
Among the top 3 investment ‘hot spots’ for the next 4 years UNCTAD & Corporate Location – April 2004
Most preferred destination for services - AT Kearney’s 2005 Global Services Location Index (previously Offshore Location Attractiveness Index)
Draft Approach Paper to the Eleventh Five Year Plan (2007-08 to 2011-12) suggests that the economy can grow between 8 and 9 per cent per year
Trade agreements
Asia Pacific Trade Agreement (APTA) Trade Agreement with Japan, China, Korea, Pakistan,
Bangladesh, Maldives, Bhutan, Mongolia etc. Comprehensive Economic Cooperation Agreement
(CECA) with Singapore. Framework Agreement with The Member States of the
Cooperation council for the Arab States of the Gulf (GCC).
Framework Agreement with ASEAN, Thailand & Chile. PTA with Afghanistan, Chile , Mercosur. FTA with Sri Lanka.
India & EU Trade Relations
EU is India's largest trading partner, with two-way trade touching about 40 billion Euros last year and growing by 20 per cent .
In September 2005 it was decided to launch a High Level Trade Group (HLTG) to explore ways and means to deepen and widen the bilateral trade and investment relationship.
India and the European Union on 13th Oct 2006 agreed to begin negotiations on a Trade and Investment Agreement to lower tariff barriers and make investment flows easier.
The proposed agreement involved huge cuts in import duties and would cover 90 per cent of tariff lines over a period of time
India & EU Trade Relations
The agreement will cover trade in goods, services, investment, trade facilitation .etc.
It would open prospects for Indian agricultural exports to Europe, besides textiles, leather, gems and jewellery, chemicals and steel.
Transparency in laws and recognition of degrees will also be incorporated in the agreement .
The HLTG had suggested that the agreement be completed in a year but this time-frame looked like a "hard call". The outer limit for concluding the pact is two years.
Recent Infrastructure Initiatives
National Highway Development Programme to develop over 24,000 km of highways
Golden Quadrilateral NSEW Corridor Links to ports and State capitals
Modernisation of airports Metro and other airports
Development of ports with private sector The Electricity Act, 2003 provides the framework for development of
power sector ‘Bharat Nirman’ Programme to develop rural infrastructure at an
estimated cost of Rs. 1,74,000 crore (~US$40 billion) Jawhar Lal Nehru Urban Renewal Mission –Rs. 100,000 crore (US$22
billion) Country wide rural connectivity programme to link all unconnected
village having population of 500 with fair weather road undertaken
Roads
Policy FDI up to 100% is permitted for construction and maintenance
of roads, highways, vehicular bridges, toll roads, vehicular tunnels
Ten year tax holiday for road and highway projects Recent Initiatives
Existing road network of 3.3 million kilometers 24,000 km of Highways being developed under National
Highway Development Programme Golden Quadrilateral : 5846 kms- 5000 kms completed NSEW Corridor: 7300 kms – 784 kms completed, 3691 kms under
implementation Investment US$20 billion envisaged
Investment Opportunities Projects for 12,000 km would be on offer Many more opportunities in the States
Ports
Policy & Incentives FDI up to 100% permitted for construction and
maintenance of ports and harbours. Ten year tax holiday
Public-private partnership 12 major ports, 185 minor ports 14 private/ captive projects with investment of US$ 600
million completed 24 projects with investment of US$1.6 billion under
implementation/award Investment requirement of US$22 billion to develop
maritime sector Ports & Shipping Inland waterways
Telecommunications
Among the fastest growing telecom markets 550,000 km of optical fibre cable laid
2 million Cellular phones added every month Among the lowest mobile tariff in the world
Share of private sector 50% Tele-density of 10.66, expected to be 20 in next three years New Broad Band Policy announced:
690,000 connections since April 2005 Internet subscribers 6 million (March 05)
Investment Opportunities Setting up manufacturing facilities; Supply of hand sets and equipments Telecom & Value added service.
Food processing
Third largest producer of food items Largest milk producer Largest livestock population; 2nd largest in fruits & vegetables
Opportunities in food processing sector 50% of household income spent on food items With increasing income levels and urbanisation fast growth in demand
of processed food expected; over 250 million strong middle class Low levels of value addition in food sector: only 7%
New Integrated Food Law being enacted Investment of US$ 28 billion required to raise food processing from 2%
to 8-10%. Investment opportunities in
Processing of fruit & vegetable, meat, fish & poultry, milk products, packaged food & drinks.
Establishing infrastructure, cold chain, etc.
SEZ Act
Policy Duty free zones, deemed foreign territories FDI up to 100% permitted in almost all
manufacturing activities Transfer of goods from DTA to SEZ treated as
exports, Units to be net foreign exchange earner within 5
years. No export commitments No limits on DTA sales Can be set up in the public, private or joint sector Single Window Clearance
SEZs
Incentives For developer: Income tax exemption for a block of
10 years in 15 years For units: 100% Income Tax exemption for first 5
years, 50% for next 5 years and 50% of the ploughed back export profits for next 5 years
Exemption from indirect taxes; excise, sales, services tax, etc.
Freedom to raise ECB with out any maturity restrictions
SEZs
11 Special Economic Zones are functional SEEPZ Mumbai, Kandla, Cochin, Chennai,
Visakhapatnam, Falta, NOIDA, Surat, Salt Lake, Indore and Jaipur
Over 800 functional units employing over 100,000 persons
Exports of US$4 billion in 2004-05 42 new Special Economic Zones have been approved
and are under establishment Many have participation with State Governments and
Private Sector Major Industries in Special Economic Zones
Gems & Jewellery, Electronics & Hardware, Software, Textile & Garment, Engineering Goods, Sports Goods, Leather Products, Chemicals & Allied Products
Incentives for the Development of Industrially Backward Areas
A special package of incentives to promote industrilisation of industrially backward regions North Eastern states, Sikkim, Jammu & Kashmir,
Uttaranchal and Himachal Pradesh
Incentives 100% Income Tax Exemptions for 10 years Excise Duty Exemptions for 10 years Transport Subsidy for transportation of raw material
and finished products, Investment Subsidy (50-90%)
Governance - Initiatives
Major e-governance initiatives undertaken at Central and State level National e-Governance Action Plan
Projects being taken up in Mission mode at Central and State level. Integrated services projects for services across Departments. MCA-21 - Ministry of Company Affairs, to cover all Registrar of
Companies by June 2006 e-Biz project being taken up by the Department of IPP
To set up a web enabled portal to provide for the services at the Central, State and Local level during the entire life cycle of business
To begin with a pilot project covering 25 services in four states Project capable of rapid upscaling to cover other services and extend
to other areas Right to Information Act for greater transparency in public administration
Investment opportunities-Snapshot Development and management of
infrastructure Food processing, including logistic and
support services, development of cold chain
Manufacturing – relocation into India R&D – leveraging on abundant skilled
manpower IT & ITES, Software as well as hardware
Conclusion
Business transaction costs can be reduced by cutting red tape, embracing automation, harmonizing standards and eliminating unnecessary barriers to trade.
More FDI does not automatically transfer into higher growth: a country also needs good policies and strong institutions.
Investment in TF measures is necessary for a holistic investment climate.
Governments should continue to explore opportunities for future partnership with the private sector in the development and execution of trade facilitation programs.
Conclusion
TF is essentially about domestic capacity building, not multilateral rules.
Multilateral cooperative action at national and regional levels, is required to assist developing countries in building the capacity to implement trade facilitation.
Thank You!
SETH ASSOCIATESSETH ASSOCIATES ADVOCATES AND LEGAL CONSULTANTSADVOCATES AND LEGAL CONSULTANTSNew Delhi Law OfficeNew Delhi Law Office: C-1/16, Daryaganj, New Delhi-110002, India: C-1/16, Daryaganj, New Delhi-110002, IndiaTel:+91 (11) 65352272, +91 9868119137Tel:+91 (11) 65352272, +91 9868119137Corporate Law OfficeCorporate Law Office: B-10, Sector 40, NOIDA-201301, N.C.R ,India: B-10, Sector 40, NOIDA-201301, N.C.R ,IndiaTel: +91 (120) 4352846, +91 9810155766Tel: +91 (120) 4352846, +91 9810155766Fax: +91 (120) 4331304Fax: +91 (120) 4331304E-mail: E-mail: [email protected]