JULY 2020

GST Updates:

1. Reduction/Waiver of Interest & Late Fee payable & Extension of Due Date for August,2020 & One Time Amnesty Scheme for filing of Form GSTR-3B

The Central Government vide Notification No. 51/2020- Central Tax dated 24th June, 2020 ,Notification No. 52/2020- Central Tax dated 24th June, 2020 & Notification No. 54/2020- Central Tax dated 24th June, 2020 , Notification No. 05/2020– Integrated Tax dated 24th June,2020 & Notification No. 02/2020 – Union Territory Tax dated 24th June,2020 has made the following conditional waiver of interest & late fee for delay in furnishing returns in FORM GSTR-3B for tax periods of February, 2020 to July, 2020 & also provided one time amnesty by lowering/waiving of late fees for non-furnishing of FORM GSTR-3B from July, 2017 to January, 2020 & extended the due date for furnishing FORM GSTR-3B for the month of August,2020 as under.:-

*A - Taxpayers whose principal place of business is in the States of Chhattisgarh, Madhya Pradesh, Gujarat, Maharashtra, Karnataka, Goa, Kerala, Tamil Nadu, Telangana, Andhra Pradesh, the Union territories of Daman and Diu and Dadra and Nagar Haveli, Puducherry, Andaman and Nicobar Islands or Lakshadweep.

*B- Taxpayers whose principal place of business is in the States of Himachal Pradesh, Punjab, Uttarakhand, Haryana, Rajasthan, Uttar Pradesh, Bihar, Sikkim, Arunachal Pradesh, Nagaland, Manipur, Mizoram, Tripura, Meghalaya, Assam, West Bengal, Jharkhand or Odisha, the Union territories of Jammu and Kashmir, Ladakh, Chandigarh or Delhi.

2. Waiver of late fee for delay in furnishing FORM GSTR-1

The Central Government vide Notification No. 53/2020- Central Tax dated 24th June, 2020 has made the following conditional waiver late fee for delay in furnishing returns in FORM GSTR-1 for tax periods for months from March, 2020 to June, 2020 for monthly filers and for quarters from January, 2020 to June, 2020 for quarterly filers as under:-

Income tax updates :

1.Income Tax Appellate Tribunal (ITAT) is set to launch an e-filing portal

It was also announced that the Standard Operating Procedures (SOPs) and detailed guidelines for use of facility of E-Filing Portal are under consideration and shall be announced once the E-filing Portal is hosted on the NIC server after completion of ITAT hopes that this initiative of development of e-filing portal shall be of immense use to the taxpayers, tax consultants and other stakeholders as it is yet another milestone in the their transition to digitization.

Format of Declaration to be taken from Salaried Employee by Employer to deduct TDS in Old or New IT Slab Rates

The Finance Act 2020, has introduced new section 115BAC, as per this provision the assessee has an option whether to pay tax as per new slab rates or the old slab rates including employees for Financial Year 2020-21 Assessment Year 2021-22. Where the employee opts for new tax regime then the employee has to forgo some of the tax concessions under the existing income tax act, whereas if the employee opts for old tax regime then he will get the benefits of deduction under the income tax act.

The provision is made applicable for the Individual/ HUF and the individual can exercise the option at the time of filing the return of income. If the individual assessee is a salaried employee then he opt the scheme on a yearly basis. It means the individual can switch to the tax regime of his choice in the next year.

For opting the scheme, the employee has to give declaration to the deductor of his intention to opt for old or new tax scheme as per his choice. Upon such intimation, the employer shall compute his total income and make TDS thereon in accordance with the provision of section 115BAC of the Act. The declaration made by the employee cannot be changed. However at the time of filing Returns he can again chose one more time. Also Next year he can chose again if employee wish to switch method.

Latest updates came from Government on 24th June 2020

• The last date of 31 March 2020 for filing the income tax return for AY 2019-20 (FY 2018-19) has been extended to 31 July 2020. The extension applies to the filing of original return and revised returns.
• The last date for completion of assessments which are getting time-barred on 31 December 2020 stands extended to 31 March 2021. In the case of assessments which get time-barred on 31 March 2021, the time stands extended to 30 September 2021.
• The due date for furnishing TDS and TCS returns due for the Quarter 4 of FY 2019-20 stands extended to 31 July 2020, for non-government deductor. The extension also applies to TDS and TCS return due for the month of February 2020 and March 2020 in the case of sale of immovable property etc. In case of government deductors, the extended due date is 15 July 2020.
• The due date to issue Form 16 for FY 2019-20 stands extended to 15 August 2020.
• Taxpayers can make tax-saving investments for FY 2019-20 such as payment of LIC premium, deposit to NSC, PPF, SSY and so on until 31 July 2020. Similarly, medical insurance premium, donations, interest on education loan paid until 30 July 2020 will also be eligible for a tax deduction for FY 2019-20.
• Taxpayers can also make investments in the new house property, bonds and so on until 30 September 2020 to claim capital gains exemption. Such investment or purchase made until 30 September 2020 can be claimed as capital gains exemption for FY 2019-20.
• Taxpayers having a self-assessment tax liability up to Rs 1 lakh can pay the same by 30 November 2020 without incurring penal interest liability.
• The last date of making payment under Vivaad se Vishwas Scheme without additional amount stands extended to 31 March 2021
• The last date for Aadhaar PAN linking is extended to 31 March 2021.

Overseas Direct Investment (ODI)

IIn this Article, we will be understanding what is an Overseas Direct Investment and the regulations pertaining to the same under Foreign Exchange Management Act 1999.

What is an ODI?

ODI refers to those Investments made under the automatic or approval route in a foreign entity by way of capital contribution or subscription to Memorandum or by share purchase in the form of private placement or through stock exchange, signifying a long-term interest in the foreign entity (Joint Venture (JV) or Wholly Owned Subsidiary (WOS)) by an Indian Party.

Indian Party refers to:

• A Company incorporated in India
• Body created under an Act of Parliament
• Partnership Firm registered under Indian Partnership Act 1932
• Limited Liability Partnership
• Any other entity as may be notified by RBI

Automatic Vs Approval Route:

Automatic Route investments are those wherein the Indian Party doesn’t need RBI approval for making ODI. The Indian party can approach the Authorised Dealer Category-I Bank and obtain the necessary approval.

In case of approval route, RBI approval for making such ODI is mandatory. List of cases where RBI approval is mandatory has been specified by the RBI.

Extent and Criteria of ODI Investment allowed:

i. The Indian Party can invest up to the prescribed limit of its net worth (currently 400% of networth, with the condition that anything exceeding USD I billion needs RBI approval) (as per the last audited Balance Sheet) in JV / WOS for any bonafide activity permitted as per the law of the host country. The prescribed limit vis-a-vis the net worth will not be applicable where the investment is made out of balances held in the EEFC account of the Indian party or out of funds raised through ADRs/GDRs;

ii. The Indian Party is not on the Reserve Bank’s exporters' caution list / list of defaulters to the banking system published/ circulated by the Credit Information Bureau of India Ltd. (CIBIL) /RBI or any other credit information company as approved by the Reserve Bank or under investigation by the Directorate of Enforcement or any investigative agency or regulatory authority; and

iii. The Indian Party routes all the transactions relating to the investment in a JV/WOS through only one branch of an authorised dealer to be designated by the Indian Party.

ODI by Resident Individuals from India:

It is important to note that 400% of Networth mentioned as the eligible limit if for the total financial commitment of the Indian Party with respect to ODI. Let us understand what the term financial commitment means:

TYPE	QUANTUM
Investment in equity, Compulsorily convertible Preference Shares and Other Preference shares of JV/WOS	100%
Loans to Overseas JV/WOS	100%
Guarantee issued to Overseas JV/WOS other than performance guarantee	100%
Bank guarantee issued to JV/WOS that is counter guaranteed by the Indian party	100%
Performance Guarantee	50% (in case if such 50% leads to increase in financial commitment beyond the limits, RBI approval is needed)

CONCLUSION:

This Article just gives an overview of some of the important aspects of an ODI Investment. The Master Direction on Direct Investment by Residents in Joint Venture/ Wholly Owned Subsidiary Abroad dated Jan 1 2016, updated as on September 18,2019 explains in detail the instructions issued on Direct Investments in JV/WOS.

Scheme for relaxation of time for filing Charge creation/modification forms

Every Company creating charge on it’s assets or properties must register the Charges within 30 days of creation of such charge. And where the company has failed to file the Charges within 30 days, it is allowed to register the Charges within 60 days from the date of creation of charge with payment of additional fees. Where the Company has failed to register the charges even within 60 days of creation of charge, additional 60 days is allowed to file the necessary forms with payment of applicable advalorem fees. Thus, any company must file forms relating to creation/modification of Charges within a maximum period of 120 days.

In the wake of COVID-19 situation and the Charge forms being specifically excluded from the applicability of CFSS (Companies Fresh Start Scheme),2020 wherein all other pending compliances with MCA can be complied at one go without any late fees upto 30th September 2020. MCA has announced another scheme with effect from 17th June, 2020, specifically for creation/modification of charge forms during this time. It must be noted that this Scheme is applicable only for Creation or Modification of Charge and not for any other forms like satisfaction of Charge.

This Scheme is applicable as follows:

1. The date of Creation/Modification of Charge is before 1st of Mar,2020 and the timeline for filing of Charge form has not expired as on 1st Mar,2020

Number of days to be counted:

• If the Charge form is filed on or before 30th September 2020, the number of days from 1st of Mar,2020 to 30th September 2020 shall not be considered for counting the number of days of delay for filing the form.
• If the form is not on or before 30th September,2020, the number of days of delay shall be counted from the date of creation of Charge until 29th February 2020 and add the number of days from 1st Oct 2020 until the date of filing the said form.

Applicable fee:

• If the form is filed on or before 30th September 2020, the applicable fees as on 29th of February 2020 would apply.
• If the form is filed after 30th of September 2020, the fees shall be calculated based on the number of days from the date of creation of Charge until 29th February 2020 and add the number of days from 1st of Oct 2020 until the date of filing the form.

2. Where the date of Creation/Modification of charge falls on any date between 1st of Mar,2020 and 30th of September 2020.

Number of days to be counted:

• If the form is filed on or before 30th September 2020, the applicable fees as on 29th of February 2020 would apply.
• If the form is filed after 30th of September 2020, the fees shall be calculated based on the number of days from the date of creation of Charge until 29th February 2020 and add the number of days from 1st of Oct 2020 until the date of filing the form.

The Scheme will not apply to:

• 1. The forms CHG-1 and CHG-9 for creation and modification of Charge forms respectively had been filed before the date of the circular for the scheme announcement.
• 2. The timeline of 120 days has already expired before 1st of March 2020
• 3. The timeline for filing the form expires at a future date despite the exclusion of time period provided
• 4. Filing of form for Satisfaction of Charges CHG-4.

Dividend – Taxability during FY 2020-2021

Dividend is the Income received by the shareholders of a company, which is distributed from the profits earned by such company during any given financial year. Under Income tax such dividend shall be subjected to Dividend Distribution tax (DDT) under section 115-O and the same shall be exempted in the hands of shareholders under section 10(34). This was the law prevalent up to Financial Year 2019-2020. The Finance Act 2020, has abolished DDT and hence the section 115-O has lost its relevance in case the dividend is distributed on or after 1st April 2020.

The Taxability of dividend has been restored back in the hands of shareholders and the exemption specified under section 10(34) has been wiped off. In order to tax the Dividend in the hands of shareholders, various revisions has been made in the act in respect of deduction of tax at source by domestic companies, allowability of expenses in respect of Dividend Income, Inter Corporate Dividend.

Let us now understand the meaning of dividend and the erstwhile provisions for taxability of dividend which will enable us to have a better understanding of the amended provisions with effect from 1st April 2020.

Meaning of Dividend

As discussed above, dividend is the distribution of profits by a company during any given financial year. In Income Tax act, Dividend also means distribution by the company as specified under section 2(22):

• Distribution of accumulated profits to shareholders entailing release of the company’s assets;
• Distribution of debentures or deposit certificates to shareholders out of the accumulated profits of the company and issue of bonus shares to preference shareholders out of accumulated profits;
• Distribution made to shareholders of the company on its liquidation out of accumulated profits;
• Distribution to shareholders out of accumulated profits on the reduction of capital by the company; and
• Loan or advance made by a closely held company to its shareholder out of accumulated profits.

Taxability of Dividend distributed prior to 1st April 2020

Dividend distributed by the domestic company shall be subjected to DDT as specified under section 115-O at the rate of 15% on gross amount of dividend. Therefore, the effective rate of DDT is 20.56% (after considering surcharge and education cess) on the amount of dividend.

The manner and procedure for payment of DDT is specified under section 115P:

DDT is to be paid within 14 days of declaration, distribution or payment of dividend whichever is the earliest. In case of non-payment within 14 days, the company would be liable to pay by way of interest at the rate of 1% of the DDT from the date following the date on which such DDT was payable till the time such DDT is actually paid to the government.

Since the dividend income referred to in section 115-O shall be exempted in the hands of shareholders as provided under section 10(34).

However, If the dividend which is subjected to DDT received by a resident shareholder exceeds INR 10 Lakhs, then such dividend shall be subjected to an additional tax at 10% in the hands of shareholder vide section 115BBDA (introduced in Finance Act, 2016).

The Income earned by the shareholder in the form of dividend income shall be assessed either under the head business income or Income from other sources. Since the dividend is anyway exempt under section 10(34) in the hands of resident shareholders, except where the income exceeds INR 10 lakhs, the taxability under which head of income has less relevance for dividend distributed up to 31st March 2020.

The main disadvantage of DDT in the hands of non-resident shareholders is that the credit of DDT was not available in their home countries, which ultimately result in a reduction of rate of return on equity capital.

Reason of abolition of DDT in Finance act, 2020

The concept of distribution taxes in the hands of the Indian company was introduced in India in 1997. Under this distribution tax regime, Dividend Distribution Tax ('DDT') was paid by the company on the dividends (after grossing-up) and the income was exempt in the hands of the shareholders. This was considered as an efficient mechanism to collect tax on distributed income of the company. Over a point of time, the tax rate on distribution of income by the Indian Company increased and the ambit was widened to include companies being special economic zone developers or special economic zone units.

Being among the few countries to have adopted this tax mechanism, most of the tax treaties entered with India failed to provide credit of the underlying DDT (paid by the company) to the non-resident shareholders. There has been persistent demand from non-resident investors to abolish DDT and revert to the old regime whereby dividend would be taxed in the hands of the shareholders and would allow them to take beneficial tax rates for the dividend prescribed in the tax treaties. Furthermore, such taxes paid in India would be eligible as tax credit in the home country, eliminating double taxation on the same dividend income.

Taxability of Dividend distribute after 1st April 2020

The Domestic companies shall be liable to deduct tax at source under section 194 at the rate of 10% on the dividend distributed to a resident shareholder if the aggregate amount of dividend distributed or paid during the financial year to a shareholder exceeds Rs. 5,000. However, no tax shall be required to be deducted from the dividend paid or payable to Life Insurance Corporation of India (LIC), General Insurance Corporation of India (GIC) or any other insurer in respect of any shares owned by it or in which it has full beneficial interest.
The section 10(34) has been amended to withdraw the exemption provided to shareholders in respect of dividend income with effect from financial year 2020-2021. Thus, dividend received during the financial year 2020-21 and onwards shall now be taxable in the hands of the shareholders. Consequently, Section 115BBDA which provides for taxability of dividend in excess of Rs. 10 lakh has no relevance as the entire amount of dividend shall be taxable in the hands of the shareholder.

Now let us understand the taxability of dividend in hands of Resident and Non Resident shareholders separately considering various provisions in Income Tax act:

Taxability of Dividend in the hands of resident Shareholder:

# where a resident individual, being an employee of an Indian company or its subsidiary engaged in Information technology, entertainment, pharmaceutical or bio-technology industry, receives dividend in respect of GDRs (purchased by employee in foreign currency) issued by such company under an Employees’ Stock Option Scheme, then dividend shall be taxable at concessional tax rate of 10% without providing for any deduction under the Income-tax Act.

The Tax deducted at source by the domestic company at the rate of 10% under section 194 on distribution of dividend shall be claimed by the resident shareholder while filing their respective return of income.

Taxability of Dividend in the hands of Non-resident Shareholder:

There are three types of Foreign shareholders that a company can generally have:

1. FDI – Foreign Direct Investment
Foreign Direct Investment (FDI) means investing in a country other than your home country. It involves, foreignn direct capital inflows from one country to another. Wherein, foreign countries have an ownership interest or a say in the business. FDI is generally seen as an accelerator for economic growth and it can be undertaken by institutions, corporations and individuals.

The FDI’s can invest in a company as private equity investor or as promotor of the company. A non-resident person generally hold shares of an Indian company as an Investment and, therefore, any income derived by way of dividend is taxable under the head other sources except where such income is attributable to Permanent Establishment of such non-resident in India.

2. FPI – Foreign Portfolio Investor
Foreign Portfolio Investment (FPI) means investing in the financial assets of a foreign country, such as stocks or bonds available on an exchange. This kind of investment is considered less favourable than direct investment because portfolio investment can be sold off quickly and these are at times seen as short-term attempts to make money, rather than a long-term investment in the economy. Unlike FDI, FPI doesn’t offer control over the business entity in which the investment is made.

In case of FPI’s also the securities held by them are always treated as a capital asset and not as stock-in-trade. Thus, in case of FPIs also, the dividend income shall always be taxable under the head other sources.

3. FII – Foreign Institutional Investor
Foreign Institutional Investors (FIIs) are large companies that invest in countries other than where their headquarters are located. The term FII is most commonly used in India, where it refers to outside entities investing in the nation’s financial markets. FIIs can include hedge funds, insurance companies, pension funds, investment banks and mutual funds.

FII is an important source of capital in developing economies. Yet, countries like India have placed limits on the total value of assets an FII can purchase and the number of equity shares it can buy, particularly in a single company. This helps limit the influence of FII on individual companies and the nation’s financial markets.

Examples of FIIs are pension funds, mutual funds, investment trusts, insurance or reinsurance companies, trustees, banks, endowment funds.

Dividend distributed to Non-resident shareholder or FPI/FII shall be subject to tax as specified in section 195 or section 196D respectively.

Now let us analyze the above sections to have better clarity on the taxability of dividend in the hands of Non-residents:

Section 195
In the case of dividends paid to non-resident shareholders, taxes are to be deducted at 'rates in force' under Section 195 of the IT Act, prescribed in Part II of First Schedule to the IT Act.

The term ‘rates in force’ has been defined in section 2(37A) to mean, the rates of income-tax specified in this behalf in the Finance Act of the relevant year or rates of income-tax specified in an agreement entered into by the Central Government under section 90, or an agreement notified by the Central Government under section 90A, as the case may be whichever is beneficial.

Section 90 and section 90A elaborates on the tax treaties entered into with foreign countries by India and the taxability of Dividend income under such Double Taxation Avoidance agreements (DTAA).

As per most of the DTAAs India has entered into with foreign countries, the dividend is taxable in the source country in the hands of the beneficial owner of shares at the rate ranging from 5% to 15% of the gross amount of the dividends.

Section 115A provides for the taxation of dividends received by non-residents @ 20%. The rate is relatable to the rate specified in Part II of First Schedule to the IT Act which also requires tax to be deducted on dividends paid:

• • to non-residents (not being Indians) - @ 20%;
• • to foreign companies - @ 20%.

Further, section 115A requires non-residents in possession of only dividend income to file income-tax return, if taxes have been withheld at a rate lower than the tax rate prescribed in the IT Act (i.e., 20%).

Likewise, a flipside Form 3CEB would also be required to be obtained where dividends are received from associated enterprises.

Section 196D
Section 115AD deals with the tax on the income of Foreign Institutional Investors from securities or capital gains arising from their transfer. It provides for a special rate of tax on dividend income @ 20 per cent.

Clause (a) to the Explanation to Section 115AD defines the term 'Foreign Institutional Investor' to mean such investor as the Central Government may, by notification in the Official Gazette, specify in this behalf.

Accordingly, CBDT has notified a Notification No. 17/2020 on 13.03.2020 to specify that a non-resident being an Eligible Foreign Investor which operates in accordance with the Securities and Exchange Board of India, circular IMD/HO/FPIC/CIR/P/2017/003 dated 04th January, 2017, shall be deemed as Foreign Institutional Investor (FII) for the purposes of transactions in securities made on a recognized stock exchange located in any International Financial Services Centre (IFSC), where the consideration for such transaction is paid or payable in foreign currency.

The with holding tax shall be deducted at special rate of 20% without considering the provisions of DTAA under section 90 or section 90A.

Let me now highlight on the flip side of considering the DTAA while deducting Tax on dividend distributed:
In DTAA with countries like Canada, Denmark, Singapore, the dividend tax rate is further reduced where the dividend is payable to a company which holds specific percentage (generally 25%) of shares of the company paying the dividend. However, no minimum time limit has been prescribed in these DTAAs for which such shareholding should be maintained by the recipient company. Therefore, MNCs were often found misusing the provisions by increasing their shareholding in the company declaring immediately before declaration of the dividend and offloading the same after getting the dividend. After the proposed amendment in taxability of dividend, India too will face the risk of tax avoidance by the foreign company by artificially increasing the holding in the dividend declarant domestic company.

India is a signatory to the Multilateral Convention (MLI) which shall implement the measures recommended by the OECD to prevent Base Erosion and Profit Shifting. MLI is a binding international legal instrument which is envisaged with a view to swiftly implement the measures recommended by OECD to prevent Base Erosion and Profit Shifting in existing bilateral tax treaties in force. With respect to dividend income, Article 8 (Dividend Transfer Transactions) of MLI provides for a minimum period of 365 days for which a shareholder, receiving dividend income, has to maintain its shareholding in the company paying the dividend to get the benefit of the reduced tax rate on the dividend.

Deduction in respect of certain inter-corporate dividends.
Section 80M proposes to remove the cascading effect of taxes in circumstances of dividend distribution through multiple layers of companies. This section allows the amount of dividend received by a domestic company from another domestic company or a foreign company or a business trust as deduction (only to the extent of dividend distributed) from the Gross Total Income.
Dividend received by a domestic company from a foreign company, in which such domestic company has 26% or more equity shareholding, is taxable at a rate of 15% plus Surcharge and Health and Education Cess under Section 115BBD. Such tax shall be computed on a gross basis without allowing deduction for any expenditure.
However, if such dividend is received by a domestic company from a foreign company, in which equity shareholding of such domestic company is less than 26%, then such income shall be taxable at normal tax rate and the domestic company can claim deduction for any expense incurred by it for the purposes of earning such dividend income.

Conclusion
Now with the abolition of DDT, companies will be able to successfully distribute dividend within the group without incurring DDT cost. This will be particularly helpful to listed companies, which will be able to receive dividend from their joint venture/ subsidiary/ associate and distribute the same to the ultimate shareholder without incurring DDT cost.
Even in unlisted companies/ groups, dividends may be received from the joint venture/ subsidiary/ associate with a one-time tax cost, where dividend is retained at the recipient company level.
This amendment will also be a positive move for foreign investors who do not currently receive the benefit of DDT tax credit in their home jurisdictions. Such foreign investors will now be able to avail credit of such taxes withheld, subject to the availability of the benefit of the tax treaty.

WHY ONE SHOULD INVEST IN INDIA

Fastest Growing Economy
India is considered as one of the Emerging Superpowers of the world and one of the primary attributes towards that is India is one of the fastest-growing economies in the world. In the post-pandemic world when the economy resumes across the globe, according to the International Monetary Fund (IMF) India’s GDP is expected to grow at 1.9 percent for the fiscal year ending 31st Mar’21 making it the only other large economy estimated to grow apart from China. China is undoubtedly one of the largest markets in the world but in the post-pandemic world, we could expect a shift in the mindset of the large capitalists to move their investments from China to India.

Largest Youth population
India has the largest population of youth, 600 million people below the age of 25. It is said that developing countries with a large youth population could see their economies soar provided they invest heavily in young people’s education and health. The study finds that India to be the largest supplier of university graduates in the world and has the largest group of scientists and technicians in the world.

Domestic Market
India is expected to be the third-largest consumer economy as its consumption may triple to US$ 4 trillion by 2025, owing to shift in consumer behavior and expenditure pattern, according to a Boston Consulting Group (BCG) report; and is estimated to surpass USA to become the second-largest economy in terms of purchasing power parity (PPP) by the year 2040, according to a report by PricewaterhouseCoopers.

Government Initiatives
Indian Government has taken a slew of measures to attract foreign investments into India viz., Make in India initiative to boost the manufacturing sector, Startup India to encourage start-ups, reduced corporate taxes of 15% (for the newly incorporated manufacturing companies), the simplified company set up processes, etc., Besides, the Government has also come up with Digital India initiative, which focuses on three core components: the creation of digital infrastructure, delivering services digitally and to increase the digital literacy.

Apart from the facts and figures, it is an un-denying fact that the direction of the Government of India is set towards attracting Foreign Direct Investments (FDI) to India. What could be a better time than now to invest in India, with Government making all efforts to attract investments, slashing tax rates, promising lands, simplifying set up processes, incentivizing start-ups? And with the expected mind shift of the consumers and capitalists across the globe, the Indian economy is growing large, the country as a whole is developing and overall India is becoming a land of opportunities.