AUTOMOBILE

SECTOR!
GST KEY ISSUES
AND WAY
FORWARD!

CA Pritam Mahure and Associates

OVERVIEW

Overview? Levy? Valuation?

ITC? Way forward Actions!

REVENUE?

Real-Estate

Autom
obile

Taxes
OVERVIEW!

Key Players!
• VW India
• Hyundai
Passenger Vehicles! • MS
• Honda
• Hyundai
• Toyota • 1.4 bn!
• Tata
• GM
• Mahindra
• Ford
• Tesla!
OVERVIEW!

Approx. 7% of Employment
Organised! MS 1.5 mn units
GDP 3.70 crore!
WHY?
Past
• EVs

Future Present
• EVs • Petrol/ Diesel
engines
GST ON AUTO SECTOR!

Particulars Today Tomorrow

Motor vehicles ~45% 5% + No Cess

(28% + 17% Cess) (Reduction of taxes by ~40%)

Fuel Petrol/ Diesel Electricity

STATUS!

Particulars Central Excise ST State Excise State VAT GST

Crude, Diesel, Petrol, Yes - No Yes Excluded

NG, ATF (Entry 84) (Entry 54)

Tobacco and Tobacco Yes - No No Yes

products (Entry 84)

ALHC No - Yes Yes Excluded

(Entry 51) (Entry 54)

Electricity - - - (Entry 53 -
Taxes on the
consumption or
sale of electricity) 8
AUTOMOBILE SECTOR!
SUPPLY CHAIN!

Car
Tier III Tier II Tier I
Manufacturer

Pre-owned cars
• Dealer Consumer Dealer
• Olx/ Quikr
RATE AND CESS!

Length

Fuel
For Passenger or
Goods

Power

Old or
new
VEHICLES!

CC - 1200/1500 cc GC - 170 mm

Length - 4000 mm
 KEY ISSUES!

Classification ITC Other

• One or Two supplies • Person vs Goods • Discount vs Incentive

• Goods or services
• Goods vs money • Valuation (Exchange, moulds etc)
• Vehicles
• Company vs Director • GTA vs Not GTA
• Parts
• 13 persons vs Above 13 persons • Cancellation, FCN
• Accessories

• Rental vs Leasing

• New vs old
OEM - KEY POINTS
RATE - EV!
NOT. NO. 11/2017-CT (R)
Sr. Particulars Description GST

242A 87 Electrically operated vehicles, including two and three 5%

wheeled electric vehicles.

Explanation .- For the purposes of this entry, “Electrically

operated vehicles” means vehicles which are run solely on
electrical energy derived from an external source or from
one or more electrical batteries fitted to such road vehicles
and shall include E- bicycles.

16
ANJALI ENTERPRISES HOOGHLY MOTORS
[2021-TIOL-208-AAR-GST] [2020-TIOL-215-AAR-GST]

▪ Battery operated cars, though not fitted with ▪ 4.4 A three-wheeled motor vehicle without the battery pack

batteries, the same is still classifiable as "battery does not have the essential character of an "electrically

powered road vehicles" as they can run on battery operated vehicle." However, it is neither a vehicle fitted with

when put to use an internal combustion engine. Unless it is equipped with any
device like solar panels that may supply energy for its
▪ Fitting of battery in the vehicle, at or before the
locomotion, it is not classifiable as a vehicle under Sub-
time of supply, is not a pre-condition for the same
heading 8703 of the Tariff Act.
to be classified as electrically operated vehicle
▪ A three-wheeled motor vehicle is classifiable under HSN 8703
▪ Thus, classifiable as HSN 8703 as an 'electrically
as an electrically operated vehicle, provided it is fitted with
operated vehicle' and is taxable @ 5% GST
the battery pack. Otherwise, it will be classifiable under HSN
8706.
PARTS!
ISSUE!

18% 28%
NOT. NO. 11/2017-CT (R)
Sr. Particulars Description GST

170 8708 Parts and accessories of the motor vehicles of headings 14%
8701 to 8705 [other than specified parts of tractors]

20
SECTION XVII - VEHICLES, AIRCRAFT, VESSELS AND ASSOCIATED
TRANSPORT EQUIPMENT

2. The expressions “parts” and “parts and accessories” do not apply to the following articles, whether or not
they are identifiable as for the goods of this Section:

(a) joints, washers or the like of any material (classified according to their constituent material or in
heading 8484) or other articles of vulcanised rubber other than hard rubber (heading 4016);

(b) parts of general use, as defined in Note 2 to Section XV, of base metal (Section XV), or similar goods of
plastics (Chapter 39)

3. References in Chapters 86 to 88 to “parts” or “accessories” do not apply to parts or accessories which are
not suitable for use solely or principally with the articles of those Chapters. A part or accessory which
answers to a description in two or more of the headings of those Chapters is to be classified under that
heading which corresponds to the principal use of that part or accessory.
WESTINGHOUSE SAXBY FARMER LTD
[2021 (376) E.L.T. 14 (S.C.)]
35. Note 3 of Section XVII reads as follows :

“References in Chapters 86 to 88 to “parts” or “accessories” do not apply to parts or accessories which are not suitable for
use solely or principally with the articles of those Chapters. A part or accessory which answers to a description in two or
more of the headings of those Chapters is to be classified under that heading which corresponds to the principal use of
that part or accessory.”

36. What is recognized in Note 3 can be called the “suitability for use test” or ‘the user test’. While the exclusion under Note
2(f) may be of goods which are capable of being marketed independently as electrical machinery or equipment, for use
otherwise than in or as Railway signalling equipment, those parts which are suitable for use solely or principally with an
article in Chapter 86 cannot be taken to a different Chapter as the same would negate the very object of group
classification. This is made clear by Note 3.
WESTINGHOUSE SAXBY FARMER LTD
[2021 (376) E.L.T. 14 (S.C.)]

37. It is conceded by the Revenue that the relays manufactured by the appellant are used solely as part of the
railway signalling/traffic control equipment. Therefore, the invocation of Note 2(f) in Section XVII,
overlooking the “sole or principal user test” indicated in Note 3, is not justified.
A RAYMOND FASTENERS 2021-TIOL-05-AAAR-GST

▪ Thus it has been established beyond doubt that the impugned goods are suitable for use solely or primarily with
articles of CH 8701 to 8705 and, therefore, applying the principle laid down by the Supreme Court in GS Auto
International Ltd. (supra), it is manifest that the impugned goods will be construed as parts of Motor vehicles
falling under CH 8701 to 8705 and will merit consideration under TI 8708 9900 –

▪ Moreover, respondent are not supplying identical goods to customers from other sectors so as to construe the
goods as part of general use - Impugned goods are customised and tailor made for the automobile customers as
per specification approved by the automobile customers (company)

▪ Held, therefore, that Metal Nuts with metrical threading, Metal Nuts without metrical threading and Metal Spring
Nuts will be considered as parts of MV and are correctly classifiable under TI 8708 9900 as contended by
Department - Appeal of Department is allowed by setting this portion of the AAR
SHIROKI TECHNICO INDIA 2021-TIOL-11-AAR-GST

▪ 'Seat adjuster' merely helps in the adjustment of the seat i.e. moving it back and forth as per
requirement/convenience and merely improves the efficiency and convenience of the seat but does
not form a part of the seat - it can be derived that it can be termed only as an 'accessory' and not a
part of the 'seat’

▪ However, Chapter heading 8708 covers both the 'parts' as well as 'accessories’

▪ Therefore, 'Seat adjuster' manufactured and supplied by applicant merits classification under Tariff
item No.8708 of the First Schedule to the Customs Tariff Act, 1975 (51 of 1975) and is covered
under Serial No.170 of Schedule-IV of Notification No. 1/2017-Central Tax (Rate) - GST @28%:
BRAKES INDIA 2018-TIOL-157-AAR-GST

▪ 'Disc Brake Pads' manufactured and supplied by Applicant is a part of the motor vehicle and is
classifiable under Heading 8708 3000
WARRANTY SUPPLY – RECIPIENT?
WARRANTY!

Sweden India
Invoice

Volvo Dealer
Payment

Repairs
(Parts and Servicing)

Customer
M/S VOLVO-EICHER COMMERCIAL VEHICLES LTD
[2020-TIOL-37-AAAR-GST]

Particulars AAR AAAR

Composite supply with the principal Composite supply with the principal
Goods or services?
supply ‘’Goods’ supply ‘service’

Recipient? Customer (as agent of Sweden) Volvo Sweden

Export Not export Refrained as ‘PoS' is not covered

WARRANTY SUPPLY – ITC?
SECTION 16 - ELIGIBILITY AND CONDITIONS FOR
TAKING INPUT TAX CREDIT

(1) Every registered person shall, subject to such conditions and restrictions as may be
prescribed and in the manner specified in section 49, be entitled to take credit of input
tax charged on any supply of goods or services or both to him which are used or intended
to be used in the course or furtherance of his business and the said amount shall be
credited to the electronic credit ledger of such person.

31
SECTION 17 - APPORTIONMENT OF CREDIT AND
BLOCKED CREDITS

(1) Where the goods or services or both are used by the registered person partly for the
purpose of any business and partly for other purposes, the amount of credit shall be
restricted to so much of the input tax as is attributable to the purposes of his business.

(2) Where the goods or services or both are used by the registered person partly for effecting
taxable supplies including zero-rated supplies under this Act or under the Integrated Goods
and Services Tax Act and partly for effecting exempt supplies under the said Acts, the
amount of credit shall be restricted to so much of the input tax as is attributable to the
said taxable supplies including zero-rated supplies

32
SARASWATHI METAL WORKS [2018-TIOL-239-AAR-GST],
SOUTH INDIAN FED. OF FISHERMEN SOC. [2021-TIOL-164-AAR-GST]

Particulars AAR

Supply Without consideration

No (as covered under original

Exempt?
supply)

ITC Reversal not required

MOULDS AND DIES!
MOULDS/ DIES!

Moulds
Component
OEM
Parts Manufacturer
MOULDS AND DIES - AMORTIZATION COST!

Not to add? To add?

VALUATION - SECTION 15(2) OF CGST ACT

(2) The value of supply shall include–

(a) any taxes, duties, cesses, fees and charges levied under any law for the time being in force
other than this Act, the State Goods and Services Tax Act, the Union Territory Goods and
Services Tax Act and the Goods and Services Tax (Compensation to States) Act, if charged
separately by the supplier;

(b) any amount that the supplier is liable to pay in relation to such supply but which has been
incurred by the recipient of the supply and not included in the price actually paid or
payable for the goods or services or both;
 MOULDS AND DIES

Lear Automotive Nash Industries

(2018-TIOL-306) (2018-TIOL-260)
• Not to be included • Includible
JOB WORK - CIRCULAR 47/2018 – 8TH JUNE 2018

Not a supply

Owned by OEM and provided to

Not to be included as per 15 (2) (b)
Component Manufacturer (CM)
Moulds / dies

No ITC to be reversed

Ammortised the cost

Contract exists that component to be
manufactured using moulds and dies of CM
Reverse the credit as FOC supply
SUBSCRIPTION TO EVS!
ISSUE!

18% 5%
NOT. NO. 11/2017-CT (R)
Sr. Particulars Description GST

10. Heading 9966 - Rental services of (iii) Rental services of transport 18%
transport vehicles with operators* vehicles with or without operators,
other than (i) and (ii) above
[Added vide Not. No. 20/2019 – CT
(R) dt 30.09.2019]
17. Heading 9973 - Leasing or rental (viia) Leasing or renting of goods Same rate of central tax as
services without operator applicable on supply of like
goods involving transfer of
title in goods
42
NOT. NO. 1/2017-CT (R) - 5%
Sl.No Chapter/Heading/ Description of goods Amended Notification
Sub -
Heading/Tariff
Item
242A 87 Electrically operated vehicles, including two and three Notification 01/2017 CT
wheeled electric vehicles. (R) dated 28-06-2017 as
amended by Notification
Explanation: For the purpose of this entry "Electrically No 12/2019 CT (R) dated 31-
operated vehicles" means vehicles which are run solely on 07-2019.
electrical energy derived from an external source or from
one or more electrical batteries fitted to such road vehicles
and shall include E-bicycles.

43
YULU BIKES PVT LTD
[2021-TIOL-08-AAAR-GST]

▪ The rider never gets the possession of the vehicle!

▪ Getting access to use the vehicle does not tantamount putting the rider in possession of the vehicle!

▪ Except having access to the facility which the Appellant is providing by virtue of possessing such goods, no
such right in the goods is transferred to the rider!

▪ Providing access does not amount to right to use goods!

▪ We also see from the terms of the User Agreement that the vehicles (e-bikes and bicycles) are always in the
physical control and possession of the Appellant at all times and there is no transfer of right to use such
goods!
YULU BIKES PVT LTD
[2021-TIOL-08-AAAR-GST]

▪ In other words, the Appellant retains the effective control of the goods in all respects!

▪ Therefore, we do not find any transfer in the right to use the goods and we hold that in the absence
of any such transfer of the right to use the goods, the Appellant does not get covered under entry
Sl.No 17(iii) of the Rate Notification. The appropriate correct entry is SL. No 17(viia) i.e Leasing or
renting of goods and the rate of tax will be the same rate of tax as applicable on supply of like goods
involving transfer of title in goods!
CAR DEALER - KEY POINTS
EXCHANGE!
EXCHANGE!

Old car

Cash
Seller Customer
New car
EXCHANGE!
Section 7. Scope of Supply

(1) For the purposes of this Act, the expression “supply” includes —

(a) all forms of supply of goods or services or both such as sale, transfer, barter, exchange,
license, rental, lease or disposal made or agreed to be made for a consideration by a
person in the course or furtherance of business,

49
27. VALUE OF SUPPLY OF GOODS OR SERVICES WHERE THE
CONSIDERATION IS NOT WHOLLY IN MONEY

Where the supply of goods or services is for a consideration not wholly in money, the value of the supply shall,-

(a) be the open market value of such supply;

(b) if the open market value is not available under clause (a), be the sum total of consideration in money and any such
further amount in money as is equivalent to the consideration not in money, if such amount is known at the time
of supply;

(c) if the value of supply is not determinable under clause (a) or clause (b), be the value of supply of goods or services
or both of like kind and quality;

(d) if the value is not determinable under clause (a) or clause (b) or clause (c), be the sum total of consideration in
money and such further amount in money that is equivalent to consideration not in money as determined by the
application of rule 30 or rule 31 in that order.
EXCHANGE!

Rule 27 - Illustration:

(1) Where a new phone is supplied for twenty thousand rupees along with the exchange of an old
phone and if the price of the new phone without exchange is twenty four thousand rupees, the open
market value of the new phone is twenty four thousand rupees.

(2) Where a laptop is supplied for forty thousand rupees along with the barter of a printer that is
manufactured by the recipient and the value of the printer known at the time of supply is four
thousand rupees but the open market value of the laptop is not known, the value of the supply of
the laptop is forty four thousand rupees.
EXAMPLE!

Exchange

OMV available OMV not available

INR 10,00,000 INR 10,00,000

In Kind = Value of old car

In Cash = INR 9,00,000
INR 1,00,000
DISCOUNT VS INCENTIVES!
ISSUE!

Discount! Incentive!
FINANCIAL CN!

Car
Car
Dealer
Manufacture
FCN
POST SUPPLY DISCOUNT -CIRCULAR NO. 92/11/2019-GST

3rd October 2019

7th March, 2019 Circular No. 112/31/2019–GST
Circular No. 92/11/2019-GST Withdrawal of Circular No.
issued 105/24/2019-GST

28th June 2019

Circular No. 105/24/2019-GST
 POST SUPPLY DISCOUNT -CIRCULAR NO. 92/11/2019-GST

Free samples BoGo Buy more, save more Financial CN

• No GST • Not a ‘free’ - Single • In invoice or after • ITC available

• No ITC price for two / more supply

supplies • Colloquially referred
• ITC available as ‘volume discounts’

• Rate – Composite • Shall be occluded to

supply or Mixed determine
Supply
 SECONDARY OR POST-SALES DISCOUNTS - CIRCULAR NO.
105/24/2019-GST

Examine Obligation Discount

• True nature • With further obligation? • Additional discount for

• Without further obligation? further discount

• Dealer to pay GST on amount

received from customer plus
additional discount from
main supplier
 KWALITY MOBIKES LTD
[2019-TIOL-391-AAR-GST]

Discount/ Incentives from manufacturer for achieving sale target

Manufacturer issues a CN for the same without affecting GST!

Such discount not liable for GST!

VALUE – SPLIT OR NOT!
SUPPLY OF BOTH!

Servicing @ 18%
Authorised
Service Customer
Station Parts @ 28%
SUPPLY!

Section 7. Scope of Supply

(1) For the purposes of this Act, the expression “supply” includes —

(a) all forms of supply of goods or services or both such as sale, transfer, barter, exchange,
license, rental, lease or disposal made or agreed to be made for a consideration by a
person in the course or furtherance of business,

62
HOW TO DISTINGUISH!

PO!

Industry Contract!
practice!

Payment! Contract
Annexure!

Invoice! Intent!
SECTION 8

The tax liability on a composite or a mixed supply shall be determined in the following
manner, namely:—

(a) a composite supply comprising two or more supplies, one of which is a principal supply,
shall be treated as a supply of such principal supply; and

(b) a mixed supply comprising two or more supplies shall be treated as a supply of that
particular supply which attracts the highest rate of tax.

64
COMPOSITE SUPPLY VS MIXED SUPPLY

CS MS

[Sec. 2 (30)] [Sec. 2 (74)]

• “Composite supply” means a supply made by • “Mixed supply” means two or more
a taxable person to a recipient consisting of individual supplies of goods or services, or
two or more taxable supplies of goods or any combination thereof, made in
services or both, or any combination thereof, conjunction with each other by a taxable
which are naturally bundled and supplied in person for a single price where such supply
conjunction with each other in the ordinary does not constitute a composite supply;
course of business, one of which is a principal
supply; 65
SPLIT OR NOT!

• How is servicing of cars involving both supply of goods (spare parts) and
services (labour), where the value of goods and services are shown
separately, to be treated under GST?

• 2.1 The taxability of supply would have to be determined on a case to case

Car repairs basis looking at the facts and circumstances of each case.

• 2.2 Where a supply involves supply of both goods and services and the
value of such goods and services supplied are shown separately, the
goods and services would be liable to tax at the rates as applicable to
such goods and services separately.
DEMO CARS – ITC?
SECTION 17

(5) Notwithstanding anything contained in sub-section (1) of section 16 and sub-section (1) of section
18, input tax credit shall not be available in respect of the following, namely :—

(a) Motor vehicles for transportation of persons having approved seating capacity of not more than
thirteen persons (including the driver), vessels and aircraft except when they are used -

(i) For making the following taxable supplies, namely

(A) further supply of such vehicles or

(B) transportation of passengers; or

(C) imparting training on driving such motor vehicles

68
CHOWGULE INDUSTRIES PVT LTD KHATWANI SALES AND SERVICES
[2020-TIOL-05-AAR-GST] LLP 2021-TIOL-49-AAR-GST

▪ A reading of s.17(5)(a) indicates that ITC shall be available

▪ Every model of demo cars is used by applicant for
in respect of Motor vehicles which are further supplied as
demonstration only for a limited period viz. every two
such
years or 40,000 kms whichever is earlier
▪ Subsequent sale of Demo vehicle after one or two years
▪ Thereafter, the said vehicle is sold after
cannot be said to be further supply inasmuch its not
paying applicable taxes on sale value at that point of
sale of a new vehicle but second hand car
time
▪ Demo vehicle used for demo and trial to the customers are
▪ Since the applicant would be making further supplies of not covered in the exception clause:
the Demo vehicles and there is no time limit prescribed (A) i.e for further supply of such vehicle or in clause
in the GST Act for making such supplies, Authority is of (B) i.e. for transportation of passengers or in clause
the opinion that applicant is eligible to avail ITC (C) i.e. for imparting training for driving
CHOWGULE INDUSTRIES PVT LTD KHATWANI SALES AND SERVICES
[2020-TIOL-05-AAR-GST] LLP 2021-TIOL-49-AAR-GST

▪ Availability of credit is dealt with u/s 18 of the Act ▪ Therefore, although the demo vehicles are for
furtherance of business of the applicant, even
then they are not eligible for ITC in view of
provisions of s.17(5)(a) of the Act

▪ Furthermore, eligibility for ITC on Demo vehicles

cannot be decided on the basis of
their capitalisation or payment of GST at the time
of their sale in the subsequent year(s) since what
is essential is compliance of the provisions of
s.17(5)(a) of the Act
CUSTOMER - KEY POINTS
CASH AND CARRY VANS!
SECTION 17 – BEFORE 1.02.2019

(5) Notwithstanding anything contained in sub-section (1) of section 16 and sub-section (1)
of section 18, input tax credit shall not be available in respect of the following, namely :—

(a) Motor vehicles and other conveyances except when they are used
(i) For making the following taxable supplies, namely

(A) further supply of such vehicles or

(ii) For transportation of goods

73
PERSONS VS GOODS TRANSPORT

SECTION 2. Definitions. — In this Act, unless the context otherwise requires, —

(52) “goods” means every kind of movable property other than money and
securities but includes actionable claim, growing crops, grass and things
attached to or forming part of the land which are agreed to be severed before
supply or under a contract of supply;
CMS INFO SYSTEMS 2020-TIOL-33-AAAR-GST

▪ In the context of the present case, it is unavoidably warranted to deviate from the literal
meaning provided to the term 'money' u/s 2(75) of the CGST

▪ 'Money' transported by the appellant in the cash-carry vans can be considered as 'goods’,

▪ ITC in respect of the cash-carry vans used for transportation of cash will be available to the
appellant in accordance with provisions of s.17(5)(a)(ii) of the CGST Act, 2017 - Held
therefore that Input Tax Credit against the GST paid on the purchase and fabrication of the
motor vehicles used for carrying cash and bullions is available to the appellant
SECTION 17 – W.E.F. 1.02.2019

(5) Notwithstanding anything contained in sub-section (1) of section 16 and sub-section (1)
of section 18, input tax credit shall not be available in respect of the following, namely :—

(a) Motor vehicles for transportation of persons having approved seating capacity
of not more than thirteen persons (including the driver), vessels and aircraft
except when they are used -
(i) For making the following taxable supplies, namely
(A) further supply of such vehicles or
(B) transportation of passengers; or
(C) imparting training on driving such motor vehicles

76
ITC FOR CUSTOMER!
SECTION 17 - APPORTIONMENT OF CREDIT AND BLOCKED CREDITS

(5) Notwithstanding anything contained in sub-section (1) of section 16 and sub-section (1) of
section 18, input tax credit shall not be available in respect of the following, namely :—

(a) Motor vehicles for transportation of persons having approved seating capacity of not
more than thirteen persons (including the driver), vessels and aircraft except when they
are used -
(i) For making the following taxable supplies, namely
(A) further supply of such vehicles or
(B) transportation of passengers; or
(C) imparting training on driving such motor vehicles

78
SECTION 17 - APPORTIONMENT OF CREDIT AND BLOCKED CREDITS

(b) the following supply of goods or services or both —

(i) food and beverages, outdoor catering, beauty treatment, health services, cosmetic and
plastic surgery, leasing, renting or hiring of motor vehicles, vessels or aircraft referred to
in clause (a) or clause (aa) except when used for the purposes specified therein, life
insurance and health insurance :

79
ISHAN RESINS AND PAINTS LTD 2020-TIOL-13-AAR-GST

▪ Section 17(5)(a) of the CGST Act does not allow Input Tax credit on inward supply of motor vehicles
of specific category (i.e. those meant for transportation of persons having seating capacity not
exceeding thirteen persons)

▪ Such restriction does not apply to the Goods Transport Vehicles

SALE BY CUSTOMER!
SALE OF PRE-OWNED CAR!

BMW BMW BMW

Individual – Businessman

Individual – Salaried
Company

80 lacs 80 lacs 80 lacs

GST? GST? GST?
SALE!
Section 7. Scope of Supply

(1) For the purposes of this Act, the expression “supply” includes —

(a) all forms of supply of goods or services or both such as sale, transfer, barter, exchange,
license, rental, lease or disposal made or agreed to be made for a consideration by a
person in the course or furtherance of business,

83
BUSINESS!

2 (17) “business” includes —

(a) any trade, commerce, manufacture, profession, vocation, adventure, wager or any
other similar activity, whether or not it is for a pecuniary benefit;

(b) any activity or transaction in connection with or incidental or ancillary to sub-clause

(a);

(c) any activity or transaction in the nature of subclause (a), whether or not there is
volume, frequency, continuity or regularity of such transaction;
PRESS NOTE DATED 13.07.2017

4. Even though the sale of old gold by an individual is for a consideration, it

cannot be said to be in the course or furtherance of his business (as selling
old gold jewellery is not the business of the said individual), and hence
does not qualify to be a supply per se.
THANK YOU

CA Pritam Mahure and Associates

+91 9920644648 / 020-27293425
Happy to Discuss!

https://pmaconsulting.in
info@lawgical.in
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