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    Interns Digest 2016

    Key Topics Covered:

    • Professional Tax Act 1987
    • Companies Act, 2013
    • General
    • Income Tax Act, 1961
    • Project Finance
    • Audit
    • Companies Act Updates
    • FEMA Updates

    This article is contributed by Partners of SBS and Company LLP - Chartered Accountant Company. You can be reached at This email address is being protected from spambots. You need JavaScript enabled to view it.

    July – 2016 (Volume-24)

    Key Topics Covered:

    • International Taxation
    • FEMA
    • Audit
    • Indirect Tax
    • Companies Act, 2013
    • Labour Laws

    This article is contributed by Partners of SBS and Company LLP - Chartered Accountant Company. You can be reached at This email address is being protected from spambots. You need JavaScript enabled to view it.

    Tags: ,

    In the recent past there has been constant conflict between the employers and the Employees Provident Fund Organisation (EPFO)enforcement authorities on the issue of ‘basic wages’ on which contributions are required to be made. In this paper an attempt is made to collate the information on the subject based on the various judgements of the High Courts and Supreme Court to create a perspective on the subject for future guidance and to initiate corrective measures to avoid possible litigation with the EPFO.

     

    Para 29 of the Employees’ Provident Funds Scheme, 1952 deals with the contributions payable by the employer. In accordance with the said para, the employer shall contribute twelve per cent of the basic wages, dearness allowance (including the cash value of any food concession) and retaining allowance (if any)payable to each employee to whom the Scheme applies.

     

    The EPF&MP Act has defined ‘Basic Wages’ as all emoluments which are earned by an employee while on duty or on leave or on holiday with wages in either case in accordance with the terms of the contract of employment and which are paid or payable in cash to him, but does not include –

     

    • The cash value of any food concession;

     

    • Any dearness allowance ( that is to say, all cash payment by whatever name called paid to an employee on account of a rise in the cost of living ), house rent allowance, overtime allowance, bonus, commission or any other similar allowance payable to the employee in respect of his employment or of work done in such employment;

     

    • Any presents made by the employer.

     

    Most of the new economy establishments are devising a salary structure with Basic Salary, HRA and other allowances without the component of Dearness Allowance and contributions towards provident fund are being paid on the basic salary only on the assumption that all other allowances fall under the exclusion category as per the above definition.

     

    There has been conflict between the employers and EPF Organisation and hence these matters reached various Hon’ble High Courts in the country and some of the matters are pending before the Apex Court for its final verdict. Review of some important judgements are mentioned hereunder to understand the views of the judiciary in the matter.

     

    The Hon’ble Madhya Pradesh High Court Division Bench in the matter of Montage Enterprises Pvt Ltd Vs EPFO, Indore [2011 LLR 867] held that the conveyance allowance and Special Allowance will fall within the definition of ‘Basic Wages’. The rationale taken by the Hon’ble bench is that the Conveyance Allowance and Special Allowance is paid to all non-executive category of employees and it is not a case that some of the employees are not getting the same. It is a settled law that if such wages are paid universally, necessarily and ordinarily to all across the board, the same will fall under the definition of basic wages.

     

    In the year 2005,the Hon’ble Calcutta High Court Division Bench in the matter of RPFC (II), WB Vs.

    Vivekanadnda Vidya Mandir [2005 LLR 339] held that contributions are payable on Special Allowance

    when it is revised from time to time and the company has not adopted the system of payment of

    Dearness Allowance. The detailed view of the court in the matter is as under:

     

    In order to exclude any allowance from the purview of Section 6 which provides for liability to pay contribution based on basic wages, such allowance should fall under Clause (i), (ii) and (iii) of Section 2 (b) which enumerate allowances which are not included in the definition of ‘basic wages’. In the instant case the special allowance paid by the employer was not a retaining allowance, neither cash payment for food concession, nor over time allowance, house rent, bonus, commission, nor a present by employer and it did not satisfy any of the ingredients of Clauses (i) to (iii). Considering that the said allowance was paid in terms of contract of employment and was upwardly revised every 2 years and there is no system of payment of dearness allowance, it was held to be dearness allowance though described differently (Special Allowance) and therefore has to be treated as a part of pay and hence order passed by PF Authority that special allowance was subject to liability of contributions under section 6 of the Act is upheld.

     

    In the year 2004, the Hon’ble High Court of Gujarat in the matter of Gujarat Cypromet Ltd Vs APFC [2004 III CLR 485] also held that the contribution to Provident Fund made on basic wages includes all emoluments earned by the employee and allowances like lunch allowance, medical allowance, conveyance allowance etc., except those which are specifically excluded by the legislature, such as house rent allowance which is clearly excluded from the definition of basic wages by virtue of Section 2(b).

     

    It could be seen from the above the judiciary has interpreted the term ‘basic wages’ to include all allowances which are not specifically excluded. This interpretation has major cost implications to industry.

     

    The establishments have been engaging employees through contractors and agencies to meet the non-core activities of the industry such as Security, House Keeping etc., In addition to this, during the last one decade, the establishments started engaging manpower through outsourcing agencies to meet the work requirements without having long term liability. The number of such employees have increased substantially in the recent past. Most of these employees are paid applicable minimum wages. The outsourcing agencies in general bifurcate the minimum wages as basic wages, house rent allowance and conveyance allowance etc.,

     

    The E P F authorities have come to the view that the employers are bifurcating the minimum wages with a view to avoid payment of provident fund contributions and this led to litigation across India. The Hon’ble High Court of Andhra Pradesh issued a stay order on the circular issued by the PF Department on this issue. The Division Bench of Punjab & Haryana held that the definition of wages under Minimum Wages Act is inapplicable to that of basic wages under EPF Act.

     

    The decisions of the Hon’ble High Courts, which are discussed above and similar other matters are pending before the Hon’ble Supreme Court of India for disposal. We have to await the decision of the Apex Court on these matters.

     

     

    The courts have also held that certain category of payments does not fall under the ambit of basic wages and does not attract provident fund contributions. They are:-

     

    The Supreme Court held that the Production Bonus / Incentive when paid in a sliding scale with due regard to the production made by each workman then no contribution is payable. Similarly if the production bonus is paid on an average to all workmen on the basis of extra production made by them, then also, no contribution need be paid. [Daily Pratap Vs RPFC 1999 I LLJ 1]

     

    The Madras, Delhi and Gujarat High Courts held in various matters that the ad-hoc allowance and ad-hoc payments made to employees does not form part of ‘basic wages’ and hence no contributions are payable.

     

    The Hon’ble High Court of Bombay held that payment made in lieu of notice for terminating the contract of employment of a permanent employee does not constitute ‘basic wages’ and hence no contributions are payable. The Gujarat High Court in the matter of Swastik Textile Engineers Vs V M Rathod [2008 II LLJ 533] held that the back wages awarded by Court cannot be regarded as ‘basic wages’ payable to the employee and it is in the form of damages or compensation and hence provident fund contributions are not required to be paid.

     

    The Supreme Court held that Leave Encashment should not be taken as part of ‘basic wages’ and hence no provident fund contributions are payable.

     

    The Hon’ble High Court of Madras in the matter of Wipro Ltd Vs PO Employees PFAT [[2007 LLR 624] held that the canteen subsidy is not equivalent to cash value of food concession and hence provident fund contributions are not payable on canteen subsidy.

     

    With effect from 1.9.2014, employees drawing basic wages, dearness allowance and retaining allowance of Rs. 15,000/- or below are liable to be covered under the provident fund scheme. Once covered employee will continue to get covered even though his wages exceed Rs. 15,000/- per month. The Supreme Court in the matter of Marathwada Gramin Bank Karamchari Sanghatana Vs Management of Bank [2011 LLR 1130] held that employers need not pay provident fund contributions higher than the prescribed limited under the Act and Scheme that is now Rs. 15,000/-.

     

    Most of the new generation organisations are following the concept of cost to the company of the employee and the compensation package is decided on annualised basis. As the organisations are deciding the cost to the company, it has all the freedom to bifurcate the mutually agreed compensation package. Say for example the annual CTC is Rs. 2.90 Lacs, the monthly wages can be defined as Basic: Rs. 15,000/-, HRA 40% of the Basic Salary ie Rs. 6000/- and the employer Provident Fund contribution as Rs. 1800/-. Thus the monthly cost to the company is Rs. 22,800/- and annual cost is Rs. 2, 73, 600/-. In view of the recent amendment to the Payment of Bonus Act, the employee with basic wages of Rs. 15,000/-will also be covered under the Act. Hence the employee will be entitled to at least 8.33% of the basic wages earned in the financial year which translates to one month basic wage of Rs. 15,000/-. Thus the annual cost to the company will be Rs. 2, 88, 600/-.

     

    When the CTC offered to an employee is higher than the Rs. 2.9 lacs per annum, other allowances such as conveyance allowance, medical reimbursement etc., may be introduced.

     

     

    In case of employees whose monthly wages are minimum wages, it would be advisable to bifurcate the minimum wage as basic wages and house rent allowance only. For example if the minimum wage is Rs. 10,010/- per month the same may be bifurcated as Rs. 7150/- as basic wage and 40 percent of basic wage as HRA ie Rs. 2860/-. The cost to the company per annum would be Rs. 1, 43, 272/- which includes statutory minimum bonus of 8.33%, 12% of PF and 4.75% of ESI contributions.

     

    If the monthly wages are above minimum wage and below Rs. 22,800/- per month, that is the annual cost to the company is between Rs.1.45 lacs and Rs. 2.9 lacs, the applicable minimum may be taken as basic and the balance wage be bifurcated as HRA, Conveyance Allowance, Washing Allowance and Medical Reimbursement etc.,

     

    In the above mentioned cost to the company, the liability that may arise on account of Payment of Gratuity Act is not included.

     

    Of late the highly reputed and law abiding employers are also finding it difficult to convince the provident fund enforcement authorities the method followed by them in finalising the compensation package of the employees during the 7A proceedings and the matters are going against them. This has led to large scale litigation in the Tribunal and also depositing a part of the amount determined in the 7 A proceedings by the Qasi Judicial Authority by the company. The cost of litigation has also become substantial besides monitoring the maters under litigation which may become major liability on the company at a later date.

     

    In view of the above analysis, it is suggested that organisations may consider to restructure the salaries of the employees, as suggested above, to ensure litigation free statutory compliance under Provident Fund Act, Payment of Bonus Act and the Minimum Wages Act.

     

     

    Tags:

     

     

     

     

    Contributed by CS DVK Phanindar

     

     

     

     

     

     

     

    Sl.

    Section(s) under the CA,

    Clause No. in the

    Proposed amendment relating to

    Remarks/Comments/Penalty

     

    No.

    2013, amended

    Amendment Bill

     

     

     

     

     

     

     

     

     

    30.

    Section 123

    31

    Substitution  of  sub-section  (3)of  Section  123  to  allow

    Welcome  amendment,  as  it

     

     

    Declaration of Dividend

     

    declaration and payment of interim dividend, during the

    allows  a  new  criteria  for

     

     

     

     

    period from closure of financial year till date of Annual

    declaration of Interim Dividend,

     

     

     

     

    General Meeting for a financial year, and out of the profits of

    and  clarity  on  the  rate  of

     

     

     

     

    the said year; or from the surplus in the profit and loss

    dividend  in  the  absence  of

     

     

     

     

    account; or out of profits generated in the financial year till

    profits.

     

     

     

     

    the quarter preceding the date of declaration of the interim

     

     

     

     

     

    dividend.

     

     

     

     

     

    In addition to the above, the substitution also prescribes the

     

     

     

     

     

    rate at which the interim dividend can be declared, in case of

     

     

     

     

     

    loss is incurred during the financial year.

     

     

     

     

     

     

     

     

    31.

    Section  129  -Financial

    32

    Substitution of sub-section (3) of section 129, in connection

    Amendment/inclusion to

     

     

    Statements

     

    with preparation of Consolidated Financial Statements in the

    remove ambiguity.

     

     

     

     

    same form and manner as that of its own in accordance with

     

     

     

     

     

    applicable accounting standards, for associate companies

     

     

     

     

     

    also in addition to subsidiary.

     

     

     

     

     

     

     

     

    Sl.

    Section(s) under the CA,

    Clause No. in the

    Proposed amendment relating to

    Remarks/Comments/Penalty

     

    No.

    2013, amended

    Amendment Bill

     

     

     

     

     

     

     

     

     

     

    32.

    Section – 130 –

    Accounts

    33

    Amendment to sub-section (1) of Section  130, so as to

    Welcome amendment, as there

     

     

    Re-opening

    of

     

    provide that in addition to authorities already specified in the

    is  a  increased  scope  of

     

     

    on Court’s

    or

    Tribunal’s

     

     

     

    section, any other person concerned shall be given notice

    authorities, to whom notice as

     

     

    Orders (Section notified

     

     

     

    before passing an order for re-opening of accounts.

    to re-opening of accounts is to

     

     

    w i t h  e f f e c t  f r o m

     

     

     

     

     

     

     

    be given by the Tribunal; and

     

     

    01.06.2016)

     

     

     

     

    Insertion of a new sub-section (3) to provide that no order

     

     

     

     

     

     

    also  giving  the  periods  for

     

     

     

     

     

     

     

    shall be made for re-opening of books of account relating to a

    which order can be given by

     

     

     

     

     

     

     

    period  earlier  than  eight  financial  years  immediately

    Tribunal,  for  re-opening  of

     

     

     

     

     

     

     

    preceding the current financial year, unless there is a specific

    accounts.

     

     

     

     

     

     

     

    direction under section 128(5) [i.e., maintenance of books of

     

     

     

     

     

     

     

     

    accounts] from the Central Government for longer period.

     

     

     

     

     

     

     

     

    33.

    Section 132- Constitution

    34

    Amendment (reduction) of the minimum penalty that can be

    Welcome amendment.

     

     

    of  National

     

    Financial

     

    levied by way of an order by NFRA on CA Firms, if professional

     

     

     

    Reporting

     

    Authority

     

    or other misconduct is proved from Rs. 10 Lakhs to Rs.5 Lakhs.

     

     

     

    (NFRA). (Section yet to

     

     

     

     

     

    be notified)

     

     

     

     

     

     

     

     

     

     

     

     

     

     

     

    34.

    Section 134

    Financial

    35

    Substitution of sub- section (1)of section 134, with a new

    Welcome amendment as the

     

     

    statements

    &  Board

     

    section, thereby removing the requirement that the CEO signing

    proposed amendments reduce

     

     

    Report

     

     

     

     

    the financials shall be a Director, and accordingly, a CEO shall

    the reporting requirements in

     

     

     

     

     

     

     

    now sign financial statements irrespective of whether he is a

    the Board Report.

     

     

     

     

     

     

     

    director or not.

     

     

     

     

     

     

     

     

    Amendments to sub-section (3) of section 134 seeks to modify

     

     

     

     

     

     

     

     

    the disclosure requirements with respect to (a) removal of the

     

     

     

     

     

     

     

     

    requirement of attaching the extract of annual return to the

     

     

     

     

     

     

     

     

    Board report, and just mentioning the web-address, if any,

     

     

     

     

     

     

     

     

    where the extract of annual return is placed is to be mentioned

     

     

     

     

     

     

     

     

     

     

     

    Sl.

    Section(s) under the CA,

    Clause No. in the

    Proposed amendment relating to

    Remarks/Comments/Penalty

     

    No.

    2013, amended

    Amendment Bill

     

     

     

     

     

     

     

     

     

     

     

     

     

     

    (b)amendment to clause (p) of the sub-section relating to

     

     

     

     

     

     

    statement  on  annual  performance  of  the  Board,  its

     

     

     

     

     

     

    committees and independent directors by the companies to

     

     

     

     

     

     

    which the provision is applicable(c)mentioning only the salient

     

     

     

     

     

     

    features of the Remuneration and nomination policy (Section

     

     

     

     

     

     

    178) and CSR policy( Section 135) in the Board Report, and

     

     

     

     

     

     

    providing the web-address where  the complete policy is

     

     

     

     

     

     

    available.

     

     

     

     

     

     

    Insertion of a new section 3A, which empowers the Central

     

     

     

     

     

     

    Government to prescribeabridged Board's report for small

     

     

     

     

     

     

    company and one person company.

     

     

     

     

     

     

     

     

     

     

    35.

    Section - 135 – Corporate

    36

    Amendment to sub-section (1) of section 135,with regard to

    Amendment  to

    remove

     

     

    Social Responsibility.

     

    the period for which the criteria for applicability of CSR to a

     

     

    ambiguity  and

    ease  of

     

     

     

     

    Company (i.e., Turnover, Net worth & Net Profit) are to be seen

     

     

     

    operations.

     

     

     

     

     

    from “any financialyear” to “immediately preceding financial

     

     

     

     

     

     

     

     

     

     

     

    year”.

     

     

     

     

     

     

    Insertion of a proviso to sub-section (1) regarding composition

     

     

     

     

     

     

    of CSRcommittee with two or more directors, by a company

     

     

     

     

     

     

    which is not required to appointindependent director under

     

     

     

     

     

     

    section 149.

     

     

     

     

     

     

    Amendment of Clause (a)  in sub-section (3) with regard to

     

     

     

     

     

     

    areas in which CSR activity can be undertaken "as specified in

     

     

     

     

     

     

    Schedule VII", the words and figures "in areas or subject,

     

     

     

     

     

     

    specified in Schedule VII", thereby providing more scope in

     

     

     

     

     

     

    the CSR activities.

     

     

     

     

     

     

     

     

     

     

    Sl.

    Section(s) under the CA,

    Clause No. in the

    Proposed amendment relating to

    Remarks/Comments/Penalty

     

    No.

    2013, amended

    Amendment Bill

     

     

     

     

     

     

     

     

     

     

     

     

     

     

    Amendment to the explanation given in sub-section (5) earlier

     

     

     

     

     

     

    with regard to “Average Net profit”, now changed to “Net

     

     

     

     

     

     

    profit”, and further to empower the CentralGovernment to

     

     

     

     

     

     

    prescribe sums which shall not be included for calculating 'net

     

     

     

     

     

     

    profit' of a Company for the purpose of section 135.

     

     

     

     

     

     

     

     

    36.

    Section  - 136 – Right of

    37

    Amendment to sub-section (1) of section 136 by inserting a new

    Welcome amendment.

     

     

    member

    to  copies  of

     

    proviso to provide that copies of audited financial statements

     

     

     

    a u d i t e d

    f i n a n c i a l

     

    and other documents can be sent at shorter notice if 95 % of

     

     

     

    statement.

     

    members entitled to vote at the meeting agree for the same;

     

     

     

     

     

     

    and  accordingly  aligning  the  existing  provisos,  after  the

     

     

     

     

     

     

    insertion.

     

     

     

     

     

     

    Substituting the existing 4th proviso to Sub-section (1) with new

     

     

     

     

     

     

    proviso,   to rationalise the requirements with respect to

     

     

     

     

     

     

    financial statements of foreign subsidiaries of a listed company

     

     

     

     

     

     

    subject to conditions.

     

     

     

     

     

     

    Insertion of a proviso to Sub-section (2) thereby companies

     

     

     

     

     

     

    having subsidiaries to provide financials of the subsidiary for

     

     

     

     

     

     

    inspection by the member who asks for it.

     

     

     

     

     

     

     

     

     

    37.

    Section  –  137  –  Copy

    38

    Insertion of a new proviso after the existing 4th proviso to sub-

    Welcome amendment.

     

    section (1)   so as to enable filing of unaudited financial

     

     

     

    offinancialstatement

     

     

     

     

    tobe filed with

     

    statements by listed companies, of their foreign subsidiaries

     

     

     

    Registrar.

     

     

    which is not required to get its accounts audited, under the laws

     

     

     

     

     

     

    of the country of incorporation.  The filing of unaudited

     

     

     

     

     

     

    financial statements are to be accompanied by a declaration by

     

     

     

     

     

     

    the listed company, to the above effect.

     

     

     

     

     

     

     

     

     

    Sl.

    Section(s) under the CA,

    Clause No. in the

    Proposed amendment relating to

    Remarks/Comments/Penalty

     

    No.

    2013, amended

     

     

    Amendment Bill

     

     

     

     

     

     

     

     

     

     

     

     

     

     

    38.

    S e c t i o n

    1 3 9

    39

    Omission  of  the  first  proviso  to  sub-section  (1),  i.e.,

    Welcome amendment.

     

     

    Appointment of Auditors

     

    ratification of the appointment of auditors by the members at

     

     

     

     

     

     

     

     

    every AGM.

     

     

     

     

     

     

     

     

     

     

     

    39.

    S e c t i o n

    1 4 0

    -

    40

    Amendment to sub-section (3) of section 140 to reduce the

     

     

    penalty/penalty  criteria,  withrespect  to  failure  to  file

     

     

     

    Removal,resignation

    of

     

     

     

     

    auditor and giving of

     

     

    resignation form (ADT-3) by auditor to the Registrar concerned

     

     

     

    Specialnotice

     

     

     

    and also to the Comptroller and Auditor General (CAG) for the

     

     

     

     

     

     

     

     

    applicable companies, from  the existing  “Rs.50,000/-“ to

     

     

     

     

     

     

     

     

    “Rs.50,000/-or  the remuneration of auditors whichever is

     

     

     

     

     

     

     

     

    less”.

     

     

     

     

     

     

     

     

     

     

     

    40.

    Section – 141 - Eligibility,

    41

    Insertion of an explanation to clause (d) of sub-section (3) of

    Amendment to remove

     

    section 141, to clarify the meaning of relative with reference to

     

    Qualifications and

     

     

    eligibility for appointment of auditors.

    ambiguity.

     

     

    disqualifications of

     

     

     

     

     

     

     

     

     

     

     

    auditors.

     

     

     

     

    Substitution of the existing clause (i) of sub-section (3) along

     

     

     

     

     

     

     

     

     

     

     

     

     

     

     

     

    with explanation, for harmonisation with section 144 in respect

     

     

     

     

     

     

     

     

    of providing of certain non-audit services to holding or

     

     

     

     

     

     

     

     

    subsidiary company of a company.

     

     

     

     

     

     

     

     

     

     

     

    41.

    Section 143 - Powers and

    42

    Amendment to sub-section (1) of section 143 of the Act to

    Amendment to remove

     

    include   associate  companies  in  addition  to  subsidiary

    ambiguity.

     

     

    duties  of

    auditors  and

     

     

     

    companies with respect to right of auditors to have access to

     

     

     

    auditing standards.

     

     

     

     

     

     

     

    accounts and records for the purpose of consolidation.

     

     

     

     

     

     

     

     

     

     

     

     

     

     

     

     

    Amendment to clause (i) of sub-section (3) to provide that

     

     

     

     

     

     

     

     

    auditors shall report on internal financial control systems

     

     

     

     

     

     

     

     

    relating to financial statements.

     

     

     

     

     

     

     

     

    Amendment to sub-section (14) to replace the term “cost

     

     

     

     

     

     

     

     

    accountant in practice” with “cost accountant”.

     

     

    Sl.

    Section(s) under the CA,

    Clause No. in the

    Proposed amendment relating to

    Remarks/Comments/Penalty

     

    No.

    2013, amended

    Amendment Bill

     

     

     

     

     

     

     

     

     

    43

    Section 148 - Central

    44

    Amendment to substitute the words 'cost accountant in

    Amendment to remove

     

     

    Government to specify

     

    practice' with the words 'cost accountant' in sub-section (3)

    ambiguity.

     

     

    audit of items of cost in

     

     

     

    & (5) of Section 148 and also to substitute the words 'Institute

     

     

     

    respect of certain

     

    of Cost and Works Accountants of India' with the words

     

     

     

    companies.

     

     

     

     

     

    'Institute of Cost Accountants of India',in the explanation to

     

     

     

     

     

     

     

     

     

     

    Sub-section (3) of Section 148.

     

     

     

     

     

     

     

     

    44

    Section 149 -

    45

    Amendment to Sub-section (3) of Section 149, relating to the

    Welcome  Amendment  to

     

     

     

     

    requirement of resident director, the amendment proposed

    remove ambiguity and ease of

     

     

     

     

    requires that “every company shall have at least one director

    operations.

     

     

     

     

    who stays in India for a total period of not less than 182 days

     

     

     

     

     

    during the financial year”instead of the existing requirement

     

     

     

     

     

    of “shall have at least one director who has stayed in India for

     

     

     

     

     

    a total period of not less than 182 days in the previous

     

     

     

     

     

    calendar year.”

     

     

     

     

     

    Further the amendment proposes that in case of a newly

     

     

     

     

     

    incorporated company the requirement under this sub-section

     

     

     

     

     

    shall apply proportionately at the end of the financial year in

     

     

     

     

     

    which it is incorporated.

     

     

     

     

     

    Amendment to clauses in sub-section (6) of Section 149, to

     

     

     

     

     

    specify limits with respect to pecuniary relationship of a

     

     

     

     

     

    director with respect to eligibility of a director to be appointed

     

     

     

     

     

    as an independent director. It also seeks to specify the scope of

     

     

     

     

     

    restriction on pecuniary relationship entered into by a relative.

     

     

     

     

     

     

     

     

     

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