Residential Status Of An Individual

1. Resident (Ordinary Resident) [Section 6(1)]

To determine the residential status of an individual, section 6(1) prescribes two tests. An individual who fulfils any one of the following two tests is called Resident under the provisions of this Act. These tests are :

(a) If he is in India during the relevant previous year for a period amounting in all to 182 days or more.

(b) If he was in India for a period or periods amounting in all to 365 days or more during the four years preceding the relevant previous year and he was in India for a period or periods amounting in all to 60 days or more in that relevant previous year.

Explanation—
(a) In case of individual being a citizen of India who leaves India in any previous year as a member of the crew of an Indian ship as defined i.n clause (18) of section 3 of the Merchant Shipping Act 1958 (44 of 1958) or for the purposes of employment outside India the provisions of sub clause (b) as given above shall apply in relation to that year as if the words “sixty days” have been Substituted by “182 days “.

(b) In case of an individual being a citizen of India, or a person of Indian origin within the meaning of explanation to clause (e) of section 115 C, who being outside India, comes on a visit to India in any previous year, the provisions of sub-clause (b) shall apply in relation to that year as if for he words. ‘Sixty days occurring therein the words One hundred and eighty two days had been substituted.’

After fulfilling one of the above two tests, an individual becomes resident of India but to become an ordinary resident of India an individual has to fulfill both the following two conditions :

(1) He has been resident of India (fulfilling at least one test given above) in at least 2 previous years out of 10 previous years immediately prior to the previous year in question.

(2) He has stayed in India for at least 730 days in 7 previous years immediately preceding the previous year in question.
This means that an individual will not become an ordinary resident of India by simply staying in India for a period of 182 days or more in a previous year. He will become ordinary resident only if. he fulfills one of these two tests and was also fulfilling one of the tests in at least 2 previous years pieceding the relevant previous year and did stay in India for at least 730 days in 7 previous years preceding the relevant previous year.

While calculating number of days for stay in India, day of departure was not included. But now as per decision of Authority for Advance Rulings, both, day of departure from India and day of arrival in India are to be counted as stay in India.

Tests Explained

Test No. 1. Stay in India for 182 days or more :

If an individual is to become resident of India during any previous year, his/her personal stay in India during that year is a must although the number of days of stay differs in the two tests. It means that if an individual does not stay in India at all in any previous year, he cannot be resident of India in that year. Stay in India means that the individualshould have stayed in Indian territory and anywhere (cities, villages, hills, even Indian territorial waters) for such number of days.

The period of 182 days need not be at a stretch. But physical presence for an aggregate of 182 days in the relevant previous year is enough. The status of resident is not linked with any particular place or town or house.
The onus to prove the number of days of stay in India lies on the assessee. It is for him to prove, if he desires to be taxed as non-resident or not ordinarily resident.

Test No. 2. Presence for 365 days during the four preceding previous years :
A person may be a frequent visitor to India. In his case, the residential status will be determined on the basis of his presence in India for 365 days in four years immediately preceding the relevant previous year. Along with this his presence for 60 days during the relevant previous year is another essential condition to be fulfilled. The purpose, object or reason of visit to and stay in India has nothing to do with the determination of residential status.
For Indian citizen going abroad on a job or as a member of crew of an Indian ship [Explanation (a)]

In case of an Indian citizen :
(a) Who is going outside India for a job and his contract for such employment outside India has been approvedby the Central Government ; or
(b) He is a member of crew of an Indian ship ;
test (a) u/s 6(1) remains the same but in test (b) 60 days have been replaced by 182 days.

The practical effect of this explanation is that in case of persons of Indian citizenship going abroad on a job approvedby the Central Government only test (a) is to be applied during the year he is leaving India.
For Indian citizens and persons of Indian origin [Explanation (b)]
For such persons test (a) remains the same but in test (b) words ‘60 days’ have been replaced by 182 days.

The practical effect of this provision is that those persons who are Indian citizens or persons of Indian origin living outside India and when they come to visit India only test (a) of 6 (1) is to be applied.
A person shall be deemed to be of Indian origin if he or either of his parents or any of his grand parents was born in India or undivided India [Section 115 (c) explanation to clause (c)]

2. Resident But Not Ordinarily Resident

An individual who is resident u/s 6(1) can claim the beneficial status of N.O.R. if he can prove that :

(a) He was non resident in India for 9 previous years out of 10 previous years preceding the relevant previous year.
OR

(b) He was in India for a period or periods aggregating in all to 729 days or less during seven previous years preceding the relevant previous year.
An individual who is Resident u/s 6(1) can be subdivided into two categories :
(a) Ordinary Resident ; or (b) Not ordinarily Resident

Ordinary Resident Resident But Not Ordinarily Resident
(a) He was in India for a period or periods totaling in all to 182 days or more during relevant previous year.

OR

(b) He was in India for a period or periods totaling in all to 60 days or more during relevant previous year and 365 days or more during four previous years preceding the relevant previous year.

And

Must be resident of India (by fulfilling at least one of two above mentioned tests) in at least 2 out of 10 previous years preceding the relevant previous year.

And

Must have stayed in India for 730 days or more during 7 previous years preceding the relevant previous year. (a) He was in India for a period or periods totaling in all to 182 days or more during relevant previous year

OR

(b) He was in India for a period or periods totaling in all to 60 days or more during relevant previous. year and 365 days or more during four previous years preceding the relevant previous year.

And

Was non-resident in India in 9 or 10 previous years out of 10 previous years preceding the relevant previous year.

OR

Was in India for less than 730 days during 7 previous years preceding the relevant previous year.

To Summarise :
Ordinary Resident = Satisfying any one of two conditions given u/s 6(1) + Satisfying both the additional conditions of Sec. 6(6)(a)&(b)
Not Ordinarily Resident = Satisfying any one of the two conditions u/s 6(1) + Satisfying none or any one of the additional conditions
3. Non-resident [Section 2(30)]
Under section 2(30) of the Income-tax Act, 1961 an assessee who does not fulfil any of the two conditions given in section 6(1)(a) or (b) would be regarded as ‘Non-resident’ assessee during the relevant previous year for all purposes of this Act.

Important Points
(i) Meaning of Stay in India
It means stay any where within Indian geographical territory, i.e., any where in Indian villages, towns, cities, waters or mountains.
(ii) Stay may be continuous or intermittant
Stay in India for specified days should not necessarily be continous. It means a person is not required to stay 182 days at a stretch as per Sec. 6(1), i.e., a person stays in India in the months of April, May and June and then left India and stayed for 5 months in a foreign country and then came back and stayed in India upto 31st March. In such a case the stay in India will be counted by adding stay in India on each different occasion.
(iii) Stay need not be at one place
A person must stay within Indian territory and where he stays is not an important cods4deration.
(iv) Object of stay is not important
It is immaterial whether he stays in India for business purposes or on a personal purposes or visits India as a tourists.
(v) Calculation of ‘period of stay’ in India
The ‘period of stay’ in India is to be calculated on the basis of actual stay of an individual in India during the relevant previous year. Thus, if a person stays in India for a part of the day (i.e., for certain hours etc. only) then period of stay in India is to be calculated on hourly basis. Thus, a stay of 24 hours will be taken as stay of one day and total hourly stay in India will be converted into days.
However, if detail of hourly stay in India is not available then period of stay in India is to be calculated in days. It is important to note that while calculating the period of stay in India (in days), both the day of departure from India and the day of arrival in India are to be counted as stay in India. [As per the decision of Authority for Advance Rulings—P.No. 7 of 1995).

Source : Incometax Management/Sanjay Kumar Satapathy

Posted in NRI

Income Which ‘Accrues’ Or ‘Arises’ In India under I.Tax Act.

Income can be held to accrue or arise to an assessee only when the assessee obtains a right to receive that income. No amount can be said to accrue unless it is actually due.

Accrue means “to fall as natural growth or increment, to come as an accretion or advantage” and arise means “to spring up, to come into existence” according to Oxford dictionary. It has been held that these two expressions—accrue and arise—are for all purposes synonymous. Jiwan Dass v. Commissioner of Income Tax, Lahore. [A.I.R. (1929) L4H 609].

Income accrues or arises at a place where the origin or source of growth of income is situated.

As regards salaries, income accrues or arises in India if it is earned in India.
(i) Income accrues or arises to a person, who is entitled to demand and receive the income.
(ii) Income accrues or arises at a time or date when it ripens into a debt, i.e., at that moment when assessee acquires a right to receive it.
(iii) In the case of salaried employees, the salary is earned in India if the person renders services in India. Income earned in India obviously arises in India.
(iv) In case of dealer of goods, if the purchases and sales of goods take place in India, the profits out of such sales arise in India.
(v) Profit from such transaction where goods are manufactured outside India but are sold in India will be split up into manufacturing profits and only mercantile profits, i.e., accruing from sale transaction will be income arising in India.

Source : Incometax Management

Posted in NRI

Taxation of Global Income in USA for Indians who are US Citizens, NRIs, or Green Card holders, including for EB-5 immigrants

The issue of global taxation of Indians residing in USA, or residing in India but being a US reportable person, requires comprehensive understanding of the following:

1. US tax laws which are governed by IRS;
2. Specific regulations under FATCA which covers foreign assets;
3. Provisions of FEMA in India;
4. Guidelines by the Reserve Bank of India from time to time in relation to remitting or receiving dollars; and
5. Income Tax Act, in specific, Indo-US DTAA.

Each of the above is a specialised area in itself; however, the only way to address the issues of global taxation for Indians residing or anticipating residing in America is to understand them thoroughly with a unified approach. This article aims to give a 360operspective apropos the tax intricacies for Indians who have now become US Citizens, NRIs, Green card holders & for aspiring immigrants under the EB-5 route.

The first & most imperative point to understand is that the moment you become a green card holder, global income must be reported to IRS irrespective of whether the green card holder stays in USA or abroad. Thus, a US green card holder who spent entire 365 days in India, would still need to reflect his Indian & other global income to US authorities nevertheless he being considered resident in India as well. It does not matter whether you are a provisional or permanent green card holder; and it also does not matter whether you obtained your green card organically or through the EB-5 route. It would be preposterous to keep arguing on different permutations-combinations, and trying to find a way of avoidance, because the law is very clear that all US green card holders must surrender their global income to IRS for taxation in US. It is a harsh fact that many Indians, especially provisional green card holders who are residing in India, have not been adhering to the system because a significant number of them have no clue whatsoever on the reporting requirements. In the past, this wouldn’t be a problem; but with cross-country reporting and increasing regulations for mandatory exchange of information, there has been a terrific rise in levels of transparency between the two nations. US government has already started taking actions, and a plethora of people have been officially reported to have received notices for compliance failures.

It is not possible to write down the intricacies and various different stands which an individual may take for his or her personal case, however, important provisions have been outlined below:

1. All types of foreign income, whether taxable in the foreign country or not, must be reported to IRS. There are a bunch of questions asked by clients to me, the most popular one being “Whether rental income earned in India should be reported to IRS or not”. When someone comes to me with a question like this, it only means people have misled themselves all this while. The law is very clear “Any foreign income”, and thus there is nothing further to interpret. It certainly doesn’t matter whether your source of income is rental, capital gains, or bank interest.

2. FBAR has to be filed if you have financial interest in a foreign account, and the aggregate value of all such foreign financial accounts exceeds $10,000 at any time during the calendar year. Again, do note here that reporting has to be of all the financial accounts once you touch the limit. For e.g., Mr. India, a business owner residing in California, has 4 bank accounts in India, and one bank account in Kenya. The bank account in Kenya had a balance of dollar equivalent $ 10,300 at one point during the entire financial year, whereas the bank accounts in India have a closing balance of US$ 100 each. In that case, all the foreign bank accounts would get reportable, mandatorily, under the current provisions of the Bank Secrecy Act. The reason I am quoting this example is because some people are under a misconception that only those bank accounts are reportable which have crossed the non-reportable limit.

3. Compliance under FATCA is in addition to point 2 above. Again, most NRIs are not aware that these are two completely separate reporting requirements. FBAR has been in practise for quite some time now whereas FATCA is relatively new; and importantly, it has been introduced in addition to the Report of Foreign Bank & Financial Accounts. The provisions of FATCA are applicable to US citizens, Green card holders, H1 visa holders and those persons who have resided in USA for 183 days or more in the current year OR 31 days in the current year coupled with 183 days in immediately previous 3 years. Further, to satisfy the test of 183 days, count all of the days you were present in the current year, and one-third of the days you were present in the first year before the current year, and one-sixth of the days you were present in the second year before the current year. Complex as it sounds, but not!

4. Under the provisions of FATCA, all financial interests overseas, including balance lying in bank savings account, mutual fund investments, fixed deposits, would have to reported under Form 8938 at the time of filing of your annual tax return with IRS if the value of such assets exceeds:
For taxpayers living abroad (abroad here refers to US reportable persons who are residing anywhere other than USA)

• You are not a married person and the total value of your foreign financial assets is more than $200,000 on the last day of the tax year or more than $300,000 at any time during the year. Do note that “year” refers to calendar year, and not financial year as followed in India. I come across situations quite often where people are checking their closing balances as on 31st March, which is out rightly absurd. The closing date has to that of the relevant calendar year, being 31st

• You are married & thus filing a joint income tax return. The combined value of the couple’s foreign financial assets is more than $400,000 on the last day of the tax year or more than $600,000 at any time during the year.
For taxpayers residing in USA

• You are unmarried and the total value of your foreign financial assets is more than $50,000 on the last day of the tax year or more than $75,000 at any time during the year.

• You are married & have chosen to file a joint income tax return, and the total value of your foreign financial assets is more than $100,000 on the last day of the tax year or more than $150,000 at any time during the year.
• You are married but have chosen to file a separate tax return, and the total value of your foreign financial assets is more than $50,000 on the last day of the tax year or more than $75,000 at any time during the year.
Do note that FATCA is not merely about reporting on Indian bank accounts & their balances; as it also covers other financial assets like the underlying interest in a private limited company by NRI, insurances, mutual fund investments, etc.

Failure to file Form 8938 by the due date or filing an incomplete form attracts penalty of US$ 10,000. Additional penalty of US$ 10,000 per month up to a maximum penalty of US $50,000 is payable on continuing failure to file in-spite of a notice issued by IRS.

5. One of the most frequently asked doubts is on the mechanism for obtaining credit on tax paid in India, especially for those people who have literally zero income in USA, and would still need to file a US tax return. Generally, most Indians in USA would not have an active source of income in India, other than bank interest, and few investments here and there. Unless a property is being sold which has resulted into some capital gain, I have lately seen that NRIs in general have stayed away from owning active / official partnership or stake in Indian businesses. They would not normally have the issue of obtaining tax credits every tax year. However, those Indians who are still very much residing in India, and are in the process of obtaining green card, they would need a heck of proper tax planning. For instance, Mr. Shah & his family have filed i-526 petition under the EB-5 immigration route. A few months later he received his provisional green card. The question that first comes to mind is whether he needs to start filing US tax returns from the next tax year onwards? The answer to this question is 100% yes. Nevertheless his continuing to be resident in India, and notwithstanding any other fact, he must start reporting his income in India to IRS. He can however file Form 1116 with IRS to claim credit of taxes paid to Indian government.

I am not touching the Double Taxation Avoidance Agreement between India & USA as that would require a separate article by itself. Terrific amount of relief is given to taxpayers by virtue of this treaty; a bit of planning will go a long way in saving your money legitimately.
Source :Taxguru

Posted in NRI

How much money can an Individual transfer out of India?

The Reserve Bank of India (RBI) in its monetary policy review enhanced the limit under Liberalized Remittance Scheme (LRS) to $250,000 per person per year from existing limit of 125,000 USD.

RBI had reduced the eligibility limit for foreign exchange remittances under LRS to $75,000 in 2013 as a macro-prudential measure. With stability in the foreign exchange market, this limit was enhanced to $125,000 in June 2014 without end-use restrictions, except for prohibited foreign exchange transactions such as margin trading, lotteries and the like.

It was in 2004 that the Reserve Bank of India (RBI) announced the Liberalized Remittance Scheme to facilitate the Indian Residents to transfer funds abroad without its prior permission.

Under this scheme, all resident individuals, including minors, are allowed to freely remit up to USD 2,50,000 (or its equivalent freely convertible foreign currency) per financial year (April – March).

This scheme is applicable to people like you and me; not for NRIs. If you wish to send money abroad for the following purposes, you can do so without the prior approval of RBI

Purpose of remittance:
• For travel, studies, medical treatment etc.
• To acquire shares or debt instruments in listed or unlisted companies or any other assets including acquisition of immovable property directly or indirectly outside India
• To invest in Mutual funds, Venture funds, unrated debt securities, promissory notes, etc
• To gift or to give donations
• To acquire ESOPs in overseas companies (in addition to acquisition of ESOPs linked to ADR/GDR)
• Repayment of loan taken while an individual was a Non Resident Indian
• To open, maintain and hold foreign currency accounts with banks outside India for carrying out any permitted transactions
Prohibited transactions: Some of them are –
• Purchase of lottery tickets/sweep stakes!
• To use as margin money for trading in overseas stock exchanges
• To use for trading in overseas stock exchanges
• To purchase Foreign Currency Convertible Bonds (FCCB) issued by Indian Companies abroad
• For setting up a company abroad ( however, with effect from August, 2013, to set up a Joint Venture or a Wholly Owned Subsidiary outside India is permitted)
• Remittance directly or indirectly to Bhutan, Nepal, Mauritius and Pakistan

FAQ
Q1: A Resident individual gifts money in Indian rupees to their NRI relatives and such amount is credited to the NRO account of the relative for an onward transfer outside India. Is the overall limit of USD 125000 applicable for this transaction?
Yes. Gift in Indian rupees (by way of crossed cheque or electronic transfer) is also to be considered while calculating the overall limit of USD 125000

Q2: Can Resident Individual give loans to NRIs?
Yes. The resident individual can lend money by way of crossed cheque or electronic transfer within the overall limit of USD 125000 per financial year. However, the loan should not be remitted out of India. Secondly the loan should be interest free and have a maturity of minimum one year.

Q3: Should the interest or dividend earned on overseas investments be remitted back to India?
No. the investment along with interest or dividend can be retained and reinvested abroad.

Q4: Can the resident Individual open bank account abroad?
Yes. Resident Individuals are allowed to open and hold bank accounts abroad.
Source : Simplifiedlaws

Posted in NRI

Can Non Resident Indian (NRI) invest in Partnership firm or a proprietary concern?

The applicable rules for investment in a partnership firm or a proprietary concern under FEMA are summarized below –

Automatic route –
As per FDI policy of India, A Non-Resident Indian (NRI) or a Person of Indian Origin (PIO) resident outside India can invest by way of capital of a firm or a proprietary concern in India on non-repatriation basis, provided
• the amount is brought in by inward remittance or out of NRE/FCNR(B)/ NRO account
• the amount should come as capital of the firm. No loan or grant is permitted.

Approval route –
In case NRI/PIO wants to repatriate the funds from the firm, then prior permission of Reserve Bank of India (RBI) has to be sought before investing the amount in the firm.

Prohibited sectors
The firm where the investment to be done should not be engaged in any agricultural or plantation or real estate business or print media sector.
The list of prohibited sectors –
• Business of chit fund, or
• Nidhi company, or
• Agricultural or plantation activities, or
• Real estate business, or construction of farm houses, or
• Trading in Transferable Development Rights (TDRs).
• It is clarified that “real estate business” means dealing in land and immovable property with a view to earning profit or earning income there from and does not include development of townships, construction of residential / commercial premises, roads or bridges, housing, hotels, resorts, educational institutions, recreational facilities, city and regional level infrastructure, townships.
However, the construction of small commercial building is not covered in the above permitted activity for foreign investors! (means the below conditions are not applicable to NRIs) The investment will be subject to the following conditions –

Condition A: Minimum Area under development
• In case of development of serviced housing plots, a minimum land area of 10 hectares
• In case of construction-development projects, a minimum built-up area of 50,000 sq.mts
• In case of a combination project, any one of the above two conditions would suffice.

Condition B: Minimum amount to be invested in the project
• 10 Million USD for wholly owned subsidiary
• 5 Million USD for Joint Venture projects
• The entire amount should be brought in within 6 months of commencement of business of the company

Condition C: Restriction on Repatriation, completion of the project:
• The entire amount brought into the project can’t be repatriated before 3 years from the date of last installment of remittance into India.
• At least 50% of the project must be developed within a period of 5 years from the date of obtaining all statutory approvals.

Source : Simplifiedlaws

Posted in NRI

Things you must know about Income Tax before buying property from Non Resident Indian (NRI)

1. Check whether the seller has PAN: Seller has to necessarily obtain Permanent Account Number (PAN). So, at the time of finalizing the transaction, we suggest you to take a copy of PAN card of the seller. If the seller is not having one, he has to apply for PAN Card.

2. TDS @ 20.60% – If you are buying property (such as site or house or flat) from a NRI, you have to do TDS (Tax Deducted at Source) @ 20% on the sale value of the property. Suppose, you are buying a residential site at Bangalore for Rs.1,00,00,000, then you have to pay Rs.80,00,000 in favor of seller and Rs.20,00,000 in favor of Income Tax department.

3. Obtain TAN – After deducting tax (TDS) you have to remit it to Income Tax department. To remit you have to obtain Tax Deduction Account Number (TAN) from Income Tax department. While remitting the amount you have to quote TAN as well as PAN number of the seller.

4. File e-TDS return and Issue Form 16A – After deduction of tax (TDS), the buyer has to file a statement called e-TDS (Form 27Q). Within 30 days from the end of the month in which the payment is made, Form 16A has to be issued to the seller.

5. What if no TDS is done? The buyer will have to pay an amount equal to the amount of tax not deducted to the Income Tax department.

6. Option for Lower deduction of Tax – The seller or the buyer can apply to Income Tax department (International Tax Ward) for determination of the amount of tax on capital gain. Based on the certificate of lower deduction issued by the Income Tax Officer, the seller can deduct lower taxes. Suppose, the Sale Price is Rs.1,00,00,000 and the indexed cost of purchase of the site is Rs.80,00,000, the difference of Rs.20,00,000 is called as capital gain. On getting a certificate from the Officer stating that the capital gain is Rs.20 Lakhs, the seller can deduct 20.60% on Rs.20 Lakhs.

7. Chartered Accountant Certificate–won’t do for lower deduction of tax. The seller has no option other than obtaining lower deduction certificate from the Income Tax officer. In the event the seller/buyer fails to obtain the certificate, TDS to be done at 20.60% on the sale value.

Source:Simplifiedlaws

Posted in NRI

Buying property from NRI and consequence of Non Deduction of Tax

Purchase of property in India from Non-Resident Indians (NRI) is a bit tricky when compared to buying it from Resident Indians.

TDS at the time of buying the property – You may be aware about Tax Deduction at Source (TDS) to be done at the rate of 20.6% in case the sale price is less than Rs.1 Crore or 22.66% in case the sale price is over Rs.1 Crore.

Non Deduction of Tax – You or your consultant have no power to reduce TDS percentage. Only Income Tax Officer (ITO) is authorized to reduce TDS percentage. For this one has to apply (buyer or seller) to ITO and get the certificate. You can read How to obtain TDS exemption certificate from Income Tax officer to know more about it.

Consequences of Non Deduction of Tax – Suppose you failed to deduct tax (TDS) and paid the entire sale consideration to the seller at the time of buying the property. You will have trouble from Tax department. The department can paint you as ‘Assessee in default’ and recover the entire tax dues from you.

What will happen if the taxes are paid by the seller directly?
This can be explained through two examples –

Example A: Let’s assume that you are buying a property from Mr.Duniya (a NRI) for Rs.1.20 Crores on 25th May 2014. As per the law, you are obliged to deduct tax (TDS) at the rate of 22.66%, i.e Rs.27,19,200 and remit it to the government. The balance amount of Rs.92,80,800 to be paid to the seller.
Suppose, you failed to deduct the tax, but the seller has paid the entire tax on, say 10th July 2014. In such case, the department can’t ask you to pay the taxes again. Once the applicable taxes are paid by the seller, the department will condone the default of non deduction of tax.

Example B: Suppose, in the above example, the seller pays the applicable taxes in June, 2015 (at the time of filing his income tax return). Then the department can levy interest at the rate of 12% simple interest u/s 201(1A) till the date of payment of taxes by the seller. In this case, the seller was supposed to pay taxes as advance tax during the financial year 2014-15. Since he has not paid it, the buyer has to pay Rs.3,26,304 (for 12 months i.e., from June 2014 to June 2015 at 12% p.a)

Apart from the interest, the department can also levy penalty u/s 271C towards ‘failure to deduct tax at source’. The penalty amount is equal to tax deducted or paid!

Precautions to be taken – We suggest all readers of this article to take note of these aspects seriously. Please be aware that the department will come back after couple of years and not in the year of sale! The non-compliance of TDS provisions will cost the buyer heavily.

Source : Simplifiedlaws

Posted in NRI