Update
|
|
|
< Ajay Shah's blog: Consumer protection in Indian finance ...
itat on CAs' tax practice
Vijay V. Meghani vs. ACIT (MA By ICAI) (ITAT Mumbai)
Strictures passed against ICAI By ITAT for
alleged “deteriorating standards” and
“losing its grip over the Income tax matters”
toned down on the basis that they were made in the context
of a "hypothetical situation" and were not
"intended to criticize the functioning of the
ICAI"
The Income tax Appellate Tribunal, being a part of
Government of India, should not shut its eyes when it is
noticed that certain developments occurring in the Country
may affect the Country as a whole, more particularly when
the reputation of particular profession, from whom the
Tribunal is getting assistance in the dispensation of
justice, is at stake. Accordingly, we sincerely believe that
it is the bounden duty of not only the Tribunal, but also
the duty of one and all to point out and discuss about such
kind of developments, when it is noticed that the same may
affect the public at large. There cannot be any controversy
that the interest of our Country is Supreme and no citizen
can or should compromise on the same
JULY 16
Citizenmat
In other news...
|
A
few concerned citizens of Bengaluru who were aware of the problems faced by
laymen while purchasing a house in the city have drafted their objections and
suggestions to the amended Real Estate Bill 2013. Here’s what they had to
say. Read: Bengaluru citizens
highlight lacunae in new real estate bill.
|
ref. comments:
Read more at: http://bangalore.citizenmatters.in/articles/bengaluru-citizens-file-objections-to-amnded-real-estate-bill?utm_source=copy
PREV
Some of the major observations said to have been made by
citizen groups on the said Bill, as listed herein above, are not clearly
understood; rather are confusing. \The citizen groups , it is earnestly wished,
should consider desirably having a relook at, and review in detail; provided,
of course, it is not already late to doing so.
For instance:
Q
The Bill does not have provision on the lines of KAOA
to protect the interest of customers by way of conferring a title to each
apartment when the whole property and all apartments are submitted to it. In
the proposed Bill, any part of the property automatically receives a title, devoiding
protection to customer.
UQ
To one’s independent understanding, based on a sound
reasoning of own, the Bill, - as the nomenclature itself is noted to
sufficiently bear out/ imply,- is, if and when enacted, expected and intended
to be followed by the states having it as a broad frame work, so to say; so as
to suitably fit into the special enactments of each state as applicable to and
governing the two types of property- Flats and Apartments. To put in more
explicitly, in one’s firm conviction, that is a not a uniform national code,
expected to be universally followed and applied uniformly by all states,- much
less enforced rigidly by the central government, - ignoring for the purpose
what each of its own enactments provide.
While the input as above, is with a view to mainly
clarifying one‘s own understanding, it is being shared for the benefit of those
citizen groups to make use of it as a well-meaning and –intended feedback. And
do so, keeping in mind that the very objective is to bring about improvements
in the current scenario, so as to benefit the larger public, being the
investors, having vested interests; and that too, speedily, with no more
muddling even remotely. There is no gain saying that, having regard to the
inherent intricacies of the whole matter, consultation with and active
assistance by eminent law expert(s), known for legal acumen and personal
integrity, seem to be unavoidable, rather imperative in any case. July 17 2015
Rider:
For anyone
to understand the input with appropriate spirit and in proper light, suggest to
prudently keep as a useful backdrop, the ongoing sport, - tug of war - in the
matter of Land Bill, between the centre and the states on one hand, and between
the states selves, inter se,, seemingly with no prospects of a united
resolution in the foreseeable future. July 17 2015,
Read more at: http://bangalore.citizenmatters.in/articles/bengaluru-citizens-file-objections-to-amnded-real-estate-bill?utm_source=copy
vswaminathan
Some of the major observations said to have been made by citizen groups
on the said Bill, as listed herein above, are not clearly understood;
rather are confusing. \The citizen groups , it is earnestly wished,
should consider desirably having a relook at, and review in detail;
provided, of course, it is not already late to doing so.
For instance:
Q
The Bill does not have provision on the lines of KAOA to protect the
interest of customers by way of conferring a title to each apartment
when the whole property and all apartments are submitted to it. In the
proposed Bill, any part of the property automatically receives a title,
devoiding protection to customer.
UQ
To one’s independent understanding, based on a sound reasoning of own,
the Bill, - as the nomenclature itself is noted to sufficiently bear
out/ imply,- is, if and when enacted, expected and intended to be
followed by the states having it as a broad frame work, so to say; so as
to suitably fit into the special enactments of each state as applicable
to and governing the two types of property- Flats and Apartments. To
put in more explicitly, in one’s firm conviction, that is a not a
uniform national code, expected to be universally followed and applied
uniformly by all states,- much less enforced rigidly by the central
government, - ignoring for the purpose what each of its own enactments
provide.
While the input as above, is with a view to mainly clarifying one‘s own
understanding, it is being shared for the benefit of those citizen
groups to make use of it as a well-meaning and –intended feedback. And
do so, keeping in mind that the very objective is to bring about
improvements in the current scenario, so as to benefit the larger
public, being the investors, having vested interests; and that too,
speedily, with no more muddling even remotely.
There is no gain saying that, having regard to the inherent intricacies
of the whole matter, consultation with and active assistance by eminent
law expert(s), known for legal acumen and personal integrity, seem to be
unavoidable, rather imperative in any case.
July 17 2015, 9:30 AM · Thumb-up-icon 0 · Thumb-down-icon 0
vswaminathan
Rider: For anyone to understand the input with appropriate spirit and in
proper light, suggest to prudently keep as a useful backdrop, the
ongoing sport, - tug of war - in the matter of Land Bill, between the
centre and the states on one hand, and between the states selves, inter
se,, seemingly with no prospects of a united resolution in the
foreseeable future.
July 17 2015, 9:54 AM · Thumb-up-icon 0 · Thumb-down-icon 0
Read more at: http://bangalore.citizenmatters.in/articles/bengaluru-citizens-file-objections-to-amnded-real-estate-bill?utm_source=copy
Read more at: http://bangalore.citizenmatters.in/articles/bengaluru-citizens-file-objections-to-amnded-real-estate-bill?utm_source=copy
PREV
As
per the report , out of the several measures claimed to being taken to
promote housing construction, the most significant of all items listed
is that which is to - pursuing REB to protect interest of consumers,
while at the same time enhancing the credibility of RES. The REB as
framed and structured , after a lapse of years delay, according to a
critical view aired in expert circles , however, nowhere meets the
common expectations of the concerned consumers’ community to...
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vswami 20 June 2015
vswami 19
June 2015
Vswami18 June 2015
To Dilate (by way of clarifying and sharing own thoughts, in
quest of looking for and finding clues, f any ) :
Following is extract, of relevance) from the Judgment:
Xtracts
Q
In its order, the Court quite explicitly confronted
the policy conflict and sought to address it..... extracted below:
This Court feels concerned with the fact that three persons are deprived of their
liberty for the last fifteen months and this situation is quite onerous to
them. On the other hand, public interest as well as public good demands that
the two Sahara Companies, which had collected whopping amount of more than
[Rupees] 22,000 crores from the public in an illegal and unauthorised manner,
are made accountable for the same .... .. It is, thus, an unprecedented
situation of personal liberty of the three applicants on the one hand vis a vis
majesty of law and ensuring larger public good, on the other hand. It is this
sense of justice, in an unprecedented kind of situation, that has compelled the
Court to take such an extreme step.... This case is a burning example where
the true dictate of justice is difficult to discern, and the law needed to come
down on the side of practical convenience. We may borrow the
jurisprudential theory propounded by Ronald Dworkin, albeit in somewhat
different context, viz. ... Dworkin has instead
argued for the judicial use of public standards or principles in a way that is
capable of providing the right legal answer. The process of reaching a right
answer in hard cases obviously differs from the process of reaching the legal
answer in easy cases. After all, the avowed objective of rule of law is also to
ensure... a classic case where the approach adopted is influenced by the
necessity of “making the law work”. Therefore, the orders passed may not be
strictly construed... but in exercise of inherent jurisdiction vested in
this Court to do complete justice in the matter and to ensure that the
applicants render full compliance of its orders....
Pragmatism trumps legal doctrine. The Supreme Court has repeatedly stressed the
“unprecedented” nature of the situation, and hence
it decided to exercise its inherent jurisdiction to adopt a practical approach
as opposed to resorting to legal reasoning.
UQ
Wprt the brief comment on the Real Estate Bill 2013, the quite possible,
rather inevitable. Prolongation and delay of minimum of a few years, perforce
foreseen in having the provisions of the Bill, after its final enactment looms
large and in a way, obscures vision.
Q
> On delay, we, as a nation, have some fine qualities but a sense of
the value of time is not one of them. Perhaps, there are historical reasons.
Ancient India had evolved the concepts of eternity and infinity. So what do
years wasted in a litigation matter against the backdrop of eternity. Believing
in incarnation, what does it matter if you waste this life. You will have many
more lives in which to make good.
Ø Our cases drag on
over a length of time which makes eternity intelligible
Ø The law may or may
not be an ass but is certainly a snail; cases proceed at a pace as unduly slow
in a community of snails.
Ø Justice has to be
blind but I see no reason why it should also be lame; here it just hobbles
along, barely able to walk.>
UQ
(A narration from Palkhivala’s
published speech (1987) - The Judiciary and the Legal
Profession, the Book- We, the Nation THE LOST DECADES)
The above quote,
random selected among more of the kind
in like vein, though mainly aired in reference to the realm of tax
administration and adjudication, may be seen to equally hold good and of every relevance in respect of any other than tax.
previous
b/f from old blogs
AMONG others, representations sent to the Housing Ministry wrt the Bill of 2001 are reproduced below, for ready reference:
<<
Addendum>
(being sent today, the 7th instant)
IV. Based on an independent but close study of the
Real Estate Bill (the revised text), in one’s conviction, many of its features/requirements
could not at all be regarded to be new innovations or freshly introduced. For,
most of them are to be found already incorporated in the extant individual
enactments of State(s) (e.g. Maharashtra and Karnataka).
The significantly crucial and the most important of
them, in that order, are these:
1. Procuring from the concerned local authorities all
the necessary approvals and sanctions for development / construction of a
building project
2, Execution and registration of a ‘Deed of
Declaration’ in the prescribed Form
3. Execution and registration of an ‘Agreement to
Sell’
(Model
Form made available)
4. On completion of the project, before conveyance
and giving possession, obtaining a completion /occupancy certificate from the
concerned local authorities
5. Execution and registration of a Deed of
Conveyance
((Model
Form made available)
6. Compliance with all other related/connected
documentations/ requirements at different stages of construction; and finally, including
- Advocate’s certificate of ‘marketable title’, ‘no encumbrance’ certificate,
etc. (these are enumerated in the Model Form of Conveyance)
Besides, the State enactment, the rules framed
there under, read together with all other allied regulations do adequate cover
all other connected matters: Contents of Agreement, Deed, and Procedure to be
followed for registration, et al, - to the final stage of handing over the
property to the co-operative society or co-owners’ ‘Association’ duly formed
and registered.
The extant State enactment(s) cannot, of course, be
rightly claimed to be fool proof, with no lacuna at all. Even so, none of such
lacuna, a few in numbers, could be rightly adduced as an impediment, a serious
one at that, which are so material or of a fundamental nature as to come in the
way of promoters complying with the law. On the other hand, the largely
prevailing non-compliance or by-passing of the law, for decades now, can only
be attributed to the belligerent attitude of promoters, against it. In no small
measure, traceable to also the government’s matching apathy, and nonchalant
behaviour in failing to show any sincerity or make any attempt in
implementation and enforcement of the law. Thus, it is the mutually
contributory and complimenting callousness that has been largely responsible
for the muddled state of affairs; that has gone on merrily, unchecked for
decades.
It is in such an overwhelmingly disgusting context
/ vexing scenario that the proposed regulatory regime has come to be mooted and
legislation proposed.
In view of, and keeping in full focus the
foregoing, a truly effective strategy needs to be charted; and suitable
remedial measures be taken.
One has the following primary suggestions to offer
for consideration:
1. Same way as the income-tax department has done for
its purposes of keeping a track of the transactions in immovable property, the
Registry should be used by the RA, as the main gate keeper, for its purposes of
implementation of the proposed enactment, both in letter and spirit, thereby,
in turn ensuring strict compliance with the State enactment as well.
2. The final formats, as rightly proposed/envisaged
in the Bill, for execution of Agreement to Sell, and for Deed of Conveyance
should be got ready at the earliest and be made mandatory to be strictly
adhered to / followed.
Such steps, if devised in detail, and decided upon,
should hopefully go a long way in ensuring that the procedural requirements are
strictly complied with by the Promoters. Also safeguard and keep protected the
lawful rights and interests of the allot tees / purchasers as avowed / sought
to be secured by the law.
It goes without specially emphasising that, the key
for successful functioning, and fulfilment of its own responsibilities, the RA should
have in place absolutely effective machinery for a constant monitoring of the
entire scheme of things, to its last detail.
>Attachment
to THE FEEDBACK MAIL earlier sent TO- responseonrealestatebill@yahoo.in>
I. 1. The more times one care to read, own initial
conviction gets increasingly strong and fortified; in that, despite
the attempt made/impression given to the contrary by the media through
articles, etc. on the subject, the Bill (of 2011) does not seem to provide
clearly and adequately, even if not with a wholesome set of teeth, at least
sufficient teeth to make the regulatory authority (RA) really work effectively
and forcefully; so as to fulfil the very basic objectives of creation
of such an authority. Such objectives, as set out in the preamble and
noteworthy among them are, - (a) ‘to ensure sale of ...in an efficient and
transparent manner’, and (b)’to protect
the interest of consumers in..’. For an appreciation /justification of such
a view/reaction, what one needs to do is to mindfully go through,- first
chapter by chapter, then section by section, and then, word by word used.
2. Among others, jutting out are these:
Sections 63 and 64> These confer on the
'appropriate government' (i.e. state government) very wide and sweeping powers.
They have the inherent potentials for the state government to, at its will,
dictated by its own philosophy and approach, supersede the RA, thereby tending to
downright override / veto the exercise (by the RA) of its powers independently,
impartially and without bias.
Chapter VI> does not bear out any effective, or in any case, enough safeguards, for rendering the institution of the RA strong enough to successfully implementing and accomplishing the laudable purpose(s) of the proposed legislation; seemingly opposed to/belying what is being tom-tom med with a big noise in certain quarters.
Sections 70 to 73> what should be of concern is
the discouraging purport and import of these sections. In one's sincere
perception, they do not seem to provide any useful help to achieve the goal of
the RA successfully working towards accomplishing the objectives of the legislation
on the anvil.
For driving home what is sought to be conveyed, one is obliged to recall the bizarre story, given wide publicity in the media, of the open battle of wits (no wits !) that came to be fought, not long ago, between the two most powerful of all extant regulatory authorities namely, SEBI and IRDA. The point to be specially made a note of is that, - those are the two authorities established by law and commonly acknowledged as profoundly 'central' authorities,-not a 'state authority' like the one intended for realty sector,- with its jurisdictional powers extending to the country as a whole. For an insight into that story (rather the inside-story), though now may have been forgotten, one may read >
For driving home what is sought to be conveyed, one is obliged to recall the bizarre story, given wide publicity in the media, of the open battle of wits (no wits !) that came to be fought, not long ago, between the two most powerful of all extant regulatory authorities namely, SEBI and IRDA. The point to be specially made a note of is that, - those are the two authorities established by law and commonly acknowledged as profoundly 'central' authorities,-not a 'state authority' like the one intended for realty sector,- with its jurisdictional powers extending to the country as a whole. For an insight into that story (rather the inside-story), though now may have been forgotten, one may read >
In a nut shell> The point requiring to be
stressed is this: Keeping the above referred episode in mind, every conceivable
precaution should be taken, by having in-built safe guards in the enactment
itself, so as to ward off any similar, not otherwise unlikely, confrontation, -
that is between the RA and the appropriate government (of the state(s)).
The most disturbing of all concerns is that, the Bill, on which comments have been invited, is quite incomplete. With almost every one of the host of 'Rules' and 'Regulations' spoken of in the Bill (ref. Section 2 (zf), (zg)) - WITHOUT WHICH THE LEGISLATION REMAINS INCOMPLETE, HENCE CAN ONLY BE REGARDED AS STILLBORN - to one's knowledge yet remaining to be framed and / or made known, what is in store is anybody's guess; a wild one at that. For, as truly said, - devil is (OFTEN LURKS) in details.
The most disturbing of all concerns is that, the Bill, on which comments have been invited, is quite incomplete. With almost every one of the host of 'Rules' and 'Regulations' spoken of in the Bill (ref. Section 2 (zf), (zg)) - WITHOUT WHICH THE LEGISLATION REMAINS INCOMPLETE, HENCE CAN ONLY BE REGARDED AS STILLBORN - to one's knowledge yet remaining to be framed and / or made known, what is in store is anybody's guess; a wild one at that. For, as truly said, - devil is (OFTEN LURKS) in details.
Other
comments:
II. IT IS SADLY OBSERVED, DRAFTING
HAS BEEN DONE IN A GLARINGLY LIGHT-HEARTED AND CAVALIER MANNER.
IN SO FAR AS IT DEALS WITH
'UNITS' OF BUILDING(S), TO WHICH THE LEGAL CONCEPT OF 'CO-OWNERSHIP'
ESSENTIALLY APPLIES, THE MOST CRUCIAL ASPECTS NOT COVERED OR EVEN BORNE IN MIND
ARE THE FOLLOWING:
1. ALMOST EVERY ONE OF THE
'STATES' HAS ITS OWN ENACTMENTS, RULES, AND REGULATIONS, ALREADY IN PLACE, ON
ITS INDEPENDENT STATUTE BOOK.
EVEN THE VERY SCHEME OF
THINGS RESPECTIVELY UNDERLYING THEM, ARE NOT UNIFORM BUT VARY; IN SOME RESPECTS,
ALSO WIDELY.
2. SO FAR AS ONE KNOWS, IN
SOME OF THE STATES (E.G. MAHARASHTRA AND KARNATAKA)THE 'UNITS' OF BUILDINGS
THUS FAR GIVEN DUE LEGAL RECOGNITION / SANCTION, AND COVERED BY THE REFERRED SPECIAL
ENACTMENTS, ARE OF TWO (only two) DISTINCT TYPES - FLATS and APARTMENTS.
3. ALL THE APPLICABLE
PROCEDURAL REQUIREMENTS IN REGARD TO THE SAID TWO TYPES OF UNITS ARE MUTUALLY
DIFFERENT AND MATERIALLY AT VARIANCE.
IN THE BILL, THE FOREGOING
ARE NOT FOUND TO HAVE BEEN PROPERLY FOCUSED ON OR ACCORDED ANY SPECIAL ATTENTION
AS ONE WOULD HAVE EXPECTED; MUCH LESS SUITABLY TAKEN CARE OF/COVERED, SO AS TO
MAKE THE REGULATORY REGIME TRULY EFFECTIVE AND EVENTUALLY SUCCESSFUL.FOR, AFTER
ALL,THE REGULATORY AUTHORITY IN ANY STATE, IF AND AFTER IT HAS BEEN INSTALLED,
COULD, FOR OBVIOUS REASONS,CARRY OUT ITS FUNCTIONS ONLY WITHIN THE FRAMEWORK OF
THE SPECIAL ENACTMENT, RULES, REGUATIONS.ETC., ALREADY IN FORCE IN THAT
PARTICULAR STATE, NOT OUTSIDE OF THEM.
NOTE: These comments, in a
manner of speaking, are no different but more or less go to reiterate some of
those points of view conveyed to the Ministry wrt the earlier draft bill (for reference,
see the Appendix hereto at the bottom.)
4. CERTAIN OTHER ASPECTS,
EVEN THOUGH OF AN ELEMENTARY NATURE, ARE SEEN TO HAVE BEEN SIMPLY GLOSSED OVER,
UNWITTINGLY OR OTHERWISE.
SELECTIVELY, THE FOLLOWING REQUIRE MENTION:
i)IN SECTION 2, (m),
(n) and (o), the terms “development”, “development charges” and “development
works” have been specially defined (see also,(r),(s)). The purpose is not
known; for, nowhere else in the Bill, the said terms are seen to find any
mention. May be, what has been lost sight of is the fact that, while in the
earlier draft there were provisions for sharing, subject to mutual agreement, by
the parties, of such charges, those provisions have been removed in the revised
draft (presumably after reconsideration)(subject to a double check).
In section 2 (p), in
defining the term “engineer”, in the nature of things, should it NOT have been
specified “civil”.
In section 2 (y), also elsewhere, “deed of allotment” finds mention. One has not heard; much less know, of any such ‘deed’ executed for allotment; its purport or relevance not understood.
ii)
Likewise not at all understood are these as well:
(A) Explanation
under the first proviso in section 3. - ... to be developed in ‘PHASES’...
(THE VERY IDEA AS MOOTED, ALSO REPEATED IN
SEVERAL OTHER CONTEXTS, IS ABHORRING)
(B) As to whether the ‘registration’ harped
on and projected, rightly or wrongly, as the basic requirement for compliance,
calls for compliance in respect of everyone of the several projects a promoter
may undertake, or on a onetime basis, seems to be not clear.
(THIS NEEDS TO BE GONE INTO, with a
fine-toothed comb, AND SUITABLE CHANGES BE MADE, TO MAKE THE REQUIREMENT
EXPLICIT)
(C) Section 7 (1) (b) – “........ of the agreement entered into with the
Competent Authority:...
(FOR
WHAT ONE KNOWS, NO SUCH AGREEMENT , a formal one at that, is presently being
entered into; if so, -SHOULD BE CLARIFIED)
5.
As is common knowledge, there are certain crucial areas where the players in
the realty sector often fail to properly comply with what the state enactment requires,
even if mandated. Some such areas which have come to surface in recent times may
be found covered, in detail, in the Blogs posted @ swamilook, in
public interest.
The following links may be seen to provide useful
clues for identifying such areas:
http://vswaminathan-vswaminathan-swamilook.blogspot.com/2011/12/at-news-for-consumer-home-buyer.html
http://vswaminathan-vswaminathan-swamilook.blogspot.com/2011/09/societies-registration-act-v-co.html
IN PARTICULAR, DRAFTING OF LEGAL DOCUMENTATIONS,
COMPLIANCE WITH THE PROCEDURAL REQUIREMENTS AS LAID DOWN IN THE STATE (S)
ENACTMENTS- E.G. SUCH AS THE MOST CRUCIAL ONE- EXECUTION AND REGISTRATION BY
PROMOTER OF A – ‘DECLARATION’ (IN MAHARASHTRA AND KARNATAKA, IN THE PRESCRIBED
FORM ‘A’)
A close perusal OF THE SEVERAL MATERIAL COVERED IN
THE BLOGS ON THE TOPIC OF –REALTY might help in getting to know of, identifying
precisely, and deciding whether all or anyone or more of them require to be
suitably covered in the proposed enactment and /or in framing the pending Rules
and Regulations.
III. CHAPTER VI (sections 48 and 49)
is seen to contain the ‘key’ provisions, so to say. For, the setting up of a
CENTRAL ADVISORY COUNCIL (CAC) as envisaged seems to aim at ensuring the
efficacy and eventual success in accomplishing the objectives of the machinery
of the RA.
What calls for an incisive noting is
that, as set out in Section 49, one of the functions of the CAC to be set up, -“shall
be to advise the Central Government on:-
(a) all matters concerning the
implementation of this Act;”
Having regard to the scheme of
things, -if considered in conjunction with the more relevant and supervening
provisions of each of the individual State enactments,- however, the
implementation of this Act, as envisaged, is , in turn, going to be mainly
dependent on implementation of the enactments already in force in each of the States,
respectively. In other words, in real terms, what is called for, and to be
desirably expected is a profoundly complete and passionate harmony, co-operation, and co-ordination
amongst all the States on the one hand, and the RA on the other. What really in
store is impossible to say with any certainty; only future can tell?
APPENDIX
Refer to the reproduced comments in
the concluding portion, under the head, - key note @the Blog
http://vswaminathan-vswaminathan-swamilook.blogspot.com/2011/11/real-estate-regulatory-bill.html
<<<<
Cross refer cover mails:
<<<<
Cross refer cover mails:
On Saturday, 24 December 2011 10:11 AM, V Swaminathan
<vswaminathan13@yahoo.com> wrote:
Thanks Dr.Jaypal for calling.
As desired, PLEASE FIND ATTACHED THE SUBJECT MAIL,
WITH ENCLS.
REGARDS
vswaminathan
PS: Refer the related Blog @link:
----- Forwarded Message -----
From: V Swaminathan <vswaminathan13@yahoo.com>
To: "responseonrealestatebill@yahoo.in" <responseonrealestatebill@yahoo.in>
Sent: Wednesday, 7 December 2011 1:26 PM
Subject: Fw: DRAFT REAL ESTATE (REGULATION & DEVELOPMENT) BILL 201_
From: V Swaminathan <vswaminathan13@yahoo.com>
To: "responseonrealestatebill@yahoo.in" <responseonrealestatebill@yahoo.in>
Sent: Wednesday, 7 December 2011 1:26 PM
Subject: Fw: DRAFT REAL ESTATE (REGULATION & DEVELOPMENT) BILL 201_
BEING AGAIN SENT, WITH AN ADDENDUM
vswaminathan
----- Forwarded Message -----
From: V Swaminathan <vswaminathan13@yahoo.com>
To: "responseonrealestatebill@yahoo.in" <responseonrealestatebill@yahoo.in>
Sent: Monday, 5 December 2011 4:39 PM
Subject: DRAFT REAL ESTATE (REGULATION & DEVELOPMENT) BILL 201_
From: V Swaminathan <vswaminathan13@yahoo.com>
To: "responseonrealestatebill@yahoo.in" <responseonrealestatebill@yahoo.in>
Sent: Monday, 5 December 2011 4:39 PM
Subject: DRAFT REAL ESTATE (REGULATION & DEVELOPMENT) BILL 201_
IN RESPONSE TO THE INVITATION vide your OM of
November 09, 2011, PLEASE FIND IN THE ATTACHMENT HERETO, MY PERSONAL VIEWPOINTS
/ INDIVIDUAL COMMENTS ON THE DRAFT BILL, FOR YOUR INDEPENDENT CONSIDERATION.
VSWAMINATHAN
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