UT-EN-April-2023

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R Premkumar: Where

Chief Mentor Mr. V.P. Nandakumar

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Editorial

"The road to success is paved with obstacles; embrace them as opportunities to learn and grow." - Richard Branson.

A journey of an entrepreneur is challenging but rewarding path that requires a significant amount of hard work, dedication, and perseverance. Entrepreneurs often face obstacles and setbacks along the way, such as financial struggles, competition, and pivoting their business model. However, through hard work and persistence, successful entrepreneurs are able to overcome these challenges and achieve their goals. While the journey may be tough, the rewards of being your own boss and creating something from scratch can be incredibly fulfilling. Similarly, our featured cover story of the month highlights the remarkable achievements of BLM Premkumar, an entrepreneur hailing from southern India, who has positively impacted the lives of numerous individuals through his role as the Chairman and Managing Director of Bharath Lajhna Multi (BLM) State Housing Co-operative Society Ltd.

The current edition features an article by V P Nandakumar, the MD and CEO of Manappuram Finance Limited, sharing his perspective on "Forward Thinking".

Additionally, the issue includes our usual content on topics such as beauty, travel, auto review, movie reviews, book reviews, motivation, and business.

"The book to read is not the one that thinks for you but the one which makes you think." - Harper Lee.

Happy reading!

India’s Digital Transactions More Than That Of US, China, Europe Combined: Trade Official

According to a top trade official, India conducts more real-time digital transactions than the US, China, and Europe combined. “India has a paperless, presence-less, and cashless solution for everything. The public digital infrastructure of India is unique. It is based on open systems, open architecture and open network, which allows everyone to plug in and removes entry barriers,”Anurag Jain, DPIIT secretary, said. The comments were delivered by the Secretary of the Department for Promotion of Industry and Internal Trade (DPIIT) during an interactive session on “Inclusion on the Back of Technology: Best Practices” on 14th March at the CII Partnership Summit 2023. India has emerged as one of the most rapidly expanding fintech innovation ecosystems, and the PM Modi-led administration has played a key role in accelerating the internationalisation of India’s digital payment infrastructure.

India, Australia Aim To Strengthen Economic, Defence Ties

"If you want to be successful in business, you have to constantly innovate and disrupt. The minute you stop doing that is the minute you start dying."
Gary Vaynerchuk

Anthony Albanese, the prime minister of Australia, will visit India on March 8th in an effort to deepen trade, investment, and defence ties and build on the recent momentum in bilateral relations. Anthony Albanese’s three-day visit, which is the first by an Australian prime minister since 2017, comes days before that of Fumio Kishida, the prime minister of Japan and another member of the so-called Quad grouping that aims to challenge China’s expanding dominance in the Indo-Pacific. Together with Australia and Japan, the Quad includes the United States and India. Australia is slated to host a Quad leaders conference in Sydney later this year. “India and Australia share warm and friendly relations based on common values and democratic principles. The Strategic Partnership between the two countries was elevated to a Comprehensive Strategic Partnership in June 2020,” the Indian foreign ministry said in a statement ahead of the visit.

iPhones To Be Built In 300-Acre Karnataka Factory, “To Create 1 Lakh Jobs”

Rajeev Chandrasekhar, the Union Minister, and Basavaraj Bommai, the Chief Minister, announced on March 3rd that Apple phones would be produced at a new 300-acre factory in Karnataka. One lakh people will have jobs thanks to the manufacturing facility, they claimed. On the outskirts of Bengaluru, Foxconn, the top producer of iPhones, has been given land. According to reports, the 300acre site has one of Apple’s biggest phone-making facilities. According to sources, the team would take a flight to New Delhi that evening to meet with Prime Minister Narendra Modi. Foxconn reported earnings of 206 billion dollars in 2021, placing it second internationally in the production of Apple phones. Manufacturing facilities for the corporation are located in a number of nations, including China, India, Japan, Vietnam, Malaysia, the Czech Republic, and the United States.

Reliance Jio’s 5G Network Now Available In 365 Cities, Adds 34 More Cities

"If you do what you've always done, you'll get what you've always gotten."
Tony Robbins

The number of cities now included in Reliance Jio Infocomm’s True 5G network has increased by 34, including eight from Tamil Nadu, bringing the total to 365. The company’s most recent round of network addition exercises comprised Ambur, Chidambaram, Namakkal, Pudukottai, Ramanathapuram, Sivakasi, Tiruchengode, and Villupuram in Tamil Nadu and Puducherry, the telecom giant said on 15th March. Together with the facility being available in Chennai, the 5G services were formally launched in January in Coimbatore, Madurai, Tiruchirappalli, Salem, Hosur, and Vellore. The business claimed to have invested 40,446 crores in Tamil Nadu. Commenting on the launch, a spokesperson said, “we are really excited to launch Jio True 5G services in 34 additional cities, taking the total count to 365 cities.” “Jio has achieved this milestone in just under 120 days since the Beta Trial launch and is well on its way to connect the entire nation with the transformational Jio True 5G services by December 2023.”

India, US Sign Agreement On Semiconductor Supply Chain

After a three-year hiatus, the India-USA Commercial Dialogue was relaunched with a strategic outlook and a focus on supply chain resiliency and diversification as well as new emerging areas. It was at this time that India and the US signed an MoU on the semiconductor supply chain and innovation partnership. During March 10th dialogue in New Delhi, US Secretary of Commerce Gina M. Raimondo and Union Minister of Trade and Industry Piyush Goyal signed the agreement. In February 2019, the most recent India-US Commercial Dialogue took place. Since then, due to the pandemic and other factors, it could not be held. Prior to its official launch on November 9, 2022, the India-US CEO Forum was soft-launched by the Indian Minister of Commerce and Industry and the US Secretary of Commerce via videoconference. Its key objectives included improving supply chain resilience, enhancing energy security, lowering greenhouse gas emissions overall, advancing inclusive digital trade, and facilitating post-pandemic economic recovery, particularly for small businesses.

Urban Ladder Plans To Double Retail Stores By

March 2024

"If you don't drive your business, you will be driven out of business."
B. C. Forbes

Urban Ladder, a furniture and home décor company, said it intends to treble this shop count by March 2024 after opening its 50th location on 15th March. The business, which just established a store in Kolkata, has swiftly expanded its physical presence over the past nine months after initially only running 13 outlets through June 2022. “… the company plans to expand its retail stores in 32 cities by 2023 and aims to double this number by March 2024,” Urban Ladder said in a statement. The business, which began as an online brand, would later have a stronger position in the e-commerce market. “The world of e-commerce is rapidly expanding, and Urban Ladder also aims to strengthen its online presence through UL.com and Jiomart,” it said. Nishant Gupta, the chief business officer of Urban Ladder, said the business has a comprehensive expansion strategy to serve customers in various metro and non-metro locations.

Spanish anger over TV star Ana Obregón’s surrogate baby the US

Ana Obregón, a Spanish television actress, has drawn criticism for disclosing that at the age of 68, she gave birth to a girl in the US through a surrogate. Obregón is well recognised for her roles as the lead in several Spanish sitcoms. She had previously discussed her efforts to move on with her life when her son, who was also her sole child, died of cancer in 2020 at the age of 27. All kinds of surrogacy are prohibited in Spain, however parents who return to the country can adopt the child. Following the passing of her son, Obregón, who also lost both of her parents, was depicted on the cover of the Hola! Magazine earlier this week holding a new born outside a Miami hospital. Her remarks ignited debate on Spanish social media, and ministers in Spain’s left-wing government were incensed at the move.

Bill Gates: AI is most important tech advance in decades

The development of artificial intelligence (AI), according to Microsoft co-founder Bill Gates, is the most significant technological achievement in decades. He compared it to the development of the microprocessor, personal computer, Internet, and mobile phone in a blog post on 21st March. According to him, it will alter how people work, learn, travel, access healthcare, and interact with one another. He was discussing the technology behind programmes like ChatGPT, a chatbot. ChatGPT, an AI chatbot created by OpenAI, is built to respond to internet queries in a manner that is natural and human-like. Microsoft, where Mr. Gates still serves as an advisor, made a multibillion-dollar investment in the project’s team in January 2023. But it is not the only AI-powered chatbot available, with Google recently introducing rival Bard.

France To Ban TikTok On Phones Of Civil Servants

According to Civil Service Minister Stanislas Guerini’s tweets, TikTok will no longer be allowed on government employees’ work phones in France. “In order to guarantee the cybersecurity of our administrations and civil servants, the government has decided to ban recreational applications such as TikTok on the professional phones of civil servants,” he said in a statement. He continued by saying that for some weeks, a number of France’s European and international allies had implemented policies to limit or forbid their governments’ employees from downloading and installing the TikTok programme. Guerini stated that recreational applications lack the cybersecurity and data protection standards necessary to be installed on government equipment. He also added that the prohibition is applicable right now and that government agencies will monitor compliance.

Italy’s Quest to Preserve Culinary Tradition: Controversy Surrounds Ban on

Lab-Grown

Meat

Aplan that would outlaw laboratory-produced beef and other synthetic foods has the support of Italy’s right-wing government, underlining the country’s culinary tradition and commitment to public health. A violation of the ban might result in fines of up to €60,000 (£53,000) if the plans are approved. The minister of agriculture and food sovereignty under a new name, Francesco Lollobrigida, spoke on the value of Italian cuisine. The measure was applauded by the farmers’ group. But, it was a setback for certain animal welfare organisations, who had promoted lab-produced meat as a solution to problems like preserving food safety and the environment from carbon emissions. Prime Minister Giorgia Meloni is one of the 500,000 signatories to a petition that Coldiretti and other agriculture advocacy groups have gathered in recent months to safeguard “natural food vs. synthetic food.”

For more info: europetimes.co

R Premkumar: Where success meets humanity

“The late president APJ Abdul Kalam taught us to dream big. I dreamt big and gave wings to it.” And the results are there for all to see. What began with the lofty aim of a “Home for All”, BLM today is a force to reckon with in the housing sector. It develops houses of all kinds from villas, row houses and apartment complexes to bungalows and mini townships at affordable rates. “We have completed almost 60 projects, both big and small, in Chennai, Puducherry and Kerala and they have benefited close to 50,000 people,” he says with a smile of satisfaction.

At a time when the Indian entrepreneurial hall of fame is teeming with colossal figures, only a blessed few stand head and shoulders above others for making a positive impact on the lives of others. With the right blend of grit, vision, spiritual strength and empathy, R Premkumar, more popularly known as BLM Premkumar, has

earned his rightful place among that niche group of entrepreneurs with a human touch.

Clad in a crispy white shirt and spotless starched dhoti of the matching colour and with sacred ash on his forehead, Premkumar may be mistaken for yet another typical south Indian gentleman, as he appears without the stereotypical trappings of a

business magnate. That sage-like visage framed with a thick salt-and-pepper beard hides the hawkeyed, astute visionary entrepreneur, who is at the helm of a multi-crore behemoth—Bharath Lajhna Multi (BLM) State Housing Co-operative Society Ltd. It is a force to reckon with in the entrepreneurial landscape of south India, spanning several verticals

“As you know, everyone is in a mad rush to create comfort zones for themselves. But I undertook this venture so that it makes a positive impact on the lives of others and provides a means of livelihood to many as well. For close to two decades, we have been sailing on impacting so many lives in a positive way.”

such as housing, land development, hospitality, jewellery, civil supplies and transportation to name a few. It is one of the niche enterprises which touch the lives of thousands of beneficiaries. In an exclusive interview with Unique Times, he reminisces about his entrepreneurial journey and future plans for the empire he has built.

From a seedling to a mighty colossal tree

When asked how it all began, Premkumar went down memory lane, saying it all started with a bitter experience many years ago. “I once accompanied a friend to a co-operative bank to apply for a loan to conduct his sister’s wedding,” he said.

“That was when I came to know how difficult it was to get a loan sanctioned. One had to pay the secretary Rs 7,000 to get the loan approved. To get the money, they had to shell out a good sum or they risked their application being rejected. Money apart, a recommendation from the ruling party’s district secretary was also essential to get the loan.”

It was at that juncture that the ‘nirvana’ moment came. “Why not begin something similar without any discrimination on the basis of politics, religion or caste?” he thought. “So, I contemplated starting a mul-

ti-state co-operative society,” said Premkumar, who is the Chairman and Managing Director of BLM. When he mooted the idea with four like-minded friends, they threw their weight behind him.

But the real test of mettle came when he went to New Delhi twice to procure the licence for this mega movement. Regional bias, coupled with his south Indian way of dressing made the honchos reject his application twice. However, the 1992 state middleweight boxing gold medallist who knocked down opponents with ease, was in no mood to give up. During the third visit, he was able to convince the IAS officer of the impact his enterprise would have on people and procure the license. Thus, in 2006, BLM was born in Chennai with like-minded people joining hands and pooling resources. And the rest is history. Today, it is spread across Tamil Nadu, Kerala and Puducherry with more than 100 branches and five lakh members. Chasing a big dream

Replying to the question of how he was able to expedite the growth of BLM and make it what it is today, Premkumar said, “The late president APJ Abdul Kalam taught us to dream big. I dreamt big and gave wings to it.” And the results are

there for all to see. What began with the lofty aim of a “Home for All”, BLM today is a force to reckon with in the housing sector. It develops houses of all kinds from villas, row houses and apartment complexes to bungalows and mini townships at affordable rates. “We have completed almost 60 projects, both big and small, in Chennai, Puducherry and Kerala and they have benefited close to 50,000 people,” he says with a smile of satisfaction.

Across the three states, BLM’s 17 construction projects are underway currently. Among them is a mammoth residential-cum-commercial project at Parandur in the Kanchipuram district of Tamil Nadu close to the proposed international airport. Spread across 500 acres, registration of 200 acres is already over and formalities for the remaining land are going on. “It will be a mini township near the airport,” said Premkumar, who was into the transportation business and politics before chasing the BLM dream.

In reply to the question on the mission behind this lofty enterprise, Premkumar said, “As you know, everyone is in a mad rush to create comfort zones for themselves. But I undertook this venture so that it makes a positive impact on the lives

of others and provide a means of livelihood to many as well. For close to two decades, we have been sailing on impacting so many lives in a positive way.” He also expressed his indebtedness to his friends Gopina-

than Nambiar, Venkat Rao, Babuji, Sreenivasan and Rajendran who rallied behind him to make BLM a reality.

With eyes on the horizon

An astute, sagacious entrepre-

neur whose eyes are on the horizon, Premkumar did not confine himself to construction and land development. He took the right decisions at the right time to explore new vistas of growth. “We have branched into

An astute, sagacious entrepreneur whose eyes are on the horizon, Premkumar did not confine himself to construction and land development. He took the right decisions at the right time to explore new vistas of growth.
“It is not enough that you live well, you need to ensure that those around you too live with dignity. I have assured that all who are associated with my enterprises have a decent home and a car,”

the transportation sector with BLM Transport operating a fleet of buses from Chennai to different parts of Tamil Nadu and Kerala,” said the suave businessman.

Today, BLM operates a cement factory in Andhra Pradesh’s Chittoor district and Kanjikode in Kerala’s Palakkad district. It also owns Eurotech Cement. BLM also has a gold and diamond jewellery showroom in Thrissur and 17 more are on the anvil in Kerala. “BLM also operates Maha Shank Energy, which is south India’s largest biogas producer converting 100 tonnes of waste into three tonnes of biogas every day. We have an agreement with GAIL which purchases our biogas", he added.

BLM has diversified into the hospitality sector and it operates six premium hotels: Vibe Resort in Munnar, Navaratna Hotel Thiruvananthapuram, Chennai Gateway in the Tamil Nadu capital, and Bekal in Kasaragod, north Kerala, to name a few. “We also plan to come up with a mega shopping mall in Kalamassery, Kochi. Its construction will begin soon,” quipped Premkumar. BLM in the next 5 years… When asked about where he saw the BLM empire in the next five years, Premkumar said the brand should “illuminate every household in south India within that period. It

should make a mark in one way or the other.” Foreseeing steady growth, BLM has purchased 50 lakh shares of Cochin International Airport (CIAL). “We are now one of the biggest shareholders in CIAL. We are targeting the entire south in a doorto-door manner,” he added. He made it clear that they were also foraying into the healthcare segment. “We are planning to have a medical college and discussions are going on in this regard. We already have a college in Kannur district and we have introduced new courses to make it an arts and science college,” said Premkumar, who loves to travel. BLM will also make its presence felt in the IT sector with two ventures in Infopark, Kochi and Technopark, Trivandrum.

Family:

The pillar of support

Being at the helm of this mammoth enterprise, Premkumar gives his family full credit for supporting all his endeavours. “My family is my pillar of support and inspiration in my entrepreneurial journey,” said the BLM chairman whose roots are in Thiruvananthapuram. He was born and brought up in Chennai as his father was employed in Chennai Port Trust. “My professional life is all the more hectic since it has got a human dimension that targets the

well-being of all. There are times when I do not get enough time for my family. But my wife, children and siblings are really supportive as they see so many people benefiting from BLM. I’m blessed to have them,” he added. Settled in Virugambakkam, his wife, Prabha, is a homemaker, his daughter Manusha is an advocate practicing at the Madras High Court and his son Madumkesh is an upcoming Kollywood actor.

Motto and spirituality

When asked about his motto in life and spirituality, Premkumar said, “We Rise By Lifting Others.” It happens to be the motto of his successful group. “It is not enough that you live well, you need to ensure that those around you too live with dignity. I have assured that all who are associated with my enterprises have a decent home and a car,” he quipped.

The business magnate is also steeped in spirituality thanks to his 20-year stint with a Hindu ascetic, who is his guiding star. “I am very strong spiritually and I attribute my success to the blessings of the almighty,” said Premkumar who is very fond of spiritual books and literature.

Premkumar also leaves no stone unturned when it comes to lending a helping hand to those in need. It

goes without saying that BLM is at the forefront of CSR activities. The most recent intervention was in the case of an Indian team volleyball player hailing from Kerala whose house was confiscated by a bank when her family defaulted the loan repayment. “As soon as I got to hear about it, I rushed to offer assistance. We built a new house and handed it over to the player Bhumika,” he said. BLM is also active in extending help to kidney patients requiring dialysis and in providing impoverished hospitals with medical equipment and ambulances. Their CSR activities span the three states.

Armed with experience, vision, diligence, humaneness and spirituality, Premkumar is confident of taking his enterprises to newer shores

Such a framework, in my view, will fortify the asset quality of the financial sector further so that the system can side step any surprises from credit risks.

Forward Thinking

RBI’s move to introduce provisioning for bad loans based on expected losses rather than incurred losses will act as an insurance against any systemic risks stemming from potential episodes of bad loan cycle, if any, in the future.

In early January, this year, the Reserve Bank of India (RBI) put on public domain a 'Discussion Paper on Introduction of Expected Credit Loss Framework for Provisioning by Banks' for comments and suggestions from all stakeholders including the general public. The document provides a new framework to assess the credit risks of the banking system well in advance of any actual slippages so that no systemic risks ensue from such incidence in the future.

To put it simply, RBI’s move to introduce provisioning for bad loans based on expected losses rather than incurred losses will act as an insurance against any systemic risks stemming from potential episodes of bad loan cycle, if any, in the fu-

ture. Such a framework, in my view, will fortify the asset quality of the financial sector further so that the system can side step any surprises from credit risks during the business cycles going forward.

To elucidate, let me quote from the document: “The exposures taken by banks are inherently susceptible to various risks, of which credit risk is of primary importance. Credit risk represents the risk that the loans given by a bank will not be paid in full, i.e., the bank is likely to suffer some level of losses on its exposures. Such credit losses are a natural corollary of banking business which involves lending to ventures based on reasonable assessment of their viabilities. Since such assessments involve estimations of future

trajectories of the performance of a venture as well as that of the macroeconomy in which such ventures are embedded, an element of uncertainty is inherent in such assessments, especially since the assessments would also involve biases such as projections of the bank’s own historical experiences into the future. Thus, the probability of deviations from such assessments is non-zero at any point. It thus follows that the probability of losses arising out of such assessment is also nonzero at any point.” That makes up the case for a better risk assessment and provisioning framework for the commercial lenders.

The central bank’s document also sheds light on the drawbacks of the current framework and high-

lights the merits of the new norms.

To quote the document again, “Standard approaches of regulating credit risk classify the losses that banks may face on their credit portfolio broadly into two categories – expected losses and unexpected losses. While unexpected losses are to be mitigated through maintaining capital, expected losses are to be mitigated through pricing policies and loan loss provisions. Such classification intuitively highlights the importance of loan loss provisioning – the burden of mitigating expected losses uncovered by the provisions maintained by the banks would also fall on the capital maintained by the banks, which then leaves the banks vulnerable to materialisation of unexpected losses thereby increasing the probabilities of bank failure”.

In India, the commercial lenders are to follow the incurred loss – based provisioning which was the standard framework globally till the other day. Under this framework, banks make provision for bad as-

sets on an ex post basis. This meant that loan loss provisioning happens with a lag thus impairing the asset quality of the banks. As evident from the financial crisis of 2007-09, such delays in recognising expected losses further weakened the bank’s balance sheets and was fraught with the danger of contagion. As the RBI documents rightly pointed out, faced with a systemic increase in defaults, the delay in recognising loan losses resulted in banks having to make higher levels of provisions which ate into the capital maintained precisely at a time when banks needed to shore up their capital, thereby affecting their resilience and posing systemic risks. “Further, the delays in recognising loan losses overstated the income generated by the banks which, coupled with dividend payouts, impacted the capital base of banks because of reduced internal accruals, which also affected the resilience of banks,” the RBI document points out.

However, under the expected

loan loss framework, banks are required to estimate expected credit risks/losses based on forward-looking estimations, a marked departure from the incurred loss framework that leaves room for forecast errors and wait for loan losses to actually materialize before making provisions. Under the proposed rules, commercial banks will have to classify financial assets into three categories; stage I, stage II, and stage III based on the assessed credit losses on them, at the time of initial recognition as well as on each subsequent reporting date, and make necessary provisions based on the assessment.

RBI has defined all three stages as follows.

Stage I includes financial assets that have not had a significant increase in credit risk since initial recognition or that have low credit risk at the reporting date. For these assets, 12-month expected credit losses are recognised and interest revenue is calculated on the gross carrying amount of the asset (that

is, without deduction for credit allowance).

Stage II includes financial instruments that have had a significant increase in credit risk since initial recognition (unless they have low credit risk at the reporting date) but that do not have objective evidence of impairment. For these assets, lifetime expected credit losses are recognized, but interest revenue is still calculated on the gross carrying amount of the asset.

Stage III includes financial assets that have objective evidence of impairment at the reporting date. For these assets, lifetime expected credit loss is recognised and interest revenue is calculated on the net carrying amount (that is, net of credit allowance).

The immediate impact of switching to the forward-looking expected

credit loss approach to estimating loss provisions may result in excess provisioning as compared to shortfall in provisioning by banks. This may land several banks with low capital cushion or runway in a spot as they will have to go for capital raising either through initial public issues or follow-on public issues or through raising additional Tier I capital. However, banks with sufficient capital buffers will have no issues in switching over to the new framework.

In my view, the new approach to loan loss provisioning will increase the resilience of the Indian banking system further. As evident from the past, and corroborated by many studies, the financial agents have a tendency to show what is called 'credit exuberance’ through business cycles that sometimes lead to

lowering the vigil against credit risks. This can lead to systemic episodes as markets across asset classes are now co-integrated. This was demonstrated through the South East Asian contagion as well through the sub-prime crisis of 2007-09.

Such episodes also demonstrated the incidence of market failure in the absence of right regulations. Therefore, I would like to conclude by saying that RBI’s new loan loss framework is the need of the hour and ensures financial stability like never before by enhancing the resilience of our banking system. It will also leave the financial system with enough capital to navigate through any shocks in the future. Such forward looking regulation will only strengthen the financial system’s capacity to withstand and recover from any future shocks

We have reason to believe that ever since the pandemic and subsequent economic turmoil, the lot of women in the country is going from bad to worse.

Gender Equality is Still a Distant Goal

Going

by

the WEF’s

Global

Gender

Gap Report 2022, which ranked India at 135th position in the Global Gender Gap Index (GGGI), the country has miles to go in ensuring equal opportunity and equal pay for women despite impressive economic growth.

Saadia Zahidi, the widely respected and accepted Managing Director of the multilateral agency, the World Economic Forum (WEF), wrote in the preface of the just published Global Gender Gap Report 2022 that accelerating (gender) parity must be a core part of the public and private agenda going forward. She wrote: “In 2022, amid multi-layered and compounding crises including the rising cost of living, the ongoing pandemic, the climate emergency and large-scale conflict and displacement, the progress towards gender parity is stalling. As leaders tackle a growing series of economic and political shocks, the risk of reversal is intensifying. Not only are millions of

women and girls losing out on access and opportunity at present, this halt in progress towards parity is a catastrophe for the future of our economies, societies and communities.”

One could only agree with her arguments which stand to everybody’s reason. Despite making large scale economic progress, and in many cases women breaking the glass ceilings by making it to the top and gatecrashing into hitherto mail bastions, a lot more needs to be done in achieving gender parity in many economies. It is true that we may find women heading many corporations, powerful organisations and even nations, but the lot of the women living at the bottom of the pyramid has hardly changed over

the years.

In fact, as Zahidi pointed out, new concerns are undoing whatever progress we made in the past by a greater degree and at a faster pace. This is not just the case with women and girls living in Afghanistan or elsewhere in Africa but very much true in the case of teenage girls in the US as well. Results of the Youth Risk Behavior Survey published by the Centers for Disease Control and Prevention (CDC), a US government agency which was in the forefront in the fight against Covid-19, published in February revealed that nearly 3 in 5 teen aged girls (57%) said they felt "persistently sad or hopeless." That's the highest rate in a decade. And 30% respondents said

they have seriously considered dying by suicide — a percentage that increased by a whopping 60% over the past 10 years.

Not many studies of a similar nature are available in India but a recent report by the Statistics Ministry has come up with some eyeopening data relating to the field of finance. Thanks to the Central government’s sustained initiatives in recent times, women now own over one-third of deposit accounts in banks. However, the report reveals that only one fifth of the total deposit amount in scheduled commercial banks is owned by women. Also, only one of four bank employees are women and not even one-fourth of the female population holds managerial position across these financial organisations.

We have reason to believe that ever since the pandemic and subsequent economic turmoil, the lot of women in the country is going from bad to worse. This is because, in gender stereotyped households and patriarchal, if not misogynist societies, women suffer the worst when an economic downturn happens.

Research has shown that the share of women in household economic wealth shrank at a faster clip as mirrored in their access to education, health and other facilities. This deprivation of women in household economic resources is more often than not taken for granted.

This may explain the poor ranking that India got in the Global Gender Gap Index (GGGI) published by the WEF in February 2023. As per the report, India ranked at the 135th position in the GGGI map among the 146 countries covered by the research. To amplify the point, the world's fifth largest economy ranks 11th from the bottom of the pyramid of 146 nations. What is more alarming is the fact that our position has not changed much since the composite index was launched in 2006. GGGI ranks countries on a range of variables covering economic, political, education, health and employment.

Though there are some debates and disputes about the methodology used to construct the index, the larger truth of deprivation of women at various levels remains

true as daylight. And this should be cause of worry for policy makers at every level as closing the gender gap should be treated as a primary condition for accelerated economic growth and get at the coveted figure of $5 trillion economy. This is because many studies have found that closing the gender gap can also close India’s output gap, the gap between the actual GDP and the potential GDP. A study by global consultancy firm McKinsey & Company has found that the stubborn gender gap is leading to widening the output gap and closing it can add $2.9 trillion by 2025 to the national output, 60% more than the projected GDP by 2025. That is almost 90% of our estimated GDP of $3.58 trillion this financial year.

Therefore, celebrating Women’s Day on 8th of March every year alone is not going to make lives promising for women. To use a fashionable phrase, if today’s fertiliser is tomorrow’s food security, moving to achieve gender parity now will ensure faster economic growth and sustainable development in the future

A CFO and a Trailblazer

The inspiring tale of Mrs Bindu A.L. who braved odds to reach the top of the corporate ladder at Manappuram Finance

The story of Mrs Bindu A.L., the self-made CFO and President of Manappuram Finance, is awe-inspiring, to put it mildly. Born in Potta near Chalakudy in Kerala’s Thrissur, she was the second of peasant couple Lonappan and Rosily’s three children.

Education was not a priority for her dad, especially when it came to his girl child. He was trying to save enough to marry her off once she turned 18. “Luckily for me, there were a few teachers in our neighbourhood and I used to play with their children, so I drew inspiration to study by watching them,” she says. She surprised her teachers and neighbours by becoming the topper in her class in the lower divisions.

“During harvest, my brother and I would take leave from school to help out mom. So, I knew that the choice was to study well and get a job or work in the paddy field,” she says. Her lucky break came in the form of an Air Force job for her elder brother who assured her that she could go on studying to her heart’s

content. Thus, she enrolled for predegree at the St Joseph’s College in the nearby town of Irinjalakuda.

She may have been one of the best performing students in her school but St Joseph’s attracted the cream of students from the district. “I could manage only the fourth group (commerce) with my marks. My wish was for the second group so that I could take up nursing later,” she says. Little did she know that inadvertently, she had made the best career choice of her life! Sister Rose Bastin, one of the teachers, assured the students that the fourth group was gaining in prominence and that they could later try for ‘CA’, a magical acronym that she was hearing for the first time. After clearing predegree in first class, she joined the Panampilly Memorial College nearer home for her BCom.

By the time she cleared the degree with a respectable 73%, she was determined to pursue CA even though there were many naysayers. “They said it was impossible to clear that exam but I wanted to take it up nevertheless. I told myself that even

if I failed, I would still get enough practical training to land an accountant’s job. As ever, my brother was supportive,” she says.

One day, she and her dad went to the office of Mohandas & Associates in Thrissur. “Mohandas sir was impressed with my grades and took me in,” she says. “The firm was in its 10th year but till then, no trainee had been able to qualify in the exam.”

What happened next could perhaps be explained as divine providence, says the deeply religious Bindu. Mohandas deputed her to handle the accounts of Manappuram Finance, a listed company of the region. Even as she gained valuable experience during the articleship, she also went on clearing the various papers of her course, surprising those in the office as well as herself. In fact, she had cleared all but one group in the final exam when a job offer came from Manappuram. “MD sir (Mr V.P. Nandakumar) was impressed with my resume,” she recalls. She joined as assistant manager in June 1998 in

In February this year, the CII chose her as a ‘Leading Woman CFO of the Year’, an award that followed on the heels of her being designated President by her company.

the Thrissur office, which was then the headquarters and bagged her CA degree too not long afterwards.

The following year proved to be momentous for more reasons than one. All of a sudden, Manappuram, shifted its focus from vehicle finance to gold loan. Bindu was deputed to the Valapad office and along with her seniors, they had to frame policies from scratch and prepare documentation. It was the same year that she got married to Mr Benny, an NRI. The gold loan business took off fast and more branches were opened. Soon, Valapad became the head office and the nerve centre of the operations. At the centre of it all was Bindu who grew along with the company. “Those days were hard as we had to put systems in place. I used to stay in the hostel and it was very challenging when I conceived.”

What helped was the constant support from Mr Nandakumar, the visionary leader of Manappuram. Even as the company grew, the main challenge was to get funds as banks were not comfortable lending money to gold loan companies. But first ICICI, then Fullerton and subsequently SBI sanctioned big amounts to support Manappuram’s expansion plans. Achievements

were also accompanied by stiff challenges like the liquidity crisis that the company faced in 2012. After a lot of restructuring and rebuilding, the company was again back on track and Bindu was made the CFO in January 2019. “Rating upgrade was another milestone and that helped in getting the needed credit,” says Bindu. “MD sir and I went and presented our credentials before the rating agency and we got the AA rating.” It was in the same year that she was sent to Harvard Business School for a course. “Our MD is a great believer is continuing education and upskilling. I did a course at IIM Ahmedabad and then the one at Harvard, which was a tremendous learning experience,” she says.

The company reached its peak in the pre-Covid years and is now pursuing a path of vigorous diversification. “It is the trust reposed in me by Nandakumar sir that helped me during this journey of a quarter century,” says the CFO who would complete 25 years in Manappuram in June this year. The dollar bond that the company launched in 2020 and the road show that followed in countries like Hong Kong, Singapore and the UK is another milestone that she cherishes.

Never did she ever feel disadvantaged because of her gender, she says. “There was a time when I had two little kids at home and had to travel by bus late in the evenings every day. MD sir would allow me to leave early but I always made it a point to lead from the front. I think in our dealings with investors and external stakeholders, being a lady was actually an advantage because people treated one with respect.” In February this year, the CII chose her as a ‘Leading Woman CFO of the Year’, an award that followed on the heels of her being designated President by her company. Within days of that recognition, the Thrissur Management Association presented her with the ‘Best Woman Manager’ award.

Awards, for her, are unexpected byproducts of her sustained efforts to pitchfork the company to a trajectory of high growth. “The journey of diversification that we started in 2014 hit some roadblocks because of Covid-19 but now we are back. Every year, we have been coming up with new products, each of which hold a lot of promise. As the fundamentals are very strong, there is no doubt that we can achieve greater heights in the years to come,” she concludes

While there are various indicators that have enthralled the world, there is none more than the digital tools introduced, which amount to more amazement.

Understanding the India Stack…

The last decade has seen India change exponentially. Besides the economics and the demographics, there are a series of various events which has brought these changes in the country. We are also in the clear focus of the world and there is no global expansion for any company of large ambitions, to miss out on India. While there are various indicators that have enthralled the world, there is none more than the digital tools introduced, which amount to more amazement. The armory of these tools has given a different flavor to commerce and the results are phenomenal strides in every walk of life. Together these digital enablers are called the India Stack.

If one can take a deep dive into the stack, the name that chimes everywhere is Nandan Nilekani. Nandan is definitely among the most outstanding pillars of the Indian technology foundation, both in the private and public sectors. He was a co-founder of Infosys, one of the world's largest information technology services fi rms with a market

cap of over $75 billion, and served as the Chairman of UIDAI, which developed many of India's worldclass public digital infrastructure initiatives. The forays into Aadhaar, UPI, OCEN, amongst others created what we put in a ‘pride of place' story and the world looks on with respect and envy – the unique capability of having build tools at the population scale.

There were primarily two reasons how the entire process started. The first was India was increasing its welfare programs and distributing things like pensions, scholarships, unemployment, insurance and so on. The challenge had always been to identify the beneficiaries and also how to authenticate whether the right person is getting the endowment of the government. We needed something like the social security scheme in the US, the ability to identify every individual in the country and authenticate. The second reason was that Indians were transitioning into a migrant society. People were travelling for livelihoods across the length and

breadth of the country and outside the country. While foreign travel had structured regulations, we lacked the means of identification in the domestic circuit. Regular identification tools like the birth certificate, and schools records was non existent for vast tracts of the population. With larger economic development, people were travelling everywhere and it became imperative to have an identification. Both these factors the inclusion need for getting millions of people with identification as well as the fiscal need of making sure that benefits were more efficient led to the genesis of the need for a unique

ID. This was approved by the Indian cabinet in January 2009. And Aadhar was born!

The ID was designed as a digital ID, which means you can do authentication of the ID online and verify it for multiple purposes. The same ID could be used for KYC, or know your customer, which is an electronic know your customer. And with this, it was of immense use to the regulators, it could be used to open a bank account or to get a mobile connection or any transaction that required trust verification.

Then the idea of a digital locker came up, which allowed people to

store their documents on the cloud. And today, the DigiLocker of India has 125 million people who store their ID cards or their vaccination certificates or their driver's license. So basically, the ID with its authentication, KYC, digital signature, and digital locker was one comprehensive suite of programs, which came out. These could be effectively used for the direct benefit transfers of the central government.

During this time, the project of creating a peer-to-peer payment system was envisaged. NPCI (National Payments Corporation of Inda) in May of 2016 launched a payment

platform called UPI (Unified Payments Interface), which was an interoperable peer-to-peer, four-party payment system. What we mean by saying it's four-party is that you could be using a private service like Google Pay and having a bank account in HDFC, and one could be using PhonePe and having a different bank account in a different bank in Punjab National Bank, and we could interoperate and send money in real-time, so any bank account using any consumer app to any other consumer app. This is a unique innovation that's not been done anywhere in the world. This system rolled out 100,000 transactions by October 2016. When demonetization happened and the withdrawal of certain currency notes happened. the need to have digital payments became very, very important. And the government embraced and endorsed UPI. They launched an app called BHIM on UPI, which the Prime Minister launched in December 2016. And then other people came on the platform like PhonePe, Paytm, Google Pay and so on. Today,

about 275 million people are using it for payments. This amounts to close to 7 Billion transactions of billions of dollars!

Then came the Goods and Sales Tax (GST) system. India has an excellent indirect tax system, which is nationally rolled out on the GST, which is again completely digital. There are about 11 million businesses on GST. They all file their returns electronically. And they all submit their invoices electronically to the GST because you get the invoices through the matching of tax credits on GST, which is a valueadded tax system. The system enables great information collateral at work where people get access to credit through this. So suddenly, a whole class of small businesses that was historically starved of credit will now get access to credit, which is a great thing. But the macroeconomic benefit of this is if 10 million businesses get access to credit, and with that, they're able to grow their business.

Once you get access to credit, then the supply chain will get dis-

intermediated or basically get loosened up because as you said, today, the supply chain is both a lender of money as well as a provider of products. And then the other thing which is happening is ONDC (Open Network for Digital Commerce), which is disaggregating commerce and creates an open commerce network. This will ease the access and supply chain for even the smaller business players and create a more vibrant platform for commerce.

Together each of these creates the India Stack. Aadhaar Stack provides one layer, UPI provides one layer, economic and empowerment provides another layer, and ONDC provides another layer. They provide the interoperability and the flexibility to bring most aspects of the business together! These unique public digital goods will enable the current count of 90,000 start-ups, all rearing to go, who will then use these digital capabilities and create products and services that create value for themselves and their investors and create value for the consumers

Dr Arun Oommen

MBBS, MS (Gen Surg), MCh (Neurosurgery), MRCSEd,MBA Senior Consultant Neurosurgeon VPS Lakeshore Hospital NH-47, Bypass, Maradu, Nettoor PO, Kochi 682040, India.

The majority of brain tumours don't have any specific causative factors. The best-known environmental risk factor for brain tumors is radiation exposure.

Basic Facts About Brain Tumours

Brain tumor refers to the formation of abnormal cells within the brain. There are two main types of brain tumors: cancerous (malignant) tumors and indolent (benign) tumors.

Warning signals

Tumours produce symptoms either due to compression or irritation of the brain

1. Headache occurring in the later onset of life and gradually increasing in intensity. There can be constant aching pain without any painfree period in between. Usually, the headache is maximum in the morning and the victim wakes up with a severe headache.

2. Projectile vomiting mostly on waking up in the morning. Here the vomiting may not be preceded by nausea. Vomiting can offer temporary relief to the headache.

3. New-onset seizures can be focal seizures (More significant) involving only part of the body or they can be generalized seizures.

4. Weakness or numbness-

progressively increasing and can involve only one limb or one side of the body.

5. Visual problems especially when it involves the optic Nerve (nerve of vision) or pituitary gland.

6. Cognitive problems occurring suddenly like memory problems, behavioral changes, language problems, confusion, etc.

7. Difficulty in speech, Sudden Gait disturbances, imbalance, in coordination, or weakness of facial muscles.

Risk factors

The majority of brain tumours don't have any specific causative factors. The best-known environmental risk factor for brain tumors is radiation exposure. Impaired immune systems have an increased risk of developing lymphomas (cancers of lymphocytes). In rare cases (5%) brain cancers run in families.

Environmental factors such as exposure to solvents, pesticides, oil products, rubber, or vinyl chloride (a chemical used to manufacture plastics), petroleum products, and

certain other chemicals have been linked with an increased risk of brain tumors. Exposure to aspartame (a sugar substitute) and infection with certain viruses (Epstein Barr virus, human Cytomegalovirus, polyomavirus) are possible risk factors. Relation to Cell phone use, Head injury, Power lines, Diet, Smoking, and alcohol remains controversial.

Treatment

Tumours like Meningiomas, certain Gliomas, Pituitary adenomas, Nerve sheath tumors, germ cell tumours, haemangioblastomas, cavernomas, and certain Lymphomas are curable.

Survival rates in brain tumors depend on the

• Type of tumor, size, area involved, and early detection,

• Age and health of the patient,

• Extent of surgical tumor removal.

The primary and most desired course of action is surgical removal (resection) via craniotomy. Minimally invasive techniques are the trend in neurosurgery. Endoscopic

surgeries are also being done. With the availability of ultramodern operating microscopes, neuronavigation systems, Cavitron ultrasonic aspirators, endoscopes, and other sophisticated instruments along with a better understanding of surgical techniques, the safety and success rate for brain tumour surgery has dramatically improved.

Radiotherapy is the most commonly used treatment for brain tumors. Radiosurgery is a treatment method that uses computerized calculations to focus radiation at the site of the tumor while minimizing the radiation dose to the surrounding brain. Types of stereotactic radiosurgery, include Gamma knife, linear accelerator, and Cyberknife.

Chemotherapy is a treatment option for cancer, and can improve survival in 20% of brain cancers.

Role of pharmacological therapy is limited except for anti-

epileptics (controlling fits) and steroids (reduce brain oedema).

Extensive research and studies are going on for a better understanding of the behavior of different brain tumours and more and more treatment modalities are being tried to fight this dreaded disease. Immunotherapy/ biological response modifier (BRM) therapy, Oncolytic virus therapy. Targeted therapy of faulty genes or proteins, Gene therapy. Hormonal therapy, photodynamic therapy, and Electric field therapy are some of the treatment modalities that may bring hope in the future.

Cell phone and brain tumours

Cell phones give off radiofrequency (RF) rays, a form of energy on the electromagnetic spectrum between FM radio waves and those used in microwave ovens, radar,

and satellite stations. Till now it has not been proven that RF waves can cause brain tumours and at the same time it remains to be proved that RF waves are absolutely safe. It is ionizing radiation that has been proved to cause cancer by damaging the DNA inside cells. Cell phones do not give off ionizing radiation. The International Agency for Research on Cancer (IARC) classified mobile phone radiation as Group 2B - possibly carcinogenic. That means that there "could be some risk" of carcinogenicity, so additional research into the long-term, heavy use of mobile phones needs to be conducted.

Radiofrequency rays emitted from mobile phones have not been proven to cause brain tumours nor have they been proven to be absolutely safe. IARC hence recommends mobile phones be used judiciously

Adv Sherry Samuel Oommen: This article is authored by Adv Sherry Samuel Oommen. Adv Oommen, who specializes in constitution, tax and corporate laws has also cleared the final exams of the Institute of Chartered Accountants of India, the Institute of Cost Accountants of India and the Institute of Company Secretaries of India. He has also completed his Masters Degree in Commerce, apart from obtaining a Post Graduate Diploma in Business and Corporate Laws from Symbiosis Pune. The views expressly are personal and should not be construed as a legal opinion.sherryoommen@nashcp.com.

Withholding Tax On Software-Related Payments - An Analysis

1. Software – Typical business models

Payments towards “software” has been a subject matter of continued litigation. While the tax payer depending on the business model would contend that such payments should not be subjected to withholding tax in India, the Department would contend otherwise. The Department’s contention has been morbidly revolving around the contention that the payments partook the nature of “royalty” under Section 9(1)(vi) of the Income-tax Act, 1961 (“the Act”) and Article 12 of the concerned tax treaty.

The argument of the Revenue stood bolstered when the Hon’ble

Karnataka High Court in the case CIT Vs Samsung Electronics Co Limited [2012] 345 ITR 494 held that payments effected by an Indian company towards import of a shrinkwrapped software partook the nature of “royalty” both under the Act and the related tax treaty. The Hon’ble High Court negatived the argument of the assessee that when any buyer purchases a software, there was no transfer of any intellectual property/ copyright which would entail its classification as “royalty”; on the contrary, all that the assessee did was to purchase a copy of the software without the right to exploit a “copyrighted right”.

Briefly, the dispute surrounding

taxability of software payments revolves around the following business/ operating models:

i. Where a party in India purchases a software from a non-resident supplier for his own use;

ii. Where a party in India purchases a software from a non-resident supplier for further sale – This would typically apply in the case of a reseller of a product;

iii. Where a non-resident after purchasing the software from another non-resident resells it to an Indian distributor or an end user;

iv. Where the software is sold as an integral part of a hardware.

v. Whether the software in question is a customized software or not

The Department’s contention has been morbidly revolving around the contention that the payments partook the nature of “royalty” under Section 9(1)(vi) of the Incometax Act, 1961 (“the Act”) and Article 12 of the concerned tax treaty.

or whether software development service is provided.

vi. At times, entities enter into cost contribution agreements with respect to expenditure incurred for installation and maintenance of computer software. In such a scenario, the overseas entity recharges the cost to the concerned Indian entity.

vii. At times, software is acquired through purchases effected from electronic media, for instance, downloading of a software (say, adobe).

In this note, I intend to delve on the vagaries regarding a copyright and a copyrighted article, whilst also considering the recent judgment of the Hon’ble Supreme Court in the case of Engineering Analysis Centre of Excellence Private Limited [2021] 125 Taxmann.

com 42.

1.1 Distinction between a copyright vs a copyrighted article

Courts in India have dissected payments toward computer software from the prism of whether the payment is towards a “copyrighted right” (aka a copyright) vis-à-vis a copyrighted article. For instance, the Delhi High Court in the celebrated judgment in Ericcson AB [2012] 204 Taxman 192 held that software incorporated as part of the hardware would not be subjected to withholding tax as it was akin to purchase of a good. The High Court in the said case relied on the Supreme Court judgment in the case of Tata Consultancy Services Vs State of AP (2004) 271 ITR 401 where it held that copyrighted software are goods and therefore subjected to

sales tax. The Hon’ble High Court in the said judgment also elaborated on the fine distinction between a copyright and a copyrighted article.

Courts have held that if a person acquires a software without any of the following rights, he only gets a copyrighted article and not a copyright. Broadly, the rights include the following:

• The right to make copies for purposes of distribution to the public by sale or other transfer of ownership, or by rental, lease, or lending.

• The right to prepare derivative computer programmes.

• The right to make public performance of the computer programme or the right to publicly display the computer programme. Sale of a software – A few judgments The Hyderabad Tribunal in the case of Bartronics India Limited

Essentially, the provisions of section 90(2) of the Act provides that the provisions of the Act would apply to the extent they are more beneficial to an assessee in comparison with the corresponding provision of the Double Taxation Avoidance Agreement (“DTAA” or “tax treaty”).

[2014] 62 SOT 141 held that the bundle of facts viewed in juxtaposition with the above-mentioned rights would need to be evaluated in determining whether there is a transfer of a copyright or a copyrighted article.

In another ruling, the Mumbai Tribunal in the case of Kansai Nerolac Paints Limited [2010] 134 TTJ 342 held that a computer software when put on a media partakes the nature of “goods”. Accordingly, the Hon’ble Tribunal held that a payment for the same would not partake the nature of “royalty” under Article 12 of the India-Singapore tax treaty. A pertinent aspect in the case was the fact that the acquirer was granted a right to make a copy, but such right was limited to usage of the same within its own business. However, no source code or a similar content/ element was provided to the acquirer along with the program.

The Authority of Advance Ruling in Geoquest Systems BV [2010] 234 CTR 73 held income from supply for a specially crafted off the shelf software cannot be characterized as “royalty” both under the Act and the India-Netherlands tax treaty. The AAR went on further to hold that such amounts would not partake the nature as “fees for technical services” both under the Act and the India-Netherlands tax treaty. Similar views have been endorsed by the Mumbai Tribunal in Capgemini Business Services (India) Limited [2016] 158 ITD 1, where the transaction in question pertained to downloading of software for enabling use of a product. The Tribunal held that such use would not tantamount

to transfer of a copyright but only that of a copyrighted article which would not fall within the purview of the term “royalty” both under the Act and the related tax treaty. Licensing arrangement – A few precedents

The Kolkata Tribunal in the case of ITC Limited [2017] 79 Taxmann.com 206 held that in the case of a software licensing arrangement, where the software developer had the granted the assessee, a perpetual, non-transferable, irrevocable, non-exclusive and non sub-licensable right in respect of a computer software. The Tribunal observed that the Appellant had only granted a right to use the copyright in the computer software and that the license granted did not constitute a copyright in the software within the meaning of Section 14 of the Copyright Act, 1957. A similar view was also held by the Delhi Tribunal in the case of Datamine International Limited [2016] 48 ITR(T) 229.

2. Beneficial provisions of the tax treaty – Interplay of Section 90(2) of the Act

2.1 Meaning of the term “computer software” in the context of “royalty” under the Act

The term “computer software” has been defined in Explanation 3 to Section 9(1)(vi) of the Incometax Act, 1961 (“the Act”) to mean “any computer programme recorded on any disc, tape, perforated media or other information storage device and includes any such programme or any customized electronic data”.

In the context of computer soft-

ware, the term “royalty” under the Act would comprise of payment/ consideration including lumpsum payment made by a resident for transfer of all or any rights relating to computer software supplied with a computer or computer based equipment by a non-resident manufacturer. This would include payments under any scheme approved under the Policy on Computer Software Export, Software Development and Training, 1986 of the Government of India.

It would also be pertinent to note that Finance Act, 2012 made various retrospective amendments to nullify various interpretation pertaining to the definition of the term “royalty”. One such amendment effected in 2012 was the introduction of Explanation 4 to Section 9(1)(vi) of the Act, which reads as follows:

“For the removal of doubts, it is hereby clarified that the transfer of all or any rights in respect of any right, property or information includes and has always included transfer of all or any right for use or right to use a computer software (including granting of a licence) irrespective of the medium through which such right is transferred.”

As evident, the Act contains an expansive scope, one would also need to consider the provisions of the extant tax treaty. It would also be pertinent to note that a retrospective amendment was also effected through the introduction of Explanation 5 and Explanation 6 to Section 9(1)(vi) of the Act.

2.2 Interplay of Section 90(2) of the Act – Its key contours

The taxability of payments qua a non-resident is required to be determined based on the provisions of the Act and the corresponding provisions of the tax treaty. Essentially, the provisions of section 90(2) of the Act provides that the provisions of the Act would apply to the extent they are more beneficial to an assessee in comparison with the corresponding provision of the Double Taxation Avoidance Agreement (“DTAA” or “tax treaty”). To put it differently, the provisions of the tax treaty would apply if the said provisions were more beneficial than the provisions of the Act.

The overriding provisions of the DTAA vis-à-vis the Act has been upheld in a catena of judgments. For instance, the Hon’ble Calcutta High Court in the case of Davy Ashmore India Limited [1991] 190 ITR 626 whilst considering the correctness of Circular No 333 dated 02 April 1982 issued by the Central Board of Direct Taxes (“CBDT”), held that the provisions of the tax treaty would override the generic provisions under the Act, notably, sections 4 and 5 of the Act. The said view was endorsed by Hon’ble Karnataka High Court in the case of CIT Vs RM Muthaiah [1993] 202 ITR 508, where the Court undertook an evaluation of the contours of section 90 of the Act qua distribution of powers of taxation between the signatories to a tax treaty and there-

upon upheld its sanctity. The said views of the Karnataka High Court in the case of RM Muthaiah (supra) was subsequently affirmed by the Hon’ble Supreme Court in the case of Azadi Bachao Andolan [2003] 263 ITR 706. The overriding provisions contained in section 90 of the Act was also upheld by the Hon’ble Gujarat High Court in the case of Arabian Express Line Limited [1995] 212 ITR 31.

The Hon’ble Supreme Court of India in the case of Azadi Bachao Andolan [2003] 263 ITR 706 fortified the said doctrine. In the said judgment, the Hon’ble Supreme Court noted the following key principles of law, which have been summarised below in the ensuing paragraphs:

• The power to enter into a tax treaty stands circumscribed by section 90)(2) of the Act. The power to enter into tax treaties to the Central Government was through the issuance of a notification having regard to section 90(2) of the Act.

• Once the requisite notification was issued under section 90(2) of the Act by the delegate, ie, the Central Government, the concerned assessee is entitled to seek the benefits under the concerned tax treaty even if the provisions of the tax treaty were inconsistent with the provisions of the Act.

• After a combined reading of sections 4 and 5 of the Act, the Court

held that the said sections were embedded with the phrase “subject to the provisions of this Act.”. Consequently, the provisions of section 90 of the Act would take precedence over the provisions of sections 4 and 5 of the Act. The Hon’ble Court accepted the dictum of the Hon’ble Andhra Pradesh High Court in the case of CIT Vs Vishakapatnam Port Trust [1983] 144 ITR 146.

• The Court held that the principles governing interpretation of tax treaties are not the same as those in the interpretation of a statutory legislation. Treaties should be seen in the context of “aiding commercial relations” between treaty partners, and a “bargain” agreed to between treaty countries as to the division of tax revenues between them in respect of income falling to be taxed in both jurisdictions.

Quite recently, post introduction of Section 206AA of the Act, the Special Bench of the Hyderabad Tribunal in the case of Nagarjuna Fertilizers & Chemicals Limited (2017) 55 ITR (T) 1, where the Special Bench held that the provisions of the DTAA which by virtue of section 90(2) would override the machinery provisions contained in Section 206AA of the Act. The said principle would apply irrespective of the non-obstante clause contained in section 206AA of the Act and the same is required to be read down in

order to give effect to the provisions of the DTAA.

It would also be pertinent to note that the treaties entered into by India with Turkmenistan, Russia, Romania, Morocco and Trinidad and Tobago specifically include payments for “use of or right to use computer software” within the definition of the term “royalty”. Hence, one could argue that in the absence of such verbiage in other treaties, the same would stand excluded. The said proposition has been endorsed by the Hon’ble Mumbai Tribunal in the case of Qad Europe BV [2017] 53 ITR(T) 259, where the Tribunal held that the payments would not partake the nature of “royalty” inter-alia on the ground that the India-Netherlands tax treaty does not include software while defining the term “royalty”. Moreover, in the said case, the Appellant had given the customer the right to reproduce, which was limited to making it usable for internal purposes and not for commercial exploitation.

3. Key aspects of the judgment of the Supreme Court in the case of Engineering Analysis Centre of Excellence Private Limited [2021] 125 Taxmann.com 42

The Hon’ble Supreme Court in

the case of Engineering Analysis Centre of Excellence Private Limited [2021] 125 Taxmann. com 42 upheld certain key propositions of law which include the following:

• The Court expressly accepted the definition of the term “computer programme” from the Copyright Act, 1957. The Court held that the expression “copyright” has to be understood in the context of the statute which deals with it and thus one would need to consider the provisions of Sections 14, 16, 30 and 52 of the Copyright Act, 1957.

• In order to constitute as “royalty”, there must be parting of any of the seven acts contemplated in Section 14 of the Copyright Act, 1957. Further, the transfer of a material substance does not as a sequitur serve to transfer the “copyright” therein.

• The right to reproduce and the right to use computer software are distinct and separate rights, which should be evaluated separately.

• The insertion of Explanation 4 to Section 9(1)(vi) of the Act cannot apply to any right for the use of or the right to use a computer software even before the term “computer software” was inserted in the statute.

• The Court also held the inser-

tion of Explanation 6 to Section 9(1) (vi) of the Act with retrospective effect from 01.06.1976 was not logical.

• A license from the owner of a copyright which does not conferring of any proprietary interest or license would not fall within the purview of Section 30 of the Copyright Act, 1957. Thus, a non-exclusive, nontransferable license, which merely enables the use of a copyrighted product cannot be reckoned as a license to enjoy any of the rights enumerated in Section 14 of the Copyright Act, 1957. Hence, payments towards such license fees would not partake the nature of “royalty” under the related tax treaty.

It may be noted that the Department has filed a review petition against the above judgment, which is now pending consideration before the Hon’ble Supreme Court. In a recent judgment, the Hon’ble Division Bench of the Delhi High Court in the case of Milestone Systems AS (2023 DHC 1926 DB) quashed the order of the Department and directed the concerned Assessing Officer to consider the judgment in the case of Engineering Analysis Centre of Excellence Private Limited [2021] 125 Taxmann. com 42 despite pending of the review petition. This is indeed a welcome step

About NuvoVivo (www.nuvovivo.com) Rajiv Ambat is the CEO of NuvoVivo, an online health & fitness company that is into medical fitness. He is a well-known speaker and author of the best-selling book - ‘The Midriff Crisis’ and lifestyle expert. Under the guidance of Mr Rajiv, his team at NuvoVivo help their clients manage/reverse lifestyle diseases like diabetes, cholesterol, fatty liver, uric acid, hypertension, PCOS, thyroid disorders, etc.

Breathing RightHow to manage anxiety & hypertension!

Just Breathe!!! Everything's going to be ok; it will reduce your BP and make you feel less anxious!

Sounds pretty simple..isn’t it!?

A normal human being breathes in and out nearly 8 – 15 times in a minute. But did you know almost all of us do not breathe in and breathe out the right way!? So, what is the right way of breathing in and breathing out!?

There are two types of breathing that we can do – chest breathing and the abdominal (or diaphragmatic) breathing!

Chest Breathing

Chest breathing is characterised by the upward and downward

movement of the chest, almost at a rapid pace. This usually happens as part of the sympathetic nervous system, when we are stressed, angry, or frightened, which requires a rapid heart rate, higher blood pressure, etc. to increase the blood flow to muscles as we get into the flight or fight mode. To put it very simple – chest breathing is mostly about stress.

Diaphragmatic Breathing

Diaphragmatic breathing, also known as belly breathing or deep breathing, is a technique where you breathe deeply into your diaphragm, instead of shallowly into your chest. This can be beneficial for relaxation, stress reduction, and overall respira-

tory health.

To practice diaphragmatic breathing, you should sit or lie in a comfortable position and place one hand on your chest and the other on your belly. Then, inhale deeply through your nose, allowing your belly to rise as you fill your lungs with air. Exhale slowly through your mouth, allowing the belly to fall to its normal position. Repeat this process for several minutes. (The hand placed on the chest is to notice and make sure that you are not doing upper chest-based shallow breath) Advantages of diaphragmatic breathing

Diaphragmatic breathing has several advantages, including:

Diaphragmatic breathing reduces stress by activating the parasympathetic nervous system, which is responsible for the “rest and digest” response in the body.

1. Stress reduction: Diaphragmatic breathing can help reduce stress and tension by activating the parasympathetic nervous system, which is responsible for the “rest and digest” response in the body.

2. Improved lung function: By breathing deeply into the diaphragm, you can increase the amount of oxygen that reaches your lungs, which

can help improve lung function.

3. Improved digestion: Deep breathing can help improve digestion by massaging the internal organs and promoting the release of digestive enzymes.

4. Improved sleep: Diaphragmatic breathing can help promote relaxation and reduce insomnia, leading to better sleep.

5. Improved heart health: Deep breathing can help lower heart rate and blood pressure, which can help improve heart health.

6. Improved mental clarity: Diaphragmatic breathing can help improve focus and concentration, leading to better mental clarity.

7. Pain relief: deep breathing can help reduce chronic pain by re-

leasing endorphins.

8. Improved overall respiratory function: Diaphragmatic breathing can help strengthen the muscles used for breathing, leading to better overall respiratory function.

Stress & Anxiety Management

Diaphragmatic breathing reduces stress by activating the parasympathetic nervous system, which is responsible for the “rest and digest” response in the body. The parasympathetic nervous system helps to slow down the heart rate, lower blood pressure, and decrease the levels of stress hormones like cortisol.

When you breathe deeply into your diaphragm, it sends a signal to your brain to activate the parasympathetic nervous system. The process of deep breathing also increases the amount of oxygen in your body, which can help to relax the muscles and reduce feelings of anxiety.

Additionally, deep breathing can

help to release tension in the body by allowing the breath to move into areas of the body that may be holding stress. This can include the shoulders, neck, and chest. Moreover, diaphragmatic breathing can also help to stimulate the Vagus nerve which is the longest cranial nerve in the body that runs from the brainstem down to the abdomen. This nerve plays a crucial role in regulating the body’s stress response and activating the parasympathetic nervous system.

In summary, diaphragmatic breathing can help to activate the parasympathetic nervous system, increase oxygen levels in the body, release tension, and stimulate the Vagus nerve, which can all work together to reduce stress and promote relaxation.

Vagus Nerve Stimulation

As discussed, the vagus nerve is the longest cranial nerve in the body and runs from the brainstem down to the abdomen. It is a part of the parasympathetic nervous system,

which controls the body’s “rest and digest” functions. The nerve plays a key role in regulating many of the body’s automatic functions such as heart rate, blood pressure, digestion, and respiratory rate.

The vagus nerve also plays a role in regulating the body’s stress response. When the nerve is stimulated, it can help to decrease the levels of stress hormones like cortisol and increase the levels of feel-good hormones like serotonin. This can help to reduce feelings of anxiety and promote feelings of relaxation.

Activating the vagus nerve can also have other health benefits. For instance, it can improve heart health by decreasing heart rate and blood pressure. It can also help to improve digestion by increasing the release of digestive enzymes and promoting the movement of food through the gut. Activating the vagus nerve can be done through various activities such as diaphragmatic breathing, yoga, meditation, and certain types of exercise. Certain treatments such

as electroconvulsive therapy (ECT) used for depression also stimulate the vagus nerve.

It’s important to note that some people may have a weak vagus nerve response, which can lead to issues such as chronic inflammation, poor gut health, and anxiety. In such cases, it’s important to consult a doctor or a health professional to find out the best ways to improve the function of the vagus nerve.

Improving Lung Capacity

Diaphragmatic breathing can help to improve lung capacity over time. When you breathe deeply into your diaphragm, you can increase the amount of oxygen that reaches your lungs, which can help to improve lung function.

Diaphragmatic breathing can also help to strengthen the muscles used for breathing, particularly the diaphragm, which is the primary muscle used for breathing. A stronger diaphragm can help to increase the amount of air that can be taken in with each breath, leading to a greater lung capacity over time. Deep breathing can also help expand the alveoli (small air sacs) in the lungs, which can also lead to greater lung capacity.

It’s important to note that diaphragmatic breathing is not a treat-

ment for lung diseases and should not replace any prescribed treatment. However, it can be used as a complementary technique to help improve lung function and breathing capacity in people with lung conditions such as asthma or COPD, under the guidance of a healthcare professional. Are there any Risks to diaphragmatic breathing?

In general, diaphragmatic breathing is considered a safe technique with few side effects. However, if you experience any discomfort or pain while practising diaphragmatic breathing, it’s important to stop and speak with your healthcare provider.

Some people may experience lightheadedness or dizziness when first starting to practice diaphragmatic breathing, especially if they are not used to breathing deeply. This is usually temporary and can be reduced by starting with shorter sessions and gradually increasing the duration as your body becomes accustomed to the technique.

Additionally, for people with certain medical conditions, such as asthma or chronic obstructive pulmonary disease (COPD), diaphragmatic breathing may be harder to perform due to breathlessness,

so it’s important to speak with a doctor or a respiratory therapist before starting. Also, people who have recently had surgery on their diaphragm or have diaphragm paralysis should be cautious when practising diaphragmatic breathing and consult a doctor before starting. Finally, it’s important to note that diaphragmatic breathing is a complementary technique and should not replace any treatment prescribed by a healthcare professional.

Can heart patients do it?

Diaphragmatic breathing can be beneficial for heart health, as it can help to lower heart rate and blood pressure. However, it is essential for heart patients to consult with their healthcare provider before starting diaphragmatic breathing, especially if they have any specific heart condition. For example, for people with heart failure or other cardiac conditions that make it hard for them to breathe, diaphragmatic breathing might be harder to perform and might cause discomfort.

Overall, diaphragmatic breathing can be a safe and beneficial technique for heart health when performed under the guidance of a healthcare professional, and it can be used as a complementary technique to help improve heart health

Dolly Maria is founder of THE IGNIST, a training company born out of a noble cause and spirit. She holds a decade long experience being a passionate mentor and entrepreneur.

There is no point ever waiting for the time to be right to do what you always wanted to do – Time might never be always perfect.

WHO LOOKS OUTSIDE, DREAMS!

This April we are celebrating Vishu and the Resurrection Sunday, and is also the financial year beginning month of the year. Vishu is the harvest festival and the Hindu new year in Kerala. Easter reminds us not to give up hope to resurrect miraculously amidst the inevitable challenges of life. To reawaken, regenerate, to resuscitate, to come back to life has been the pattern of every single successful person if you study history.

Life doesn't fail to throw all the setbacks, frustrations, hurdles, anger, disappointments and losses throughout its journey. Sometimes life takes you to the summit of success, sometimes it brings you to its knees just to teach lessons significant for the next phase. Winning at life means a lot to observe those

patterns keenly, understand yourself at your best, learning and building up the values/goals/discipline to make the right persuasive turn ahead. Knowing how to put on the best winning performance inorder to surf smoother through life should always be a priority learning. One very important learning here is to show gratitude for the journey you have already travelled. Nothing, absolutely nothing, in this life is a coincidence. Everything that happens to you, is happening for you. Every single success, failure, challenge, reward, or setback is taking you closer to the person life wants you to be. We just need to be open and ready to learn what life teaches at the pros and cons. An open learning mind while you are beaten down will take you unimaginable leaps ahead of the successful times of your life. That's

when being grateful always helps you to keep yourself grounded and at the right receiving end. If you can see how and what life is trying to teach you through your hard times, that's when you really get to be successful at the next swing. Being in denial or being defensive in the dark times is only going to be detrimental to your growth.

Planning is important even while you face setbacks. I'd suggest journaling through your life. Our memory is pretty weak at times. We do not tend to remember every single event or happenings in our past. That's when writing down your life events helps you go back and take significant learnings from your own life changes. We tend to forget the past when we are in our good times and go with the flow. But life is not always about mornings – There are

nights too. There will always be. Along with joys, you will have sorrows. With a lot of wins, you’ll always endure losses – whether it be material things or people. Human beings are still not able to win it all, unfortunately. That's when advance planning helps. Like I mentioned before, you

need to keep ready for the contingency planning even when you are soaring at your best. Saving for your rainy days. Indeed your real strength is always shown when you confront hardships. Your good times always should be a preparation ground for it – Vice versa, your bad times also should

be your preparation and expectation time for your imminent good times. Setting clear compelling goals, which reminds you of your inner strength and visions, will be a motivating factor. Empowering goals always act as a catalyst and fuel for your life and accelerate your efforts to fruition.

Always have clear specific visions for your life. Don't worry about others not validating your desires. Your goals should be bigger than your current circumstances. If you truly desire to have your goals met with all your heart, one day it will definitely come to fruition and you will be glad that you never gave up on your dreams. Every action first starts with a thought – the thought is your seed. We just have to make sure we nurture that seed enough so that we don't let it die anytime, unless we see the fruits out of the

enormous tree it grows into. No matter how big or unachievable your dream seems today, be rest assured that you will see it in reality as long as you don't give up on it. Manifestation is real. Keep watering the seed until you see it in your reality. You are the one who creates your own reality. Keep affirming to yourself victory-phrases and keep believing, and keep putting in planned efforts and never step back from your belief. It is indeed your faith that is the fertiliser to the growth of your dream. Who else will believe in your dream if

you don't?! Understand that your current position is never your final destination. No matter what you are or where you are, you always can get to where or who you want to be. Your visions should be an inspiration for you to become the person you always wanted to be. No matter your circumstance or no matter what your age is, nothing is or should be a letdown for you. Anything is possible if you put your mind into it. Remember – it is always the “mind” first. You should have that strong desire to make it happen and keep up your faith.

Most of the times you might not get tell-tale clear signs at your winning. Life is always tricky in that way. Unless you observe and learn it in the longer run, the roads might look vague and ambiguous. And that can cause disappointment and lower your motivation. Look into the patterns of the universe then – it is when you are about to breakthrough, you may face your biggest storm. Most of the time the scariest time is usually before you even start. Once you ven-

ture out, you get to learn faster and adapt. And once you reach the land victoriously then, that doesn't mean that your challenges ended. One should always be prepared for the good n bad, light n dark, night n mornings of life. The most important element to a satisfied content life is your belief in yourself and your dreams. Success is never a final destination; you will have to rendezvous with several setbacks on the go, only to make you stronger. Courage to continue is what

matters. There is no point ever waiting for the time to be right to do what you always wanted to do – Time might never be always perfect. A thousand-mile's journey starts with the first step. You may only see 100 metres ahead and not the entire road. So believe in your own self, take that bold step ahead and never ever ever give up! Luck and destiny always stand by the person who is ready to risk it for what he believes in. You are the Creator of your visions!

OnePlus Nord CE 3 Lite 5G

Rs 19,999 Approximately

 Android v13

 6.72 inches (17.07 cm) Display

 108 MP + 2 MP + 2 MP Primary Camera

 16 MP Front Camera

 8 GB RAM

 128 GB Internal Storage

 5000 mAh Battery Capacity

Rs 94,890 Approximately

 Android v12

 7.1 inches (18.03 cm) Display

 50 MP + 48 MP + 32 MP Primary Camera

 32 MP Front Camera

 12 GB RAM

 256 GB Internal Storage

 4520 mAh Battery Capacity

Xiaomi Redmi K60E

Rs 26,190 Approximately

 Android v12

 6.67 inches (16.94 cm) Display

 48 MP + 8 MP + 2 MP Primary Camera

 20 MP Front Camera

 8 GB RAM

 128 GB Internal Storage

 5500 mAh Battery Capacity

Rs 10,999 Approximately

 Android v13

 6.78 inches (17.22 cm) Display

 50 MP Primary Camera

 8 MP Front Camera

 8 GB RAM

 256 GB Internal Storage

 5000 mAh Battery Capacity

Unlock the Secret to Glowing Skin and Luscious Hair with Bitter Gourd!

Bitter gourd, also known as bitter melon, is a vegetable that has been used for centuries in traditional medicine and cuisine in Asia. It has gained popularity in recent years due to its numerous health benefits, including its ability to improve skin and hair health. Bitter gourd is rich in vitamins, minerals, and antioxidants that are essential for maintaining healthy skin and hair. In this article, we will explore the skin and hair benefits of bitter gourd and how it can be incorporated into your daily routine for optimal results.

Prevents skin aging:

Bitter gourd is a rich source of antioxidants, which help to prevent premature aging of the skin. The antioxidants in bitter gourd neutralize free radicals in the body, which can cause damage to the skin cells and lead to signs of aging such as wrinkles, fine lines, and age spots.

Promotes hair growth:

Bitter gourd is a rich source of vitamins and minerals that are essential for healthy hair growth. It contains vitamins A, C, and E, as well as iron, which are all important for maintaining healthy hair.

Treats acne and pimples:

Bitter gourd has anti-inflammatory properties that make it effective in treating acne and pimples. It helps to reduce inflammation and redness associated with acne, while also controlling excess oil production on the skin.

Prevents dandruff:

Bitter gourd has antifungal properties that make it effective in treating dandruff. It helps to reduce the growth of the fungus that causes dandruff, while also moisturizing the scalp and preventing dryness.

Improves skin texture:

Bitter gourd contains vitamin C, which is important for collagen production. Collagen is a protein that gives the skin its structure and elasticity. Regular consumption of bitter gourd can help to improve the texture and appearance of the skin.

Reduces dark circles:

Bitter gourd has a cooling effect on the skin, which makes it effective in reducing dark circles and puffiness around the eyes. It helps to soothe the skin and reduce inflammation, which can cause dark circles.

Prevents hair loss:

Bitter gourd is rich in nutrients that are essential for healthy hair growth, such as vitamins A and C, iron, and zinc. Regular consumption of bitter gourd can help to prevent hair loss and promote healthy hair growth.

Bitter gourd is a superfood

that is loaded with essential vitamins and minerals that can benefit both skin and hair health. Its antioxidant properties can protect the skin from damage caused by free radicals and improve its texture, while its vitamin and mineral content can promote healthy hair growth and prevent dandruff. By incorporating bitter gourd into your diet or skincare routine, you can enjoy its numerous benefits and achieve healthy, radiant skin and hair.

Stay Healthy! Stay Beautiful!

Exploring charming cities and ancient temples to trekking through lush forests and relaxing on idyllic islands, Laos has something for every type of traveler.

Journey Through Laos: Uncovering Its Charm and Hidden Wonders

Nestled in the heart of Southeast Asia, Laos is a country that is often overlooked by travelers, but it is a hidden gem that is waiting to be explored. Laos is known for its stunning natural beauty, fascinating culture, and friendly people. From exploring charming cities and ancient temples to trekking through lush forests and relaxing on idyllic islands, Laos has something for every type of traveler.

In this travel blog, we'll explore the top things to do in Laos, including must-see attractions, unique experiences, and off-thebeaten-path destinations. Whether you're a first-time visitor or a seasoned traveler, this guide will help you plan an unforgettable trip to this enchanting country. So, let's dive in and discover the best of Laos!

Best Time to Visit Laos

The best time to visit Laos depends on your travel preferences and the activities you plan to do. Generally, Laos has a tropical climate with two distinct seasons: the dry season (November to April) and the wet season (May to October).

The dry season is the most popular time to visit Laos, as the weather is cooler and drier, making it ideal for outdoor activities such as trekking, cycling, and

sightseeing. The months of December to February are the coolest and driest, with temperatures ranging from 15 to 25°C (59 to 77°F), making it the peak tourist season. March to April is warmer and can be quite hot, with temperatures reaching up to 35°C (95°F).

The wet season in Laos can be challenging for travelers due to heavy rainfall and high humidity. However, the lush green landscapes and the reduced number of tourists make it an attractive time to visit. The rainfall also brings about a refreshing coolness in the air. The countryside is particularly beautiful during this time, with waterfalls and rivers in full flow. Be prepared for occasional flooding, particularly in the lowlands, and some outdoor activities may be limited due to the weather conditions.

The best time to visit Laos is during the dry season (November to April) if you prefer cooler and drier weather and enjoy outdoor activities, or during the wet season (May to October) if you want to experience the lush green landscapes and a quieter tourist season.

Explore Luang Prabang

Luang Prabang, a UNESCO World Heritage Site, is a charming city that is located in the northern

part of Laos. It is known for its beautiful temples, French colonial architecture, and stunning natural scenery. Some of the top things to see and do in Luang Prabang include visiting the Wat Xieng Thong temple, climbing up to the top of Mount Phousi for a panoramic view of the city, and taking a boat ride along the Mekong River.

Visit the Plain of Jars

The Plain of Jars is a mysterious archaeological site that is located in central Laos. It is named after the hundreds of giant stone jars that are scattered across the area, and which are believed to date back to the Iron Age. Visitors can explore the site and learn more about the history and culture of the region.

Go tubing in Vang Vieng

Vang Vieng is a small town in central Laos that is known for its stunning natural scenery and outdoor activities. One of the most popular things to do in Vang Vieng is to go tubing down the Nam Song River. This involves floating down the river on an inner tube and enjoying the beautiful scenery along the way. Take a cooking class

Laos is known for its delicious food, which is influenced by its neighboring countries of Thailand and Vietnam. Taking a cooking

class is a great way to learn more about the local cuisine and to try your hand at cooking some traditional dishes. Some popular cooking schools in Laos include Tamarind Cooking School in Luang Prabang and Bamboo Tree Cooking School in Vientiane.

Visit the Bolaven Plateau

The Bolaven Plateau is a highland region in southern Laos that is known for its stunning waterfalls, coffee plantations, and traditional villages. Visitors can take a scenic drive through the area and stop at various attractions along the way, such as the Tad Fane Waterfall and the Pakse Market.

Explore the capital city, Vientiane

Vientiane is the capital city of Laos and is located in the south of the country. It is a charming city that is known for its French colonial architecture, Buddhist temples, and delicious food. Some of the top things to see and do in Vientiane include visiting the iconic Patuxai monument, exploring the Wat Sisaket temple, and trying some local street food at the night market.

Go trekking in Northern Laos

Northern Laos is a popular destination for trekking enthusiasts, as

it offers some of the most stunning and unspoiled natural scenery in the country. Visitors can trek through lush forests, climb mountains, and explore traditional villages while learning about the local culture and way of life.

Experience the Almsgiving Ceremony

The Almsgiving Ceremony, or Tak Bat, is a daily ritual that takes place in Luang Prabang. It involves Buddhist monks walking through the streets at dawn to collect food offerings from local residents. Visitors can observe this traditional ceremony and learn more about the Buddhist culture of Laos.

Visit the Kong Lor Cave

The Kong Lor Cave is a massive limestone cave that stretches for

over 7 kilometers. Visitors can take a boat ride through the cave and marvel at the stunning rock formations and underground river.

Relax on the 4,000 Islands

The 4,000 Islands, also known as Si Phan Don, is a group of islands located in the southern part of Laos. It is a popular destination for travelers who want to relax and unwind in a peaceful and natural setting. Visitors can explore the islands on foot or by bicycle, swim in the Mekong River, and observe the local way of life in the traditional villages.

Learn about the UXO problem

Laos is one of the most heavily bombed countries in the world, with an estimated 80 million unexploded bombs still scattered throughout the

country. Visitors can learn about the UXO problem and its impact on the local population at the UXO Visitor Center in Luang Prabang.

Attend a festival

Laos is home to many colorful and lively festivals throughout the year, which are a great way to experience the local culture and traditions. Some of the most popular festivals include the Boun Bang Fai Rocket Festival in May, the Boun Ok Phansa Festival in October, and the That Luang Festival in November.

These are just a few more ideas to consider when planning your trip to Laos. The country has so much to offer, and whether you're interested in adventure, culture, or relaxation, you're sure to find something to suit your interests

Vivek Venugopal is one of India’s top automotive writers with over a decade’s experience in road-testing and reviewing cars. He is currently the Editor of Quarter Mile magazine and a columnist in several leading magazines and newspapers. He is also a highly sought after consulting engineer and market analyst for many automobile manufacturers.

Citroen eC3

Citroen promised a model onslaught and they seem to be delivering on that with the new C3 electric. The new eC3 is their most significant launch this year aimed at the budget end of the EV market and plugs the gap between the Tiago EV and Nexon EV. We sample one, although briefly, on a test track in Chennai and here are the initial impressions.

From the outside, there is very little to tell the eC3 apart from the petrol versions. The right-side front fender has a charging port, there are a few badges and that’s it. Citroen has always maintained that the C3 is a hatchback and not an SUV like everything these days. It was designed to have an EV variant right from the beginning. The eC3 has its battery pack underneath which

reduces the ground clearance from 180 to 170mm. The Citroen eC3 has a 2540mm wheelbase which is the biggest in its class, as a result of which, the battery pack sits as one unit under the floor, unlike the split arrangement in a Tiago. The floor height inside the cabin has gone up by 70mm though. The boot remains uncompromised at 315 litres and there is a spare wheel underneath.

The interiors are the same with 10-inch touchscreen taking centre stage. It has logically laid out menus, support for wireless Apple Car Play and more functionality this time around. The drive selector is a toggle switch that looks neat. The small LCD screen for the driver is basic and now shows range and battery percentage. There is a manual day and night mirror now, but no climate control, no keyless entry, no

Powering the eC3 is a 29.2kWh battery pack that’s air-cooled rather than liquid-cooled. Citroen proudly says the development of the eC3 took only six months so it is yet to see a summer. Long-term reliability and how the battery performs in hot weather needs to be seen.

push button start, height adjustable seat belts, rear AC vents, no reverse camera, no electrically adjustable mirrors, no rear wash/wipe or defogger. The front seats have a smaller frame, but are very decently padded with good under-thigh support. The rear seat has lots of support but due to the raised floor, passengers now

have to sit knees up.

Powering the eC3 is a 29.2kWh battery pack that’s air-cooled rather than liquid-cooled. Citroen proudly says the development of the eC3 took only six months so it is yet to see a summer. Long-term reliability and how the battery performs in hot weather needs to be seen. Batteries

mainly heat up during charging and discharging and in the eC3, charging speeds and motor power output have been restricted a fair bit. The motor produces only 57bhp but it’s torquey, with 143Nm. It is slow off the line and performance gets slightly better after it picks up speed to about 40kmph. The top speed has been

With a stiff chassis, mature dynamics, and a willing engine, you can have a lot of fun with the C3.

limited to 107kmph. Since it was a test track, we couldn't test the real-world usability of the motor. Citroen says you can fast charge it as many times as you like and the battery can take it. Charging from 10-80 percent takes an hour in a DC fast charger and 10-100 percent takes 10.5 hours in a 15A wall socket. We expect it to do 210230kms on a full charge. It should be adequate for most people looking for a city hatchback. What complements the engine is a good chassis. They have given it very good suspension compliance which combined with the 195/65

R15 tyres and a good amount of suspension travel, can take on any bad road. It is so composed on broken roads, it almost feels like a rally car underneath. While it’s no C5, the ride is extremely supple for this segment, helped by the long wheelbase and the wide track. The steering isn’t the most precise unit around and the soft suspension makes it roll a bit, but the C3 is predictable and neutral around corners. With a stiff chassis, mature dynamics, and a willing engine, you can have a lot of fun with the C3.

In a segment where features

are just as important as the price, the C3 loses out on even the basic amenities. For people who want to buy it as a city car, there is also no automatic transmission option. It is sad because underneath it is a solidly engineered car. The chassis is good, the suspension is excellent and the turbocharged engine is very likeable. We can't help but think that if Citroen did the engineering and took the car to Hyundai or Kia who would then add all the features, we would have ended up with the perfect small car. Now it all comes to how well they price it

Tu Jhoothi Main Makkaar

"TuJhoothi Main Makkaar" is a delightful romantic comedy directed by Luv Ranjan that will leave you in splits with its witty one-liners and charming performances. Starring Ranbir Kapoor and Shraddha Kapoor in the lead roles, the film follows the story of a young man who prides himself on his ability to manipulate and win over women, until he meets his match in a girl who is equally adept at the game of love. The film is a rollercoaster ride of hilarious situations and unexpected twists, as the two leads engage in a battle of wits to outdo each other. With Dimple Kapadia and Anubhav Singh Bassi delivering memorable performances in pivotal roles, the movie keeps you hooked till the very end. Ranbir Kapoor shines in his portrayal of the smooth-talking ladies' man, while Shraddha Kapoor delivers a stellar performance as the sharp and witty woman who refuses to fall for his tricks. The chemistry between the two actors is palpable and makes for an entertaining watch. It is a perfect blend of romance, comedy, and drama, and is a must-watch for all those who love a good romantic comedy.

Mrs Chatterjee Vs Norway

"Mrs Chatterjee Vs Norway" is a compelling legal drama that tells the heartbreaking true story of an Indian mother's battle against Norway's foster care system to regain custody of her children. The film, written and directed by Ashima Chibber, boasts a talented cast led by Rani Mukerji in the titular role. Rani Mukerji delivers a powerful and nuanced performance as Mrs Chatterjee, portraying the character's determination and resilience in the face of tremendous adversity. Anirban Bhattacharya is equally impressive as her lawyer, bringing a sense of gravitas to the courtroom scenes. The film also explores themes of cultural differences and the challenges faced by immigrants in navigating unfamiliar legal systems. Neena Gupta and Jim Sarbh deliver solid supporting performances as key players in the legal proceedings. It is a must-watch for anyone interested in legal dramas or human-interest stories that explore the complexities of the human experience.

Bholaa

Bholaa, the latest offering from director Ajay Devgn, is an Indian action-thriller film that is a remake of the 2019 Tamil hit, Kaithi. The film boasts of an impressive star cast that includes Ajay Devgn, Tabu, Deepak Dobriyal, Sanjay Mishra, Gajraj Rao, and Vineet Kumar, with special appearances by Amala Paul, Abhishek Bachchan, and Raai Laxmi. The movie follows the story of Bholaa, a man who has spent the last ten years of his life in prison and is finally released to reunite with his daughter. However, his journey home is far from easy, as he must navigate through a series of crazy obstacles, with death lurking around every corner. The film's direction by Ajay Devgn is top-notch, with the action sequences and thrill factor being the highlight of the movie. The performances by the ensemble cast are also noteworthy, with Ajay Devgn and Tabu delivering powerful performances that leave a lasting impact on the audience. The plot is gripping and keeps the audience on the edge of their seats, with several unexpected twists and turns that add to the overall excitement.

Bheed

"Bheed" is a powerful social drama film that captures the chaos and fear that emerged during the 2020 COVID-19 lockdown in India. Written, directed, and produced by the talented Anubhav Sinha, this film is a fictional story that explores the impact of the lockdown on a group of East Indian workers who hit a checkpoint. Rajkummar Rao delivers a compelling performance as the lead character, and he is supported by an outstanding cast that includes Bhumi Pednekar, Dia Mirza, Ashutosh Rana, Pankaj Kapur, and Kritika Kamra. Each actor brings depth and nuance to their respective roles, and the result is a film that is both emotionally powerful and thought-provoking. The film highlights the struggles of migrant workers and the inequalities they face, which became even more pronounced during the pandemic. Director Anubhav Sinha masterfully weaves together different storylines, providing a nuanced and complex portrayal of the impact of the pandemic on Indian society. With its powerful performances, nuanced storytelling, and timely message, this film is sure to leave a lasting impression on viewers.

Author : Ann Napolitano

Hello Beautiful

Price : `1,420 (Hardcover)

InAnn Napolitano’s latest release, Hello Beautiful, readers are introduced to William Waters, a college basketball player who finds solace on the court after a lonely childhood. When he meets Julia Padavano, he becomes a part of her close-knit family, but little does he know that he will become the wedge that drives them apart. Napolitano’s writing is simply superb and her ability to weave together different themes into a relatable and realistic story is nothing short of impressive. The characters in this book are so richly drawn that they come to life on the page, making it impossible not to feel deeply invested in their lives. One of the standout themes in Hello Beautiful is family and sisterhood. Mental health is another key theme that is handled with sensitivity and nuance. Napolitano portrays the characters’ struggles with mental health in a way that is both empathetic and honest. This book is the ultimate book club read, as it provides so much material for discussion. It is a masterpiece that will stay with you long after you turn the final page.

Stateless

IAuthor : Elizabeth Wein

Price : `1,125 (Paperback)

n “Stateless,” Elizabeth Wein takes us back to Europe’s first air race for young adults in 1937. The protagonist, Stella North, is the only female pilot in the competition and is excited to be a part of it. The world is on the brink of chaos with Spain’s civil war and the rise of Nazi power. Amidst all the turmoil, the air race becomes a beacon of hope. However, the competition soon turns deadly when one of the pilots is killed. Each of the pilots has a dangerous past to hide, and Stella finds herself embroiled in a cutthroat race for survival. The author does a fantastic job of building tension and keeping the readers guessing until the end. Stella North is an excellent female protagonist – sharp, clever, and confident. The descriptions of flying are vivid and engrossing, making the reader feel like they are in the cockpit with the characters. The action-packed plot, combined with a cute romance, makes for an engaging and enjoyable read. “Stateless” is a fun and fascinating book that takes the reader on a thrilling adventure through the skies of Europe.

Beyond That, the Sea

Price : `1,314 (Hardcove)

“Beyond That, the Sea” by Laura Spence-Ash is a bittersweet tale of love, loss, and being caught between two worlds. Set during World War II, the story follows the life of eleven-year-old Beatrix Thompson, who is sent away from her home in London to America to escape the dangers of the war. In America, Beatrix finds a new family in the Gregorys, and the story delves into the relationships between her and their sons William and Gerald. The book is told through short vignettes, each from a different point-of-view, and the chapters are brief yet powerful. The author’s writing style is captivating, drawing the reader in with every turn of the page. The characters are well-developed and relatable, and the war years are portrayed in a poignant and realistic manner. As the narrative progresses, the story jumps forward in time, reflecting on the evolution of the relationships between the characters. “Beyond That, the Sea” is a beautifully crafted story that will leave readers moved and thoughtful. The book explores the themes of family, love, and identity in a way that is both poignant and relatable.

What Have We Done

Author : Alex Finlay

Price : `2,538 (Paperback)

WhatHave We Done is a high-octane thriller written by Alex Finlay that will keep you on the edge of your seat from start to finish. The story centers around five former teenagers who share a dark secret from their past. As adults, they have all gone on to achieve success in their respective fields, but their past comes back to haunt them when one of their own is murdered and they are targeted for assassination. While the plot may seem far-fetched and the character development lacking, the fast-paced action makes up for any shortcomings. The narrative is straightforward, with no real nuance or subtlety, but this only adds to the book’s appeal as a mindlessly entertaining read. The five main characters are a diverse bunch, each with their own unique talents and flaws. From the rock star to the former assassin, they all bring something different to the table, making for an engaging read.

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