LAM Proj Write Up (1)

8/4/2019 LAM Proj Write Up (1)

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COMPETITON ADVOCACYLegal Aspects of Management

Submitted To:- Prof C. L. Bansal

Submitted By:- Section A, Group 5

(PGP27023) Jyotirmay Asthana

(PGP27024) Pooja Kalyanker

(PGP27025) K. Rakesh Kumar

(PGP 27026) Karan Daaby

(PGP 27027) Karthikeyan T

(PGP 27028) Manu Hoysala N

(PGP 27029) Mohammed Muntaha Ali


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ContentsMeaning and Significance of Competition .............................................................................................. 2

Benefits of Competition in India ............................................................................................................. 2

Global Scenario ....................................................................................................................................... 2

Background of Competition Policy & Law in India .................................................................................. 2

Need for Competition Laws .................................................................................................................... 3

Competition Act, 2002 ............................................................................................................................ 3

Mission Statement .................................................................................................................................. 4

Main Objectives of the Act ..................................................................................................................... 4

Competition Advocacy Chapter VII, Competition Act, 2002 ................................................................ 5

Successful Competition Advocacy .......................................................................................................... 5

Creation of Awareness about Competition Issues .................................................................................. 6

Role of Competition Enforcement Agencies Worldwide ........................................................................ 8

Competition Law and Trade Associations ............................................................................................... 9

Comparison - INDIAN, US AND EU LAWS .............................................................................................. 10

Empirical Benefits of Competition Laws ............................................................................................... 11

Challenges faced by competition authorities ....................................................................................... 12Conclusion ............................................................................................................................................. 14

Bibliography .......................................................................................................................................... 14


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Competition Advocacy

Meaning and Significance of Competition

Generally in economics, competition is seen as rivalry among firms for a larger share of themarket, which leads to internal efficiency and lower prices for the consumers. Competition

can be defined as a process by which cost efficient production is achieved in a structure

where entry and exit are easy, a reasonable number of players (producers and consumers

are present) and close substitution between products of different players in a given industry

exists.

Benefits of Competition in India

The effect of competition on price and accessibility is perhaps best illustrated with an

example from Indian telecommunications. Tele-density in India has risen from mere 2.32 in

1999to 11.32 in December 200511. Also, there has been a dramatic fall in telecom tariffs

from Rs. 16 per minute to Rs. 1 per minute with increased competition in this sector. Thus

intense competition amongst the various service providers has resulted in improvement in

availability of service at affordable price to the consumers. Similarly, consumers have

benefited from competition in other sectors such as civil aviation, automobiles, newspapers

and consumer electronics.

Global Scenario

Canada was the first country to enact a competition law in 1889 followed by the

United States of America in 1890. The number of countries with Competition laws increased

phenomenally in the past 25 years from 32 in 1980 to 105 in 20062 2. Many more countries

are in the process of enacting competition laws and the numbers are slated to increase

further in the coming few years. Many countries have modernized their competition

regimes in the recent past and India belongs to the family of such nations.

Background of Competition Policy & Law in India

India pursued the strategy of planned economic development since the early 1950s.

In the industrial sector, the main objectives of the strategy were the development of a

broad industrial base with a view to achieve speedy self-reliance and promotion of social

justice. Under the industrial policy, the commanding heights of the economy were to be in

the public sector. The Industrial (Development & Regulation) Act, 1951 and the Monopolies

and Restrictive Trade Practices Act, 1969 (MRTP Act), inter alia, gave the State,

1Economic Survey (2005-06), Ministry of Finance, Government of India

2UNCTAD -Directory of Competition Authorities, 2006.


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comprehensive control over the direction, pattern and quantum of investments. Taking a

cue from report by Expert Group, Honble Finance Minister of India in his Budget Speech on

27th February, 1999 stated that The Monopolies and Restrictive Trade Practices Act has

become obsolete and a new modern competition law is required

Need for Competition Laws

The harm caused by anticompetitive practices by enterprises is so severe, both for

the consumer and the economy, that competition law vests the competition authority with

enforcement powers to investigate and penalize such practices. Through deterrent use of

enforcement powers, competition authorities hope to maintain and promote healthy

competition in the market. However, enforcement alone is not enough to sustain

competitive markets. Thus, competition authorities are usually given a more pro-active

mandate - that of competition advocacy. Competition advocacy, in one part, aims to

strengthen competition awareness and culture amongst market players, thereby

encouraging self-compliance and reducing the need for direct action against erring

enterprises.

Advocacy is often referred to as compliance without enforcement. This explains

why competition authorities in many countries maintain strong awareness programmes.

The other part of Competition Advocacy is in respect of government and regulatory policies.

The effect of these policies on market structure and business behaviour can be even more

pervasive than the activities of individual enterprises. For example, government policies that

affect competition in the market include: sector regulation, trade policy, industrial policy,

disinvestment and privatization, labour policies, procurement and so on. To the extent that

these laws or policies restrict competition, for instance through administered prices,

licensing requirements, entry barriers, preferential treatment, reservations, etc., these can

make enforcement of competition law less effective. A suitable framework of policies (no

doubt keeping in mind wider social objectives) is therefore a pre-requisite for effective

competition in the economy. In this way, Competition Advocacy and enforcement are

mutually complementary. In many countries, the competition authoritys advocacy function

is backed by suitable provisions in the competition law. This gives an added edge and

effectiveness to its advocacy efforts.

Competition Act, 2002

The Competition Act, 2002 was passed by the Parliament in the year 2002, to which the President

accorded assent in January, 2003. It was subsequently amended by the Competition (Amendment)

Act, 2007.


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An Act to provide, keeping in view of the economic development of the country forthe establishment of a Commission to prevent practices having adverse effect on

competition

1) To promote and sustain competition in markets

2) To protect the interests of consumers3) To ensure freedom of trade carried on by other participants in markets, in India,

and or matters connected there with or incidental thereto.

It extends to the whole of India except the State of Jammu and Kashmir. Prohibition of certain agreements, abuse of dominant power and regulation of

combinations

Establishment of Competition Commission of India (CCI) Competition advocacy

Mission Statement

The objectives of Competition Law have been further highlighted in a recent judgment delivered by

Hon'ble Supreme Court as:

"The main objective of competition law is to promote economic efficiency using competition as one of

the means of assisting the creation of market responsive to consumer preferences. The advantages of

perfect competition are three-fold: allocative efficiency, which ensures the effective allocation of

resources, productive efficiency, which ensures that costs of production are kept at a minimum and

dynamic efficiency, which promotes innovative practices."

(Judgment in Civil Appeal No. 7999 of 2010 pronounced on 9th September, 2010)

Main Objectives of the Act

1) Prohibit anti-competitive agreements (including cartels) which determine prices, limit or

control or share markets or result in bid rigging, etc.,

2) Prohibit abuse of dominant position through unfair or discriminatory prices or conditions

(including predatory pricing) limiting or restricting production or development, denying of

market access, etc.,

3) Regulate combinations, (i.e., mergers, acquisitions, etc.) that cause or are likely to cause

an appreciable adverse effect on competition

4) In addition, the Act gives the Commission the responsibility of undertaking competition

advocacy, awareness and training about competition issues.


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Competition Advocacy Chapter VII, Competition Act, 2002

Section 49 under chapter VII of the Competition Act, 2002, gives the following description of

competition advocacy.

1) In formulating a policy on competition including review of laws related tocompetition, the Central Government may make a reference to the Commission for

its opinion on possible effect of such policy on competition and on receipt of such a

reference, the Commission shall, within sixty days of making such reference, give its

opinion to the Central Government, which may thereafter formulate the policy as it

deems fit.

2) The opinion given by the Commission under sub-section (1) shall not be bindingupon the Central Government in formulating such policy.

3) The Commission shall take suitable measures, as may be prescribed, for thepromotion of competition advocacy, creating awareness and imparting training

about competition issues.

The mandate of the Competition Commission of India (CCI) needs to extend beyond merely

enforcing the Competition Law. It needs to participate more broadly in the formulation of

the countrys economic policies, which may adversely affect competitive market structure,

business conduct and economic performance. The CCI, therefore, needs to assume the role

of competition advocate, acting proactively to bring about Government policies, which

lower barriers to entry, promote de-regulation and trade liberalization and promotecompetition in the market place. There is a direct relationship between competition

advocacy and enforcement of Competition Law. The aim of competition advocacy is to

foster conditions that will lead to a more competitive market structure and business

behavior without the direct intervention of CCI.

Successful Competition Advocacy

A successful competition advocacy can be viewed in terms of the following:

1. CCI must develop relationship with the Ministries and Departments of the Government,regulatory agencies and other bodies that formulate and administer policies affecting

demand and supply positions in various markets. Such relationships will facilitate

communication and a search for alternatives that are less harmful to competition and

consumer welfare

2. CCI should encourage debate on competition and promote a better and more informedeconomic decision making.


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3. Competition advocacy must be open and transparent to safeguard the integrity andcapability of the CCI. When confidentiality is required, CCI should publish news releases

explaining the reasons.

4. Competition advocacy can be enhanced by the CCI establishing good media relationsand explaining the role and importance of Competition Policy / Law as an integral part

of the Governments economic framework.

The concept of competition advocacy elucidated in the Report of the High Level Committee

finds its echo in Chapter-VII, Section 49 of the Competition Act, 2002. However, the scope of

advocacy activities to be undertaken have been widened in the Act by including the

measures required for creation of awareness and imparting training about competition

issues in addition to advising the Central Government on policies impacting competition and

measures for promotion of competition advocacy per se. Under the Act, the Commission isrequired to proactively interact with the Government Departments / Ministries, media and

all other stakeholders, such as, the business community and organizations, academia,

consumer organizations and professional bodies, as an advocate of competition, and, foster

conditions to create a more competitive policy regime, market structure and business

behaviour.

Thus, the Commission has to transcend beyond being merely an authority to enforce

competition law, and don the mantle of an advocate of competition and take suitable non-

enforcement measures under section 49, together with the enforcement measures as

prescribed under the Act. Competition law enforcement is both the foundation and the tool

for fostering sustainable competitive markets that result in healthy inter-firm rivalry,

opportunities for new entry, entrepreneurship, increased economic efficiency and consumer

welfare. Competition advocacy can augment these and other benefits of competition. The

measures to be taken under section 49, therefore, should aim to foster a competition

culture where voluntary compliance of competition law becomes a reality and competition

is internalized as a key driver for economic growth and consumer welfare by all the

stakeholders. Competition Advocacy, thus quintessentially means non-enforcement

mechanism for compliance of competition law and creation of competition culture.

In the context of the aforesaid, the Commission envisages the following advocacy activities

to be undertaken as a competition advocate.

Creation of Awareness about Competition Issues

Promotion of Competition Advocacy and creation of awareness about competition issues:

1) The Commission shall endeavour and undertake programmes, activities etc. for the


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promotion of competition advocacy and creation of awareness about competition

issues in India and abroad as considered appropriate by the Commission

2) The Commission may constitute Advocacy Advisory Committee(s) with a view to haveexpert and stakeholder participation and consultation, on continuous basis, to carryforward the agenda of competition advocacy and creation of awareness about

competition issues

3) The Commission may develop and disseminate advocacy literature, including audio-visual and other material with a view to promote competition advocacy and create

awareness about competition issues. For doing so, the Commission may outsource the

professional services as deemed appropriate

4) The Commission may make extensive use of the media, both print and electronic, forpromotion of competition advocacy and creation of awareness on competition issues,

and, for this purpose may, inter-alia convene media meets, issue press notes, arrange

publication and dissemination of articles/news, release advertisements and undertake

other publicity related activities on competition issues as deemed appropriate

5) The Commission shall proactively interact with the organizations of stakeholders,academic community, sectoral regulators, Central and State Governments, Civil society

and other organisations concerned with competition matters and encourage debate on

competition and promote a better and more informed economic decision making.

6) The Commission may undertake studies and market research for the purpose ofcompetition advocacy and creation of awareness about competition issues

7) The Commission may assume the role of a competition advocate and proactivelyinteract with the Central and State Governments and other bodies in legislative policy

and other areas, such as, but not limited to, trade liberalization, economic regulation,

state aids, disinvestments; to bring about policies that lower barriers to entry, promote

de-regulation and trade liberalization and promote competition in the market place. For

this end in view, the Commission may, inter-alia, undertake studies and research on the

Central and State Government policies, and, arrange for the dissemination of the

reports thereof as deemed appropriate

8) The Commission may encourage the academic and professional institutions to includecompetition law and policy in the curricula administered by them

9) The Commission may encourage and interact with the organizations of stakeholders,academic community, sectorial regulators, Central and State Governments, Civil society


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and other organizations concerned with competition matters to undertake activities,

programmes, studies, research work etc. relating to competition issues and may

support such endeavours financially as considered appropriate.

According to Section 49(3) of the Competition Act, 2002, the Commission is required to takemeasure to promote competition advocacy, creating awareness and imparting training

about competition issues. Advocacy means competition promotion through non

enforcement measures. For promotion of competition advocacy and creation of awareness

about competition issues, the commission may,

Undertake appropriate programs/activities Encourage and interact with the organization of stakeholders, academic community

etc. to undertake activities, programmes, research work etc. on competition issues

Encourage academic/professional institutions to include competition policy and lawin their curriculum Facilitate advocacy seminars and workshops

Role of Competition Enforcement Agencies Worldwide

Denmark

In Denmark, the competition authority regularly screens markets to identify dysfunctional

ones. The authority, after consultation with relevant sector ministries, publishes detailed

recommendations on some selected markets, on how regulation could be better designed

to enhance competition.

UK

In UK, under instruction from the Cabinet Office, all government offices are obliged to

assess the impact of proposed laws on competition. Along with the Office for Fair Trading,

the Cabinet Office provides to regulators and ministries advice on how to avoid restrictions

of competition. The process of Regulatory Impact Analysis (RIA) includes applying a

competitionfilter; where a proposed law fails the initial simple assessment it is subjectedto undergo a detailed assessment.

United States of America

In the United States, the Federal Trade Commission (FTC), under an active advocacy

programme, intervenes in a number of regulated sectors such as airlines, rail,

telecommunication, electricity and financial services. The Office of Budget and

Management of the US government has published guidance on regulatory analysis which

brings out the risk of unintended harms and side-effects which might impede marked

efficiencies.


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Australia

In Australia, under its National Competition Policy introduced in 1995, it is mandatory for

government departments and other authorities to prepare a RegulatoryImpact Statement

for existing and proposed regulations whichinter alia seeks to move towards best practice

regulatory design that incorporates the principles of competition. It must be establishedthat the benefits to the community outweigh the costs and that the governments

objectives can be achieved only by restricting competition. The government has brought out

A Guide to Regulation for this purpose.

Turkey

In Turkey, under the competition law, the competition authority is empowered to provide

its opinion on competition aspects of law and regulation. A communiqu issued by the

Prime Minister in 1998, urges government ministries and agencies to consult the

competition authority in advance about proposed regulations and decisions that may haveimplications for competition.

Eurozone

The European Court of Justice has encouraged national competition authorities in the

European Union to critically examine legislation which frustrates the objective of the

European competition rules. The European Commissions own Impact Assessment

Guidelines include a specific test to assess the competition impact of new EC legislation. In

terms of these guidelines, it must be examined whether the proposed legislation could

create any restrictions on competition, directly or indirectly, and whether the legislative

objective can be achieved through less restrictive means. The OECD and International

Competition Network have both done considerable work on the advocacy role of

competition authorities. The OECDs Guiding Principles on Regulatory Policy and

Performance recommend that new and existing regulation should be reviewed with

reference to competition, and Regulatory Impact Analysis should be used in this respect. It

further suggests that the competition authority should be empowered to advocate pro-

competition reform. Similarly, UNCTADs Model Law on Competition recommends that

proposed economic legislation and regulation should be subject to ex ante.

Competition Law and Trade Associations

What is the connection between competition law and a trade association such as an

industry association or a chamber of commerce? Plenty--if you see the competition law

carefully and traverse the history of antitrust litigation involving trade associations.

Competition law typically prohibits three kinds of activities by enterprises. It condemns

cartels and other anticompetitive agreements. It prohibits abuse of dominant position by a

firm. And it bars mergers and acquisitions that can have anticompetitive effects. It is the

first category of anticompetitive agreements that must most concern trade associations.

Agreements may be horizontal-- between competitors making similar or substitutable


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products (such as sugar, cement, steel or tyres), or vertical agreements between

enterprises at different stages of the supply chain, such as between a manufacturer and a

distributor.

Trade associations make a positive contribution to the economy, particularly to the specific

industry they represent. They can legitimately lobby the authorities to resolve problems

facing the industry, or create awareness about new laws or taxes or environmental issues,

or ready the industry to meet new challenges. But the very fact that an association brings

together competitors presents the risk that they will enter into an agreement that might

violate the competition law. Any such agreement held under the auspices or cover of a

trade association, can spell trouble for not only the conspiring firms but also for the

association and its office-bearers. The most serious violations are agreements to fix prices,

allocate territories or customers, collude in submitting bids (or bid rigging), or resort to

group boycotts (of non-cooperating members). These are naked restraints of trade or hardcore cartels. Such agreements are regarded per se violations and the most severe penalties

under competition law are usually reserved for such infringements of the law. In several

countries, cartels are treated as criminal offences, carrying prison terms apart from huge

penalties

Comparison - INDIAN, US AND EU LAWS

INDIAIn Indian law, a foreign entity desiring to enter into a combination outside India which

affects the relevant market in India, must give a notice to the CCI in the prescribed form to

establish the same. The Competition Commission of India has the power to extend its

jurisdiction beyond the Indian shores and declare any qualifying foreign merger or

acquisition which affects the relevant market in India as void. CCI can exercise its power by

way of entering into arrangements and memorandum of understandings with the regulatory

bodies of other countries in order to facilitate the entire process.

UNITED STATES

In US law, when a person, including foreign nationals whose activities affects the trade in

United States, acquires any voting securities or assets of any other person then both the

persons shall file a notification in such form and contain such documentary material and

information relevant to a proposed acquisition as is necessary and appropriate to enable the

Federal Trade Commission and the Assistant Attorney General to determine whether such

acquisition may, if consummated, would not violate the antitrust laws. However, the person

shall file such notification only when the waiting period stated in S. 18a of Clayton Act of

1914 has expired.


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EUROPEAN UNION

Article 4 of the Merger Regulation3 of European Commission states that merger shall be

notified to the Commission prior to its notification. It shall be notified jointly notified by the

parties to the merger or by those acquiring joint control. They shall also publish the fact of

the notification, at the same time indicating the names of the undertakings concerned their

country of origin, the nature of the concentration and the economic sectors involved. The

parties shall make a submission to the Commission prior to the notification stating that the

merger significantly affects competition in a market within a Member State which presents

all the characteristics of a distinct market and should therefore be examined. The decision

whether or not to refer the case shall be taken within 25 working days starting from the

receipt of the reasoned submission by the Commission. Articles 1-5 of Implementation

Regulation

4

of European Commission also makes it more or less obligatory for the parties tofile pre-filing notification as failure to comply with the obligation to notify renders the

parties liable to fines and may also entail civil law disadvantages for them.

COMPARISON

From the above analysis we observe that the procedure for pre-filing notification is similar

throughout the world. The Competition Act throughout the world has been enacted to

protect the consumers, society and the business community. The pre-filing notification is

effective in cases where the transaction is going to affect competition beyond one membernation. It proposes whether the proposed transaction violates the Competition law. Each

jurisdiction has a mandatory merger notification based on targeting parties to "large

transactions" which must notify the agency, supply required information for the review of

competition issues and wait for the lapsing of established time periods before they can

legally complete the transaction.

Empirical Benefits of Competition Laws

Australia:

Average household income was up by $ 7,000/- per annum on account of thecompetition Policy (APC study quoted by OECD).

Gains from reform ~ 5.5% of GDP (Paul Crampton, OECD-IADB).

3

COUNCIL REGULATION (EC) No 139/2004 of 20 January 2004 on the control of concentrations betweenundertakings (the EC Merger Regulation)4

Implementing Council Regulation (EC) No 139/2004 on the control of concentrations between undertakings


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EU

White Paper on Growth, Competitiveness and Employment, 1993-Ensuring fair competition

in market is essential ingredient for enhancing and maintaining competitiveness in the

economy.

New Zealand, UK

Pro-competition policy in New Zealand and UK added around 2.5% to their employment rate

over 1978-1998 (OECD).

USA

Fall in prices following deregulation of certain industries.(OECD). In 1990s, competition

contributed most to economic growth; raised productivity by 4% p.a. (Paul

London)

India

Benefits since reforms - increased consumer welfare, enhanced growth, greater competitiveness.

Challenges faced by competition authorities

Despite the obvious argument in support of having a modern competition law, competition

authorities everywhere have not necessarily travelled an easy road. Many authorities havebeen making a signal contribution to economic growth and consumer welfare. But success

and recognition have often been a long and hard way in coming. Some common challenges

that have been faced by newly established competition authorities in developing countries

include:

1) Promoting the competition culture and awareness in the country. Competition istypically an abstract subject, and it is often hard for the ordinary consumer to

appreciate a direct relationship between competition and his interests. Many

competition authorities have invested substantial time and resources in getting this

message across. In UK, the competition authority undertook a long and sustained

programme of advocacy and awareness, which is regarded as having being quite

successful. It is also necessary to build a broad body of stake holders having adequate

knowledge of competition issues and having a stake in promoting compliance. The

competition authorities also need to strategize and concentrate initially on cases that

will demonstrate the benefits of their decisions, which sometimes may not be obvious

in the short term.

2) Building support amongst policy makers. Competition is a cross sectorial discipline, andit can be impacted, adversely or favourably, by the policies of several Ministries,


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authorities including regulators, and state governments. This will call for effective and

extensive advocacy, with the support of the Ministry of Company Affairs. Without such

backing by Government authorities, fresh hurdles can arise from time to time and from

unexpected quarters. In respect to regulators, it is necessary to have competition on

their policy agenda, to have clarity on jurisdiction issues, and harmony in work.

3) Unlike some sectorial regulators, competition authorities almost everywhere do nothave sufficient source of revenue of their own, and have to depend on Government for

budgetary support. This can be a severe constraint in effective competition oversight,

and in maintaining autonomy in work. In some countries e.g. Turkey, the competition

authority gets funds from an earmarked source like a cess on registration of companies.

Even in smaller countries like Mexico, the budget allocation from Government is

substantial. It will be necessary for Government to assure adequate funding for the CCI

4) Competition authorities need to establish a reputation for professionalism, credibilityand independence. Their proceedings are to be underpinned by expert analysis of

economic data and deep understanding of the economic and legal issues involved. They

need expert staff e.g. for investigation, economic analysis, application of legal

principles, and communication. Key members of the staff also have to be in position

well before the full range of functions of the Commission commence, so as to enable

capacity building, training, etc. to be undertaken prior to the regulatory and

adjudicatory work, as opposed to learning on the job. In our own country, economic

data in a form that can be readily used by the CCI may not be available. Data sources

therefore have to be developed.

5) The competition authorities decisions are normally subject to judicial review. Thequality of their decisions must stand judicial scrutiny; this will enhance the authorities

effectiveness and the respect they enjoy. An organization that has a reputation for

professionalism, independence, credibility, and transparency, will have an easier

journey in this respect.

These are only illustrative of the range of challenges that the Competition Commission mayalso face in India. Some of these are quite daunting, and will no doubt require the support

of the Ministry of Company Affairs, other Ministries and also the professions in full measure.

The legal profession and the economics discipline have been closely involved in our work for

quite some time, and we are enthusiastic about the involvement of the chartered

accountants, the company secretaries, and the cost accountants for adding value to our

activities, and building up their action plans to carry forward the cause of competition.


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Conclusion

Consumers and Economy as a whole is benefitted when there is efficient functioning of the

markets which means that there is a healthy competition among all the players in the market. A

competition enforcing authority is extremely necessary to ensure this. Apart from the enforcing

tasks of this agency, it is imperative that such an agency moves beyond mere enforcing of the lawand builds the environment and culture of competition. Apart from bringing that culture of

competition among the market players it is also very important to educate the governments,

government agencies and regulators. The main essence of advocacy lies in the self-compliance of

competition laws which reduces the action against erring companies. A well planned competition

policy would therefore be very beneficial to all enterprises irrespective of their area of operation,

size and nature of products or services rendered. While many commercial activities are covered by

the competition Act, 2002, it is very essential to influence the government interventions outside the

competition laws. Many policies such as consumer protection laws, unfair trade laws, government

policies on registration of new business, trade and FDI policies have to be influenced to ensure the

incorporation of the dimensions of competition. Competition Advocacy therefore assumes a greatimportance in the area of government interventions through policy making.

Bibliography

1) http://www.cci.gov.in,2) Competition Act as amended by the Competition Commission Amendment

Act, 2007

3) United Nations Conference on Trade & Development -http://www.unctad.org4) Federal Trade Commission -http://www.ftc.gov/oia/authorities.shtm5) Speeches and Seminars by Mr.Vinod Dhall

http://www.cci.gov.in/index.php?option=com_speeches&task=level&limit=10&limitstart=10
http://www.cci.gov.in/http://www.cci.gov.in/http://www.unctad.org/http://www.unctad.org/http://www.unctad.org/http://www.ftc.gov/oia/authorities.shtmhttp://www.ftc.gov/oia/authorities.shtmhttp://www.ftc.gov/oia/authorities.shtmhttp://www.ftc.gov/oia/authorities.shtmhttp://www.unctad.org/http://www.cci.gov.in/

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