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University Of Petroleum and Energy Studies

College of Legal Studies

B.B.A., LL.B.(Hons.)
SEMESTER 3

ACADEMIC YEAR- 2016-2017

SESSION- AUGUST- DECEMBER

Under the Supervision of: Ms. Shruti Reddy


TOPIC- LIMITIED LIABILITY PARTNERSHIP
NAME:

RACHIT MUNJAL

SAP ID:

500047862

ROLL NO:

R760215045

INRODUCTION:
The importance of the Partnership Act 1890 in the historical development of partnership
law in the United Kingdom is beyond question. Drafted in 1879 and finally enacted in 1890
after much debate and amendment, this seminal piece of Victorian legislation with its "rather
limpid prose" and the "deceptive simplicity, born of clear and elegant expression" in which
Sir Frederick Pollock clothed its provisions, 1 was intended as partial codification of the
considerable number of common law and equitable principles developed by the law courts. It
has served as an example for most Commonwealth jurisdictions and has strongly influenced
the American Uniform Partnership Act of 1914 (UPA). In fact, in irrespective of the UPA, the
Partnership Act has served as a model for more than 30 other partnership Acts and ordinances
with implementation dates ranging from 1891 to at least 1981.
The Indian law of partnership in India is based on the provisions of the English law of
partnership. Until the English Partnership Act of 1890 was passed, the law of partnership
even in England was largely based on legal decisions and custom. There were very few acts
of parliament relating directly to partnership. The Indian Partnership Act of 1932 (Partnership
Act) was the result of a Report of a Special Committee consisting of Shri Brojender Lal
Mitter, Sir Dinshaw Mulla, Sir Alladi Krishnaswami Iyer and Sir Arthur Eggar.2
Prior to the enactment of the Partnership Act, the law relating to partnership was
contained in Chapter XI (sections 239 to 266) of the Indian Contract Act, 1872 (Contract
Act). These provisions contained in the Contract Act were not found adequate. As a result,
Chapter XI of the Contract Act was repealed and replaced by the Partnership Act of 1932.
The limited liability partnership (LLP) concept originated in the US in the early 90s in
unincorporated form. It was inspired by litigation against professional firms that had done
work for failed savings and loan associations. Claims against all partners, including many
who had nothing to do with the failed associations, were a strong incentive for the
1 J.J. Henning, Partnership Law Review : The Joint Consultation Papers and the Limited Liability Partnership
Act in Brief Historical and Comparative Perspective, Comp. Law. 2004, 25(6), 163-170,

2 Law Commission of India, 178th Report, 2001, Recommendations for amending various
enactments, both Civil & Criminal

development of a mechanism to limit the vicarious liability of partners. 3 Following this, it


was also adopted in United Kingdom (2000) and now the Naresh Chandra Committee
proposed the same for India.
With the growth of the Indian economy, the role played by its entrepreneurs as well as its
technical and professional manpower has been acknowledged internationally. It is felt
opportune that entrepreneurship, knowledge and risk capital combine to provide a further
impetus to Indias economic growth. In this background, a need has been felt for a new
corporate form that would provide an alternative to the traditional partnership, with unlimited
personal liability on the one hand, and, the statute-based governance structure of the limited
liability company on the other, in order to enable professional expertise and entrepreneurial
initiative to combine, organize and operate in flexible, innovative and efficient manner.
The Limited Liability Partnership (LLP) is viewed as an alternative corporate business
vehicle that provides the benefits of limited liability but allows its members the flexibility of
organizing their internal structure as a partnership based on a mutually arrived agreement.
The LLP form would enable entrepreneurs, professionals and enterprises providing services
of any kind or engaged in scientific and technical disciplines, to form commercially efficient
vehicles suited to their requirements. Owing to flexibility in its structure and operation, the
LLP would also be a suitable vehicle for small enterprises and for investment by venture
capital. Keeping in mind the need of the day, the Parliament enacted the Limited Liability
Partnership Act, 2008 which received the assent of the President on 7th January, 2009.

3 Johan Henning, The Deadlocked Limited Liability Partnership Arbitration or Winding


Up, Comp. Law. 2005, 26(10)

BASIC CONCEPTS:
1.

Partnership
A Partnership is the relation between persons who have agreed to share the profits of
a business carried on by all or any of them acting for all.4 Under the Indian
Partnership Act, 1932, every partner is jointly and severally liable for all the acts of
the firm.5
2.General Partnership
A general partnership is formed when two or more people intend to work together to
carry on a business activity. The distinguishing feature of a partnership is the
unlimited liability of the partners. Each partner is personally liable for all of the debts
of the partnership. That includes any debts incurred by any of the other partners on
behalf of the partnership. Any one partner is able to bind the partnership by entering
into a contract on behalf of the partnership.
3.

Limited Partnership
A limited partnership consists of one or more general partners and one or more
limited partners. The general partner is responsible for the management of the affairs
of the partnership, and he has unlimited personal liability for all debts and obligations.
Limited partners have no personal liability. The limited partner stands to lose only the
amount which he has contributed and any amounts which he has obligated himself to
contribute under the terms of the partnership agreement.

4.

Limited Liability Company


A limited liability company, commonly called an "LLC," is a business structure that
combines the pass-through taxation of a partnership or sole proprietorship with the
limited liability of a corporation. The main difference between a Limited Liability
Partnership or LLP and a limited liability company is that a Limited Liability
Partnership has the organizational flexibility of a partnership and is taxed as a
partnership. In other respects it is very similar to a company.6

4 Sec. 4, The Indian Partnership Act, 1932


5 Ibid, Sec. 25
6Larry E. Ribstein, Eighth Annual Corporate Law Symposium: Limited Liability Companies, 4 U. Cin. L. Rev.
319,

LLP V LLC:

LLC

Suitable for Smaller businesses with few shareholders


Management Only Members and managing members of the
Level company
Ownership Members
Taxation Single taxation - Profit or loss are passed
directly to members(top bracket 39.6%). Can
elect to be taxed as a corporation.
Choice of Yes, it is a Single Member LLC - SMLLC or
taxation structure partnership for multiple members by default,
given and S or C Corporation (by election)
Stands for Limited Liability Company
Legal entity Separate entity from partners, but members
may be held liable for non-fiscal obligations
Members needed 1 or more
to set up
Shareholders Not necessary, but should have recorded
meeting activities and/or advisory boards
Legal agreements May not be required in some states. Should
have an operating agreement with business
records
Paperwork and Not much paperwork is required. Annual state
records reports are required to be filed with the
appropriate fee; can file by mail but most states
allow or mandate online filing
Limited Liability Yes

LLP

Professional businesses
Decentralized
Members
Single Taxation

Yes

Limited Liability
Partnership
Separate from those of
partners
2 or more
Not necessary
May not be required in
some states.
Not much paperwork is
required.

Yes

LLC
Continuity of life Indefinite term

LLP
With LLPs with no definite
term, death of partners will
not cause dissolution.

Regulation of Differs with each state but mostly LLC or


entity name L.L.C. is added.

Must include the words


"limited liability
partnership" or abbreviation
thereof

Members and An LLC has members who own the company


owners

Owners of an LLP are


called Partners

CONTENTS OF: LLP V LLC


Organization
In the UK, an LLP is organized by the filing of a registration statement with the office of the
state in which is it formed along with the required filing fee. The registration statement must
include certain information. Once the statement is filed, no other filings with the state are
necessary unless the LLP changes its name or otherwise amends its statement. The same
applies to an LLC also. Once organized, there is no requirement that an LLP have a written
partnership agreement. However, a written partnership agreement is desirable to document
important managerial and financial agreements among the partners. In the USA, LLCs are
organized with a document called the "articles of organization", or "the rules of organization"
specified publicly by the state; additionally, it is common to have an "operating agreement"
privately specified by the members. The operating agreement is a contract among the
members of an LLC governing the membership, management, operation and distribution of
income of the company.
Management Structure
The owners of an LLC are called "Members" instead of "Shareholders". Managing members
are the individuals who are responsible for the maintenance, administration and management
of the affairs of an LLC. In most states, the managers serve a particular term and report to and
serve at the discretion of the members. This may be called a Two Tiered Management
structure for LLCs. Two or more individuals, corporations, partnerships, trusts, or other

entities can join together to engage in business as an LLP. The owners of an LLP are called
"partners." Partners essentially own the LLP in much the same way as partners own a general
partnership and shareholders own a corporation. When an LLP engages in business activities,
it is the LLP itself which actually owns and operates the business from a legal sense. Both
follow a decentralized form of management.
Liabilities
An LLP in UK provides its partners with limited personal liability for the obligations of the
business. Of course, if a business operated by an LLP has financial difficulties, each partner
of the LLP could lose the amount of his or her investment in the LLP, as well as the equity
built up in the business. Beyond this, however, no partner risks the loss of his or her other
personal assets and income.
In a US LLC, Limited liability means that the owners of the LLC, called "members," are
protected from some liability for acts and debts of the LLC, but can held socially responsible
for other obligations. LLCs in most states are treated as entities separate from their members,
whereas in other jurisdictions case law has developed deciding LLCs are not considered to
have separate juridical standing from their members.
To sum it, the liability shield of LLC is broader than that of LLP. This is so because LLCs do
not make their members liable for any monetary debts of the company while a member of a
LLP may be help responsible for monetary debts.
Taxation
Pass through Taxation structure is followed by the LLCs in the US. An LLC can elect to be
taxed as a sole proprietor, partnership, S corporation or C corporation, providing much
flexibility. There is no double tax structure for LLCs unless they want to be taxed as a
Corporation. UK based LLPs normally are treated as partnerships for tax purposes. LLPs
must elect to be taxed as regular corporations.
Formalities
Though LLCs also do not follow too many formalities for setting up and running but an LLP
requires even lesser formalities. Also, a transfer of real estate to an LLP is exempt from the
real estate transfer fee.

LLP: US AND UK LEGISLATIONS:


During the crisis, the government sued the law and accounting firms7 that represented the
failed banks for malpractice. Claims against all partners, including many who had nothing to
do with the failed associations, were a strong incentive for the development of a mechanism
to limit the vicarious liability of partners. 8
In a short period of time, all US jurisdictions adopted legislation sharing the theme that a
LLP limits, or eliminates, joint and several liability of partners for some, or all, liabilities and
obligations of the partnership. The National Conference of Commissioners on Uniform State
Laws approved the Uniform Limited Liability Partnership Amendments (ULLPA) to the
Revised Uniform Partnership Act (RUPA) in 1996.
In the UK, most professional firms are structured as partnerships. Prior to the Introduction
of LLPs, England followed the traditional system of Partnership. But, the unlimited nature of
liability on partners and the increasing globalization necessitated a change. Two large
accountancy firms, assisted by a law firm, began steps to obtain a limited liability partnership
(LLP) statute in Jersey9, which received Royal Assent in November 1996. "By mid-1996 it
was plain that the option of offshore registration as a Jersey LLP was being very seriously
considered by a number of very large professional partnerships. It was this prospect,
combined with the perceived possibility that a successful mega-claim could in due course

7 Over one-third of all bank failures at the time occurred in the state of Texas. Hamilton, supra note 8, at 1069.

8 Supra 3
9 Jersey is a parliamentary democracy and a dependency of the British Crown. It is not
part of the United Kingdom, nor is it a colony. Her Majesty Queen Elizabeth II of the UK is
the Head of State of Jersey. The Sovereign is represented in the Island by the Lieutenant
Governor. While Jersey makes its own laws, it has pledged allegiance to the English
Crown since 1066.

precipitate the failure of a major firm, that led to the November 1996 decision 10to bring
forward LLP legislation in the UK."11
The concept of LLP was introduced in 1996 in the United Kingdom. The Limited
Liability Partnership Bill, shorn of any limitation on its availability to the regulated
professions, was introduced into the House of Lords late in 1999. The objective of both the
LLP Act and the regulations is to modernise the legal framework for business in the UK,
keeping it at the forefront of international practice by offering firms the ability to incorporate
with limited liability while organizing themselves on partnership lines, subject to provisions
of the Companies Act 1985 and the Insolvency Act 1986 on financial disclosure, fraudulent
trading and winding up similar to those which apply to companies and their directors, thus
providing safeguards to those dealing with the LLP.
The Limited Liability Partnership Act 2000 (the Act) received Royal Assent on July 20,
2000. Subsequently, the Limited Liability Partnerships Regulations and the Limited Liability
Partnerships (Fees) (No.2) Regulations (the Regulations) were promulgated. Since April 6,
2001, LLPs may be registered in the United Kingdom under the Act. Notwithstanding the
term "partnership" in its designation, the law of partnership will in general not be applicable
to an LLP, although it will be taxed as a partnership to ensure that the choice between using
an LLP or a partnership is a tax neutral one. The LLP will be required to disclose information,
inter alia, on its finances and members, similar to that required of companies. 12The Limited
Liability Partnership Act 200013 received royal assent on July 20, 2000. Since April 6, 2001,
limited liability partnerships may be registered in the United Kingdom under the Act.

10 On 7 November 1996, Ian Lang, President of the Board of Trade, announced the UK
government's intention to bring forward legislation at the earliest opportunity to make
LLP available to regulated professions in the UK.
11 House of Commons Select Committee on Trade and Industry Report 1998. H.C. 59, para.82.
12 DTI, Limited Liability Partnerships Bill. A Consultation Document. Regulations to Accompany the Limited
Liability Partnerships Bill (URN 99/1025), Part IV, para. 2.
13 Act 12 of 2000.

LLP in India:
In an increasingly litigious market environment, the prospect of being a member of a
partnership firm with unlimited personal liability is, to say the least, risky and unattractive. In
India, some bodies of professionals have been prohibited from practicing under an
incorporated form. E.g. Development of legal profession in India has been restricted in India
on account of the number of impediments in the current regulatory system which hinders
Indian law firms from competing effectively against foreign firms. 14 This would hamper the
growth of Indian Law Firms in comparison to the Foreign Law Firms once the Legal Sector is
opened.
The general partnership or partnership simpliciter has traditionally been the entity
of choice to provide services by professionals such as lawyers, accountants, doctors,
architects, and company secretaries.15 The unlimited liability of general partnerships under
the Indian Partnership Act 1932 has become a cause for concern in the light of increase in the
incidence of litigation for professional negligence, the size of the claims and the risk to a
partner's personal assets when a claim exceeds the sum of the assets of the partnership.16
14 A Consultation Paper on Legal Services under GATS (Prepared by Trade and Policy Division, Department of
Commerce, Government of India)
15 Naresh Chandra Committee Report
16

The idea that LLPs should be introduced in India was mooted in the Report of the
Naresh Chandra Committee on Regulation of Private Companies and Partnership and the
May 2005 Report of the Expert Committee on Company Law (J. J. Irani Committee). In
response, on November 2, 2005, the Ministry of Company Affairs in the Government of India
circulated a concept paper on LLPs with a view to stimulating public debate over ideas
which will be incorporated in the proposed Limited Liability Partnership Bill (the "Bill"). The
proposed Bill is drafted on the lines of the United Kingdom's Limited Liability Partnerships
Act 2000.17

ADVANTAGES OF LLP:
1. The main advantage of LLP is that limited partners do not take on personal liability for the
obligations of the entire partnership, but only to the extent of the money contributed to the
firm by such partners. Whereas, under Sec. 25 of the Indian Partnership Act, a partner is
jointly and severally liable.
2. Further, a partners liability is not limited when the misconduct is attributable to him or to
an employee under the supervision or control of that partner. An LLP only protects a partner,
other than a general partner from the liability arising from the misconduct or personal acts of
other partners.
3. The members of an LLP would have the option to have a general partner or more with
unlimited liability, but it would not shield the partners from legal liability arising out of their
own personal acts which are not done for and on behalf of the LLP, that is, any act done
beyond the acts and powers of the partners as laid down in the incorporation document.

17 Aparna Viswanathan, India considers introduction of Limited Liability Partnerships, I.C.C.L.R. 2006, 17(5),
141

4. The main benefit in an LLP is that it is taxed as a partnership, 18 but has the benefits of
being a corporate, or more significantly, a juristic entity with limited liability.
5. An LLP has the special characteristic of being a separate legal personality19 distinct from
its partners.
6. Sec. 11 of the Companies Act bars the formation of a partnership consisting of more than
20 persons. But in a Limited Liability Partnership, a minimum of two partners is required.20
From perspective of a Business:
1. As many owner as you need:
One of the greatest things of a limited liability partnership is that there is no limit on the
amount of owners that can be involved with the business. This is great because it evenly
spreads out the amount of liability that each partner can have if something where to go wrong
with the business.
2. Limited Liability:
Just as the name suggests, limited liability partnerships limit your liability. Since there are
multiple owners involved in the business all of the risks of the business are spread out and
made much smaller than if a single person was responsible for the business on their own.
This generally refers to legal issues, like if the company was sued for any reason.
3. Tax Benefits:
Another one of the great benefits of operating underneath an LLP is how you file taxes. The
partnership itself doesnt have to file taxes as a business, which provides great breaks for the
18 For tax law, income-tax as well as sales tax, partnership firm is a legal entity - State of Punjab v. Jullender
Vegetables Syndicate - 1966 (17) STC 326 (SC), CIT v. A W Figgies - AIR 1953 SC 455, CIT v. G
Parthasarthy Naidu (1999) 236 ITR 350
19 Though a partnership firm is not a juristic person, Civil Procedure Code enables the partners of a partnership
firm to sue or to be sued in the name of the firm. - Ashok Transport Agency v. Awadhesh Kumar 1998(5)
SCALE 730 (SC). [A partnership firm can sue only if it is registered].
20 V. Pattabhi Ram & Mithun D'Souza, Demystifying Limited Liability Partnership, The Business Line, (May
15, 2006)

company. However, each individual partner must file a variety of different tax forms
regarding the business.
4. Great Flexibility:
Flexibility is a defining characteristic of limited liability partnerships. Each partner in the
business has the ability to decide how much they want to contribute and how much of a
partner they truly want to be in the business. They are also not obligated to participate in
business meetings or consultations with anyone that they do not feel the need to.

DISADVANTAGES OF LLP:
1.Though good in parts, the implementation of this concept may give rise to certain tricky
issues. How would one prove that a particular partner is responsible for an act of felony? This
would give rise to disputes amongst the partners themselves. In a situation wherein there are
two or more joint auditors who have signed a problem balance sheet, to whom would one pin
the responsibility? Even if we say that a partner would only be liable for his acts, how can
one distinguish which partner has done which act ? The main problem will arise is to where
should one draw the line ? These are big issues which need to be resolved before
implementing or allowing firms to form LLPs.21
2.Even if the allocation of work amongst the auditors is as clear as crystal, disputes would be
inevitable. Since the LLPs are proposed to disclose financial information a la a private
limited company, a separate format of financial statements would need to be devised.
Provisions relating to authorised capital, stocks, and so on, would be irrelevant in a
professional firm. With the new-age insurance companies offering a slew of innovative
insurance products, it may not take a long time before a comprehensive policy is devised that
protects all risks for a partnership. A partner being held responsible to the extent of his
contribution in the case of a felony is bad enough for him. 22

21 Mohan R. Lavi, Little Utility of Limited Liability, The Business Line, (21st August, 2005)
22 Ibid

3.But the situation is not that bad after all. If the Partnership Act is amended to permit
unlimited partners, clauses in the partnership deed fit together limited liabilities of the
partners, there is an insurance policy that covers all business risks associated with a
partnership and corporate governance practices are introduced for partnerships above a predefined size, would then there be a requirement for a separate law relating to LLPs? Your
guess is as good as mine.

From perspective of Buiness:


1. Not all states are on Board:
Due to the tax benefits and tricky workings of an LLP, some states do no
allow them to form or operate in their region. Another big problem is that
many states do not recognize LLPs as a legal business.
2. Additional Taxes:
Just like some states do not recognize, the majority of the rest pose large
tax limits on limited liability partnerships. These taxes can come in as
additional taxes when registering as well as issues with personal tax filing.
3. Less Business Credibility:
Another huge problem with limited liability partnerships is the fact that
other business and many consumers or clients do not see them as a
credible business. Corporations gain much more respect and are generally
more successful than LLPs.

CASES INVOLVING LLP:

Because this concept has not been implemented or allowed in India, there are no Case Laws
as such. So, we will refer to some U.S Case Laws where LLP is already a full-fledged
practice.

1.

Megadyne Information Systems v. Rosner, Owens & Nunziato,23

The plaintiff sued a law firm LLP and its partners for malpractice and breach of fiduciary
duty. The court granted the defendants summary judgment on the malpractice claim but
determined there were fact issues regarding a breach of fiduciary duty claim. The breach of
fiduciary duty claim was premised on alleged misrepresentations by the firm to the plaintiff
that the plaintiff had a viable claim against the Orange County Transportation Authority
(OCTA) when the firm knew that limitations had run on the claim and the firms continued
representation and receipt of fees for worthless legal representation. The court also
determined that there were fact issues relating to the personal liability of the partners. The
court cited the California LLP provisions for the proposition that partners in an LLP do not
have vicarious liability for the torts of another partner, and the court stated that the plaintiff
could only hold a partner liable who was involved in the handling of the matter. All three
partners claimed that one of them was the sole attorney who handled the matter and that the
other two had no involvement. However, the court found there were fact issues as to the
involvement of the other two. The fact issues were raised by the admittedly-involved
attorneys testimony that there might have been discussions with the other two partners that
the plaintiff had a viable malpractice claim against the lawyers that had previously
represented the plaintiff on their claim against OCTA. The court said these discussions could
support an inference that the partners knew the plaintiffs claim against OCTA was timebarred and that they participated in the decision not to tell the plaintiff while the firm
continued its representation. In addition, the name of one of the partners who claimed he was
not involved appeared on the caption page of the claim filed with OCTA, suggesting his
involvement in the case.
2.Schaufler v. Mengel, Metzger, Barr & Company, LLP,24
Apparently confusing LLP with limited partnership in stating that defendants had submitted
insufficient evidence to establish that managing partner of accounting firm had no liability as
a matter of law on buy-out agreement negotiated with plaintiff partner because the limited
partnership act imposes joint and several personal liability on a general partner and on a
limited partner who participates in the control of the business).
23 No. B213137, 2002 WL 31112563 (Cal. App. Sept. 21, 2002).
24 745 N.Y.S.2d 291

3.Williams v. Natural Life Health Foods Ltd 25


The extent to which an individual member or employee of the LLP will be liable in tort for
his or her own misstatements is in some doubt. The case is related to a limited company and
the House of Lords held that the director of the company would only be liable in negligence
if:
(a) he or she assumed personal responsibility for the advice; and
(b) the claimant relied on this assumption of responsibility, and
(c) the claimants reliance on this assumption of responsibility was reasonable.
Thus, individuals in an LLP will not incur liability in tort except in exceptional cases.

BIBLIOGRAPHY:
TABLE OF CASES:

Ashok Transport Agency v. Awadhesh Kumar 1998(5) SCALE 730 (SC).

CIT v. A W Figgies - AIR 1953 SC 455,

CIT v. G Parthasarthy Naidu (1999) 236 ITR 350

Megadyne Information Systems v. Rosner, Owens & Nunziato No. B213137, 2002 WL
31112563 (Cal. App. Sept. 21, 2002).

Schaufler v. Mengel, Metzger, Barr & Company, LLP745 N.Y.S.2d 291

State of Punjab v. Jullender Vegetables Syndicate - 1966 (17) STC 326 (SC),

25 [1998] 1 WLR 830; [1998] 2 All ER 57.

Williams v. Natural Life Health Foods Ltd [1998] 1 WLR 830; [1998] 2 All ER 57

TABLE OF LEGISLATIONS:

UK Limited Liability Partnership Act 2000


Limited Liability Partnership Act 2008

Sec. 25 of The Indian Partnership Act, 1932

Sec. 4, The Indian Partnership Act, 1932

OTHER SOURCES:

.J. Henning, Partnership Law Review : The Joint Consultation Papers and the
Limited Liability Partnership Act in Brief Historical and Comparative Perspective,
Comp. Law. 2004, 25(6), 163-170,

A Consultation Paper on Legal Services under GATS (Prepared by Trade and Policy
Division, Department of Commerce, Government of India)

Aparna Viswanathan, India considers introduction of Limited Liability Partnerships,


I.C.C.L.R. 2006, 17(5), 141

DTI, Limited Liability Partnerships Bill. A Consultation Document. Regulations to


Accompany the Limited Liability Partnerships Bill (URN 99/1025), Part IV, para. 2.

Johan Henning, The Deadlocked Limited Liability Partnership Arbitration or


Winding Up, Comp. Law. 2005, 26(10)

Larry E. Ribstein,

Eighth Annual Corporate Law Symposium: Limited Liability

Companies, 4 U. Cin. L. Rev. 319,

Law Commission of India, 178th Report, 2001, Recommendations for amending


various enactments, both Civil & Criminal

Mohan R. Lavi, Little Utility of Limited Liability, The Business Line, (21st August,
2005)

Naresh Chandra Committee Report

V. Pattabhi Ram & Mithun D'Souza, Demystifying Limited Liability Partnership, The
Business Line, (May 15, 2006)