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Omkeshwar

Omkeshwar Singh  | Answer  |Ask -

Head, Rank MF - Answered on Aug 09, 2022

Mutual Fund Expert... more
Praveen Question by Praveen on Aug 09, 2022Hindi
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Below are my monthly SIPs (22k). Please advise if any change is required:

  • Mirae Emerging Bluechip Growth - 2k
  • Tata Digital India (G) - 5k
  • IDFC sterling value (G) - 5k
  • Canara Robeco Emerging Equities (G) - 1k
  • Mirrae Large Cap (G) - 1k
  • Axis Small Cap (G) - 1k

ELSS funds

  • Canara Robeco Equity Tax saver - 1k
  • Quant Tax (G) - 4k
  • IDFC Tax advantage (G) - 2k

Also I have around 6 lakh in Edelweiss Large and Mid cap (G) fund (SIPs stopped in this).

Is it fine to park this amount here or any other option?

Ans:

  1. Continue
  2. It is fine to continue to hold the same fund.
DISCLAIMER: The content of this post by the expert is the personal view of the rediffGURU. Users are advised to pursue the information provided by the rediffGURU only as a source of information to be as a point of reference and to rely on their own judgement when making a decision.
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Ramalingam

Ramalingam Kalirajan  |10872 Answers  |Ask -

Mutual Funds, Financial Planning Expert - Answered on May 29, 2024

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I have the following SIP investments in the below Mutual Fund plans . Please advise if I should change any ? Also ,Please advise where can I put an additional 20k per month for more investment?[SA] Quant MIdCap Direct growth Fund 5025 Quant Large and Midcap Direct Fund Growth 2025 SBI Magnum Midcap Direct Plan Growth 3001 Quant Active Direct Fund Growth 4001 Axis Nift Smallcap 50 index direct plan growth 3501 HDFC Small cap direct Plan growth 2501 ICICI Prudential BHARAT 22 FOF Direct Plan growth 5003 SBI Large and Midcap direct plan growth 3004 Nippon india Small cap Direct plan growth 5006 Quant small plan direct plan growth 3010 Quant multi assest direct plan growth 2010 ICICI Prudential Bluechip Direct plan Growth 2110
Ans: Optimizing Your SIP Investments for Long-Term Growth
With a diverse portfolio of SIP investments, it's essential to periodically review and adjust your holdings to ensure they remain aligned with your financial goals and risk tolerance. Let's evaluate your current SIP investments and explore opportunities for additional investment to enhance your portfolio's growth potential.

Reviewing Current SIP Investments
Your current SIP investments cover a wide range of fund categories, including mid-cap, large-cap, small-cap, and multi-asset funds. This diversification is beneficial for spreading risk and capturing growth opportunities across different market segments.

Analyzing Fund Performance and Suitability
While each fund serves a specific purpose in your portfolio, it's essential to evaluate their performance relative to their benchmarks and peer group. Consider factors such as historical returns, expense ratios, and fund manager expertise when assessing their suitability for your investment objectives.

Identifying Potential Changes
Based on your investment horizon, risk tolerance, and financial goals, consider the following factors when determining whether to make changes to your SIP investments:

Underperforming Funds: Review funds that consistently underperform their benchmarks or fail to meet your expectations. Consider replacing them with better-performing alternatives.

Overlapping Holdings: Identify any overlapping holdings across funds and consolidate your investments to avoid duplication and streamline your portfolio.

Risk Management: Assess the overall risk profile of your portfolio and make adjustments to ensure it aligns with your risk tolerance and investment objectives.

Exploring Additional Investment Opportunities
With a surplus of Rs. 20,000 per month available for investment, consider allocating these funds to further diversify your portfolio and capitalize on growth opportunities. Explore the following options for additional investment:

Sector-Specific Funds: Consider investing in sector-specific funds to capitalize on emerging trends and opportunities in specific industries or sectors.

International Funds: Diversify your portfolio geographically by investing in international funds that provide exposure to global markets and currencies.

Debt Funds: Balance your portfolio by investing in debt funds, which offer stable returns and act as a hedge against market volatility.

Seeking Professional Advice
Given the complexity of portfolio management and the dynamic nature of financial markets, consider consulting with a Certified Financial Planner to receive personalized advice tailored to your specific financial situation and goals. A professional can help you optimize your portfolio, identify suitable investment options, and navigate market uncertainties effectively.

Conclusion
Girish, by reviewing your current SIP investments, identifying potential changes, and exploring additional investment opportunities, you can optimize your portfolio for long-term growth and wealth accumulation. With guidance from a Certified Financial Planner, you can navigate the investment landscape with confidence and work towards achieving your financial goals.

Best Regards,

K. Ramalingam, MBA, CFP,

Chief Financial Planner,

www.holisticinvestment.in

..Read more

Ramalingam

Ramalingam Kalirajan  |10872 Answers  |Ask -

Mutual Funds, Financial Planning Expert - Answered on May 29, 2024

Money
I have the following SIP investments in the below Mutual Fund plans . Please advise if I should change any ? Also ,Please advise where can I put an additional 20k per month for more investment?[SA] Quant MIdCap Direct growth Fund 5025 Quant Large and Midcap Direct Fund Growth 2025 SBI Magnum Midcap Direct Plan Growth 3001 Quant Active Direct Fund Growth 4001 Axis Nift Smallcap 50 index direct plan growth 3501 HDFC Small cap direct Plan growth 2501 ICICI Prudential BHARAT 22 FOF Direct Plan growth 5003 SBI Large and Midcap direct plan growth 3004 Nippon india Small cap Direct plan growth 5006 Quant small plan direct plan growth 3010 Quant multi assest direct plan growth 2010 ICICI Prudential Bluechip Direct plan Growth 2110
Ans: You have taken significant steps towards securing your financial future with a diversified SIP portfolio. Your commitment to regular investing is commendable.

Review of Existing SIP Investments:

Let’s analyze your current mutual fund investments to ensure they align with your financial goals and risk tolerance.

Quant MidCap Direct Growth Fund:

This fund focuses on mid-cap stocks, which offer high growth potential but come with higher volatility.

Quant Large and Midcap Direct Fund Growth:

A balanced mix of large and mid-cap stocks, providing a blend of stability and growth.

SBI Magnum Midcap Direct Plan Growth:

Another mid-cap fund adding diversity within the mid-cap segment.

Quant Active Direct Fund Growth:

A diversified equity fund that invests across various sectors and market capitalizations.

Axis Nifty Smallcap 50 Index Direct Plan Growth:

An index fund focused on small-cap stocks, offering potential high returns with higher risk.

HDFC Small Cap Direct Plan Growth:

A small-cap fund that focuses on companies with high growth potential.

ICICI Prudential BHARAT 22 FOF Direct Plan Growth:

A fund of funds investing in the Bharat 22 ETF, providing exposure to a diversified portfolio of public sector companies.

SBI Large and Midcap Direct Plan Growth:

Invests in both large and mid-cap stocks, providing a balance between growth and stability.

Nippon India Small Cap Direct Plan Growth:

A small-cap fund known for aggressive growth strategies.

Quant Small Cap Direct Plan Growth:

Another small-cap fund, adding to the exposure in the small-cap segment.

Quant Multi Asset Direct Plan Growth:

Invests across multiple asset classes, providing diversification and reducing risk.

ICICI Prudential Bluechip Direct Plan Growth:

A large-cap fund that offers stability and consistent returns.

Recommendations for Portfolio Optimization
Diversification and Overlap:

Your portfolio has a heavy allocation towards small-cap and mid-cap funds. While these can provide high returns, they also come with higher risk.

Reducing Overlap:

Consider reducing the number of small-cap funds to avoid excessive overlap and potential volatility.

Balancing with Large-Cap Funds:

Increase allocation in large-cap funds for stability and consistent returns.

Suggested Changes
Retain:

Quant MidCap Direct Growth Fund
Quant Large and Midcap Direct Fund Growth
ICICI Prudential Bluechip Direct Plan Growth
Consider Replacing or Reducing:

Nippon India Small Cap Direct Plan Growth: Consider reducing allocation due to significant overlap with other small-cap funds.
Quant Small Cap Direct Plan Growth: Similar to above, reduce or replace to minimize risk.
Balanced Funds:

Introduce balanced funds or hybrid funds to achieve a mix of equity and debt, providing growth with reduced volatility.

New Investment Recommendations
Additional Rs. 20,000 Allocation:

Here’s how you can allocate your additional Rs. 20,000 per month for optimal returns.

Diversified Equity Funds:

Invest in diversified equity funds with a proven track record for stable growth.

Large-Cap and Bluechip Funds:

Increase allocation in large-cap funds for stability.

Balanced or Hybrid Funds:

Introduce balanced funds for a mix of equity and debt, providing growth with lower risk.

Creating a Stable Portfolio
Balanced Allocation:

Ensure a balanced allocation between large-cap, mid-cap, and small-cap funds.

Regular Review and Rebalancing:

Review your portfolio regularly and rebalance annually to maintain desired asset allocation.

Risk Management:

Ensure your portfolio aligns with your risk tolerance and investment horizon.

Perils of Direct Investing
Market Volatility:

Direct investing in the stock market can expose you to significant market volatility. Prices can fluctuate widely, affecting the value of your investments.

Lack of Diversification:

Investing in individual stocks may lead to a lack of diversification. This increases risk as your investment is concentrated in fewer securities.

Research and Knowledge:

Direct investing requires extensive research and market knowledge. Without proper understanding, you may make uninformed decisions leading to losses.

Emotional Investing:

Investors often make emotional decisions based on market movements, leading to buying high and selling low, which can erode returns.

Time-Consuming:

Managing a portfolio of individual stocks is time-consuming. It requires continuous monitoring and adjustment based on market conditions.

Benefits of Investing Through MFD with CFP Credential:

Professional Management:

Certified Financial Planners (CFPs) and Mutual Fund Distributors (MFDs) provide professional management, ensuring your investments are well-researched and diversified.

Holistic Financial Planning:

CFPs offer holistic financial planning, aligning your investments with your financial goals, risk tolerance, and time horizon.

Regular Monitoring and Rebalancing:

Professionals regularly monitor and rebalance your portfolio to ensure it remains aligned with your objectives.

Reduced Emotional Bias:

Professional management helps in reducing emotional bias, making investment decisions based on logic and analysis.

Suggested Mutual Fund Allocation
Equity Funds:

Large-Cap Funds: 40%
Mid-Cap Funds: 30%
Small-Cap Funds: 20%
Balanced/Hybrid Funds:

Balanced Funds: 10%
Summary
Compliment and Encouragement:

Your commitment to regular investing and seeking advice shows your dedication to achieving financial goals. Keep up the excellent work.

Action Plan:

Review and adjust your current SIPs to reduce overlap.
Increase allocation in large-cap and balanced funds.
Allocate additional Rs. 20,000 to diversified and balanced funds for stability and growth.
Best Regards,

K. Ramalingam, MBA, CFP,

Chief Financial Planner,

www.holisticinvestment.in

..Read more

Ramalingam

Ramalingam Kalirajan  |10872 Answers  |Ask -

Mutual Funds, Financial Planning Expert - Answered on May 25, 2024

Asked by Anonymous - May 24, 2024Hindi
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Hi I am 25 year old and have started investing in SIPs for the first time since last hear. I do 1. HDFC Index Fund Nifty 50 -5,500 2. MIRAE Asset Midcap fund - 3500 3. Axis small cap - 2500 4. JM Flexicap - (one time investment) - 20,000 5. Aditya Birla Sun Life PSU equity - (one time) - 6000 6. Quant Mid cap - 3,500 7. Quant Infrastructure- 1,000 8. ICICI Prudential retirement - 1000 9. QUANT ELSS - 1,000 10. Parag Pareikh - 1000 11. Nippon India - 1000 12. SBI PSU - 1000 Overall my monthly SIP goes around 25,000-30,000 and my plan is to retire at the age of 50 with 5 Crore. XIRR - 27.33% Please suggest if i need to make any changes
Ans: It's impressive to see a 25-year-old like you investing diligently in SIPs. Your commitment to securing your financial future early is commendable. Let's evaluate your portfolio and see if any changes are necessary to help you achieve your goal of Rs 5 crore by the age of 50.

Diversification and Allocation
You have a diverse portfolio with investments across different categories:

Large-cap Index Fund

Mid-cap Funds

Small-cap Fund

Flexi-cap Fund

Sector Funds (PSU, Infrastructure)

Retirement Fund

ELSS Fund

This diversification helps spread risk and capture growth from various market segments.

Disadvantages of Index Funds
Index funds, like your HDFC Index Fund Nifty 50, track the market and offer average returns. They cannot outperform the market. Actively managed funds, managed by experts, aim to beat the market, offering potential for higher returns. Given your long investment horizon, actively managed funds could be more beneficial.

Benefits of Actively Managed Funds
Actively managed funds are overseen by professional managers who make strategic decisions to outperform the market. These funds can provide better returns, especially in volatile markets. With the right selection, actively managed funds can significantly enhance your portfolio's performance.

Disadvantages of Direct Funds
Direct funds have lower costs but lack professional guidance. Investing through a Mutual Fund Distributor (MFD) with a CFP credential ensures you receive expert advice. This professional support helps in making informed decisions and aligning investments with your financial goals.

Assessing Your Sector Funds
Your investments in sector funds like Quant Infrastructure and SBI PSU can offer high returns but also come with high risk. Sector funds are dependent on the performance of specific sectors. Diversifying too much into sector funds can increase risk. Consider limiting exposure to sector funds to balance your portfolio.

Importance of Reviewing Portfolio
Regularly reviewing your portfolio is essential to ensure it aligns with your financial goals. Market conditions and personal circumstances change over time. A periodic review helps in rebalancing your portfolio and maintaining the desired risk-return profile.

Evaluating Long-Term Goals
Your goal of Rs 5 crore by the age of 50 is ambitious but achievable with a disciplined approach. Considering the power of compounding and historical market returns, maintaining a consistent investment strategy will be key to reaching your target.

Projecting Future Returns
While exact future returns are unpredictable, a diversified portfolio with a mix of actively managed funds and strategic investments can provide good growth. Historically, equity mutual funds have delivered around 12-15% annual returns. Adjusting your portfolio to optimize for this growth can help achieve your long-term goal.

Suggestions for Improvement
Increase Allocation to Actively Managed Funds: Shift some investments from index funds to actively managed funds to potentially achieve higher returns.

Reduce Sector Fund Exposure: Limit investments in sector-specific funds to manage risk better.

Regular Reviews and Rebalancing: Periodically review and rebalance your portfolio to ensure it remains aligned with your goals and market conditions.

Conclusion
Your current investment strategy is strong and diversified, setting a solid foundation for future growth. With some adjustments to focus more on actively managed funds and regular portfolio reviews, you can enhance your chances of achieving your Rs 5 crore goal by the age of 50. Consulting with a Certified Financial Planner can provide tailored advice to optimize your investment strategy.

Best Regards,

K. Ramalingam, MBA, CFP,

Chief Financial Planner,

www.holisticinvestment.in

..Read more

Latest Questions
Ramalingam

Ramalingam Kalirajan  |10872 Answers  |Ask -

Mutual Funds, Financial Planning Expert - Answered on Dec 06, 2025

Asked by Anonymous - Dec 06, 2025Hindi
Money
Dear Sir/Ma'am, I need some guidance and advice for continuing my mutual fund investments. I am a 36 year old male, married, no kids yet and no debts/liabilities as such. I have couple of savings in PPF, NPS, Emergency funds and long term investing in direct stocks. I recently started below mentioned SIPs for long term to grow wealth. Request you to review the same and let me know if I should continue with the SIPs or need to rationalize. Kindly also advice on how to invest a lumpsum amount of around 6lacs. invesco small cap 2000 motilal oswal midcap 2700 parag parikh flexicap 3000 HDFC flexicap 3100 ICICI prudential largecap 3100 HDFC large and midcap 3100 HDFC gold etf FOF 2000 ICICI Pru equity and debt fund 3000 HDFC balanced advantage fund 3000 nippon india silver etf FOF 2000
Ans: You already built a solid foundation. Many investors delay planning. But you started early at 36. That gives you a strong advantage. You have no liabilities. You have long term thinking. You also have diversified savings like PPF, NPS, Emergency funds and direct stocks. That shows clarity and discipline. This approach builds wealth with less stress over time.

You also started systematic investments in equity funds. That is a positive step. Your selection covers multiple categories like large cap, mid cap, small cap, flexi cap, hybrid and precious metals. So the intent is right. You are trying to create a broad portfolio. That gives balance.

» Your Portfolio Composition Understanding
Your current SIP list includes:

Small cap

Mid cap

Flexi cap

Large cap

Large and mid cap

Hybrid category

Gold and Silver FoF

Equity and Debt allocation fund

Dynamic hybrid fund

This shows you are trying to cover many segments. But too many categories can create overlap. When there is overlap, you get confusion during review. It also makes portfolio discipline difficult. You may think you are diversified. But the holdings inside may repeat. That reduces efficiency.

Your portfolio now looks like:

Equity dominant

Hybrid for stability

Metals for hedge

So the broad direction is fine. But simplifying helps in long-term habit building.

» Fund Category Duplication
You hold:

Two flexi cap funds

One large and mid cap fund

One pure large cap fund

One mid cap fund

One small cap fund

Flexi cap funds already invest across large, mid, small. Then large and mid also overlaps. So the large cap exposure gets repeated. That may not add extra benefit. But it increases monitoring complexity.

So I suggest rationalising. Keep one fund per category in core. Keep satellite space for only high conviction.

» Core and Satellite Strategy
A structured portfolio follows core and satellite method.

Core portfolio should be:

Simple

Long term

Stable

Satellite portfolio can be:

High growth

Concentrated

Based on your thinking level, you can structure like this:

Core funds:

One large cap

One flexi cap

One hybrid equity and debt fund

One balanced advantage type fund

Satellite funds:

One mid cap

One small cap

One metal allocation if needed

This division gives clarity. You can continue SIPs with review every year. No need to stop and restart often. That reduces behavioural mistakes.

» Your Current SIP List Review with Suggested Streamlining

You can consider continuing:

One flexi cap

One large cap

One mid cap

One small cap

One balanced advantage

One equity and debt hybrid

You may reconsider keeping both flexi caps and both gold silver funds. One of each category is enough. Because too many funds do not increase returns. It complicates tracking.

Precious metal funds should not be more than 5 to 7 percent in your portfolio. This is because metals are hedge assets. They do not create compounding like equity. They act as protection during cycles. So keep them small.

» How to Use the Rs 6 Lakh Lump Sum
You asked about lump sum investing. This is important. Lump sum should not go fully into equity at one time. Markets move in cycles. So use a staggered method. You can invest the lump sum through STP (Systematic Transfer Plan). You can keep the amount in a liquid fund and set STP toward your chosen growth funds over 6 to 12 months.

This reduces timing risk. It also creates discipline. So your Rs 6 lakh can be deployed gradually. You may use 50% towards core equity funds and 30% toward satellite growth category. The remaining 20% can go into hybrid category. This gives balance and comfort.

» Regular Funds Over Direct Funds
One important point many investors miss. Direct funds look cheaper. But they demand deep knowledge, discipline, and behaviour control. Most investors lose more through emotional selling and wrong timing than they save on expense ratio.

With regular funds through a Mutual Fund Distributor with Certified Financial Planner qualification, you get guidance, structure and correction. The advisory discipline protects you during market extremes. That is more valuable than a small saving in expense ratio.

A personalised planner also tracks portfolio drift, rebalancing need and category shifts. So regular fund investing gives long-term benefit and behaviour coaching.

» Actively Managed Funds over Index or ETF
Some investors choose index funds or ETF thinking they are simple and cheap. But they ignore drawbacks.

Index funds or ETF will not avoid weak companies in the index. They will invest whether the company grows or struggles. There is no fund manager decision making. So when markets are at peak, index funds continue aggressive exposure. In downturns also they fall fully. There is no cushion.

Actively managed funds work with research teams. They can avoid bad sectors. They can shift allocation based on market and economy. Over long term, this gives better alpha and stability. So continuing with actively managed funds creates better wealth compounding.

» SIP Continuation Strategy
Once the rationalisation is done, continue SIPs every month without interruption. Pause and restart behaviour damages compounding power. SIP works best when you go through all market cycles. You benefit more during corrections because cost averaging works.

So continue SIP amount. You can also review SIP increase every year based on income. Increasing SIP by 10 to 15 percent every year helps you reach large corpus faster.

» Asset Allocation Based Approach
One key point in wealth creation is having the right asset mix. Equity gives growth. Hybrid gives balance. Metals give hedge. Debt gives safety. Your asset allocation should stay aligned to your risk profile and time horizon.

Since you are young and have long term horizon, higher equity allocation is fine. But as time moves, rebalancing is important. Rebalancing protects gains and restores allocation.

So review your asset allocation every year or during major life events like child birth, home buying or retirement planning.

» Behaviour Management
Many portfolios fail not due to bad funds. They fail due to bad decisions. Selling during correction. Stopping SIP when market falls. Chasing past return performance. These mistakes reduce wealth.

Your discipline so far is good. Continue to stay patient during volatility. Equity rewards patience and time.

» Financial Goals Clarity
Since you have no children now, you can decide your long-term goals. Typical goals may include:

Retirement

Future child education

Dream lifestyle purchase

Health care reserves

When goals are clear, investment purpose becomes stronger. So you can map each fund category to goal horizon. Short-term goals should not use equity. Long-term goals should use equity with hybrid support.

» Role of Review and Monitoring
Review once in a year is enough. Frequent review can create anxiety. Annual review helps check:

Fund performance

Expense drift

Category relevance

Allocation balance

Then adjust only if needed. This progress helps you stay confident and aligned.

» Taxation Awareness
Equity mutual funds taxation rules are:

Short term (below one year holding) taxable at 20 percent

Long term (above one year holding) gains above Rs 1.25 lakh taxable at 12.5 percent

Debt mutual funds are taxed as per your income slab.

So always hold equity funds for long term. That reduces tax impact and gives better growth.

» SIP Increase Plan
You can create a simple plan to increase SIP over time. For example:

Increase SIP at every salary increment

Increase SIP during bonus time

Use rewards or extra income for investing

This habit accelerates wealth. So by the time you reach 45 to 50 years, your investments could reach a strong level.

» Insurance and Protection
Before investing large, ensure you have term insurance and health insurance. If not already done, it is important. Insurance protects wealth. Without insurance, even a small medical event can impact investment plan. So review this part also. Since you are married, cover both.

» Wealth Behaviour Mindset
You are already disciplined. Just keep these simple principles:

Invest without stopping

Review once a year

Avoid funds overlap

Follow asset allocation

Avoid reacting to media noise

This helps you reach long term milestones.

» Finally
You are on the right track. Only fine tuning and simplification is needed. Your discipline is visible. Your portfolio will grow well with structure, patience and periodic review. Use the Rs 6 lakh with STP approach. And continue SIP with rationalised categories.

With time and consistency, wealth creation becomes effortless and peaceful. You just need to stay committed and avoid overthinking during market movements.

Best Regards,
K. Ramalingam, MBA, CFP,

Chief Financial Planner,

www.holisticinvestment.in

https://www.youtube.com/@HolisticInvestment

...Read more

Dr Dipankar

Dr Dipankar Dutta  |1837 Answers  |Ask -

Tech Careers and Skill Development Expert - Answered on Dec 05, 2025

Career
Dear Sir, I did my BTech from a normal engineering college not very famous. The teaching was not great and hence i did not study well. I tried my best to learn coding including all the technologies like html,css,javascript,react js,dba,php because i wanted to be a web developer But nothing seem to enter my head except html and css. I don't understand a language which has more complexities. Is it because of my lack of experience or not devoting enough time. I am not sure. I did many courses online and tried to do diplomas also abroad which i passed somehow. I recently joined android development course because i like apps but the teaching was so fast that i could not memorize anything. There was no time to even take notes down. During the course i did assignments and understood the code because i have to pass but after the course is over i tend to forget everything. I attempted a lot of interviews. Some of them i even got but could not perform well so they let me go. Now due to the AI booming and job markets in a bad shape i am re-thinking whether to keep studying or whether its just time waste. Since 3 years i am doing labour type of jobs which does not yield anything to me for survival and to pay my expenses. I have the quest to learn everything but as soon as i sit in front of the computer i listen to music or read something else. What should i do to stay more focused? What should i do to make myself believe confident. Is there still scope of IT in todays world? Kindly advise.
Ans: Your story does not show failure.
It shows persistence, effort, and desire to improve.

Most people give up.
You didn’t.
That means you will succeed — but with the right method, not the old one.

...Read more

DISCLAIMER: The content of this post by the expert is the personal view of the rediffGURU. Investment in securities market are subject to market risks. Read all the related document carefully before investing. The securities quoted are for illustration only and are not recommendatory. Users are advised to pursue the information provided by the rediffGURU only as a source of information and as a point of reference and to rely on their own judgement when making a decision. RediffGURUS is an intermediary as per India's Information Technology Act.

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