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29-Year-Old Rahul Seeks Investment Advice for 10-Year MF Portfolio

Ramalingam

Ramalingam Kalirajan  |6986 Answers  |Ask -

Mutual Funds, Financial Planning Expert - Answered on Aug 12, 2024

Ramalingam Kalirajan has over 23 years of experience in mutual funds and financial planning.
He has an MBA in finance from the University of Madras and is a certified financial planner.
He is the director and chief financial planner at Holistic Investment, a Chennai-based firm that offers financial planning and wealth management advice.... more
Sunil Question by Sunil on Jul 01, 2024Hindi
Money

Hlo Sir I'm Rahul 29 , wants to start investment in MF I have Made one list of investment if you can give some ideas and investment plan on it I will be investing for next 10 yr and 3000 rupes Each . 1 Large Cap - HDFC Nifty 200 Momentum 30 index and ICICI prudential nifty Large cap 250 index 2 - Flexi - Nippon India flexi cap direct growth 3 - Focussed - Axis Manufacturing fund 4 - Hybrid - Parag Parikh conservative hybrid fund direct growth 5 Mid cap - Mirae Asset Mid Cap, 6 - Small - Tata Small cap , Motilal small cap, Bandhan nifty small cap 250 index 7 - Global - ICICI prudential NASDAQ 500 Nifty This is my future plan includes max all But most are New Fund starting Please share your thoughts on it Fonr next 10 yr what's should I Change Please Sir

Ans: Rahul, at 29 years old, you’ve made a commendable start by planning for a disciplined investment strategy. Your decision to allocate Rs 3,000 each to various mutual funds over the next 10 years shows your commitment to long-term wealth creation. Let’s break down your chosen funds and assess their suitability for your goals.

Diversification and Fund Selection
You've spread your investments across various fund categories, which is a good strategy. Diversification helps reduce risk and improves your chances of achieving stable returns. However, there are some points you should consider.

Large Cap Funds
You've chosen HDFC Nifty 200 Momentum 30 Index and ICICI Prudential Nifty Large Cap 250 Index.

Actively Managed vs. Index Funds: You’ve picked index funds. While index funds have lower management fees, they simply mirror the market. This means they lack the potential to outperform the market. Actively managed large cap funds, managed by professionals, may offer better returns by selecting top-performing stocks.

Suggestion: Consider allocating a portion to an actively managed large cap fund. It might provide better returns over the long term.

Flexi Cap Fund
Nippon India Flexi Cap Direct Growth is in your portfolio.

Flexibility: Flexi cap funds are versatile. They invest in large, mid, and small cap stocks. This gives them the ability to adapt to market conditions, which is beneficial over a long-term horizon.

Potential: This fund type is a good choice for diversification. It can offer growth while adjusting to market changes. Stick with this type, but ensure you monitor its performance regularly.

Focussed Fund
You’ve chosen Axis Manufacturing Fund.

Sector-Specific Risk: Focussed funds invest in a limited number of stocks, often in specific sectors. While this can lead to high returns, it also increases risk, especially if the sector underperforms.

Suggestion: If you want to keep this fund, ensure it's a small part of your portfolio. It’s riskier than more diversified funds. Alternatively, you might consider a diversified equity fund for more balanced exposure.

Hybrid Fund
Parag Parikh Conservative Hybrid Fund Direct Growth is your choice here.

Balanced Approach: Hybrid funds invest in both equity and debt. This reduces overall risk while providing reasonable returns. A conservative hybrid fund is a safe option, especially in volatile markets.

Stability: This fund adds stability to your portfolio. Keep this as a part of your strategy, especially for a long-term plan like yours.

Mid Cap Fund
Mirae Asset Mid Cap is your selected fund.

Growth Potential: Mid cap funds invest in companies with good growth potential. They can offer higher returns than large cap funds, but with more risk.

Good Choice: This fund is a good addition for growth, especially over a 10-year horizon. Ensure it's balanced with other, less risky investments.

Small Cap Funds
You've listed Tata Small Cap, Motilal Small Cap, and Bandhan Nifty Small Cap 250 Index.

High Risk, High Reward: Small cap funds offer high growth potential but come with significant risk. They can be volatile and are usually suitable for investors with a high risk tolerance.

Overexposure Risk: You’ve allocated to three small cap funds. This might expose you to higher risk than necessary. Consider reducing the number of small cap funds to avoid overexposure.

Suggestion: Diversify by selecting one strong small cap fund, and allocate more to large or mid cap funds to balance the risk.

Global Fund
ICICI Prudential NASDAQ 500 Nifty is your choice for global exposure.

International Diversification: Global funds provide exposure to international markets, reducing dependency on the Indian market alone. This can be beneficial, especially if the global market outperforms the Indian market.

Currency Risk: Keep in mind that global funds come with currency risk. Fluctuations in currency exchange rates can impact returns.

Balanced Approach: Including one global fund in your portfolio is a good idea for diversification. However, monitor global market trends and currency risks regularly.

General Insights on Your Plan
Your investment plan covers various fund categories, offering a mix of growth and stability. However, there are some areas where adjustments might be beneficial.

Focus on Active Management: While index funds have lower costs, actively managed funds have the potential to deliver higher returns. They are managed by professionals who can adjust the portfolio based on market conditions.

Avoid Overdiversification: While diversification is good, overdiversifying, especially within the same category (like small caps), might dilute your returns and increase risk. Ensure your portfolio is balanced and not overloaded in one area.

Regular Monitoring and Rebalancing: Keep a close eye on your investments. Regularly review your portfolio, and rebalance it if needed. This ensures your investments remain aligned with your financial goals.

Seek Professional Guidance: Investing through a Certified Financial Planner offers access to expert advice. A CFP can help you select the right funds, monitor your investments, and make necessary adjustments.

Final Insights
Rahul, your plan to invest Rs 3,000 each in multiple funds for the next 10 years is a strong start toward building wealth. However, consider some tweaks to enhance your portfolio’s potential. Prioritise actively managed funds, avoid overexposure to small caps, and keep your portfolio balanced. With regular monitoring and the right strategy, you can achieve your financial goals.

Best Regards,

K. Ramalingam, MBA, CFP,

Chief Financial Planner,

www.holisticinvestment.in
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  |6986 Answers  |Ask -

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

Asked by Anonymous - Oct 29, 2024Hindi
Money
Dear team, Hi I’m 46 years would like to start my investment in MF for 5 to 10 years . Till now I have not invested in any share market or MF. I have selected the following funds: 1. Nippon India large cap funds-Rs 10000. 2. Nippon India Small cap fund- Rs 10000. 3. Nippon India Multi cap fund -Rs 7500. 4. Motilal oswal Mid cap fund- Rs 10000. 5. Quant small cap fund- Rs 5000. 6. HDFC Focused 30 fund- Rs. 7500 Also I am NRI I working in Gulf there the above mentioned plan are regular plan thru ICICI direct as I am unable to update my KYC online. Please suggest me that the above mentioned funds are good to invest for 5 to 10 years
Ans: Firstly, your selection to start investing in mutual funds is commendable. As you’re new to mutual funds and looking for a 5 to 10-year investment horizon, a balanced approach across different fund types is a sound choice. This portfolio aligns well with a diversified strategy, as it includes large-cap, mid-cap, small-cap, multi-cap, and focused funds. Now, let’s look at each aspect in detail for better clarity.

Diversification: A Strategic Mix of Funds

Large-Cap Funds: Large-cap funds typically invest in established, stable companies. They bring stability to a portfolio and help balance the potential risk associated with mid-cap and small-cap funds. Large-cap funds are especially beneficial if you want consistent growth with lower risk than small- and mid-cap segments. They are known for their ability to protect capital during market downturns, offering smoother returns over the long term.

Small-Cap Funds: Small-cap funds tend to offer high growth potential but with a higher risk factor. They invest in emerging companies, which may experience considerable price fluctuations. However, for a 5- to 10-year horizon, small-cap funds can yield substantial returns as these smaller companies mature and grow in market valuation. Your allocation to small-cap funds can be a growth driver but requires monitoring.

Multi-Cap Funds: Multi-cap funds provide exposure to large-, mid-, and small-cap companies in a single fund. This gives them the flexibility to adapt to market conditions. Multi-cap funds are beneficial because they can shift their asset allocation to match market dynamics, offering growth potential with moderate risk.

Mid-Cap Funds: Mid-cap funds invest in companies that are in the growth phase and have the potential to become large-cap companies over time. They offer a blend of stability and growth. Including a mid-cap fund in your portfolio is advantageous as it balances the risk and return profile between large-cap and small-cap funds.

Focused Funds: These funds concentrate on a limited number of stocks. This focused approach can yield higher returns if the fund manager's choices perform well. However, it carries higher risk due to limited diversification. For a 5 to 10-year horizon, a focused fund can add significant value to your portfolio but should remain only a part of it.

Evaluation of Regular vs Direct Plans

Since you are investing through ICICI Direct and using regular plans, let’s examine the benefits of regular funds, especially for NRIs. Regular funds offer access to certified financial planners (CFPs) who can provide guidance on market trends, rebalancing strategies, and portfolio reviews. This is advantageous as managing a portfolio from abroad can be challenging. With a regular plan, the extra expense ratio cost is justified by the value-added services provided by ICICI Direct and their advisory services.

Benefits of Actively Managed Funds Over Index Funds

Actively managed funds aim to outperform the market through expert stock selection, which is valuable for short- to medium-term horizons like 5 to 10 years. Actively managed funds can react to market changes, unlike index funds, which simply track an index without considering market fluctuations. Moreover, index funds might not offer the same level of diversification in emerging markets, potentially limiting returns.

Tax Considerations for NRIs

Mutual fund investments for NRIs in India are subject to tax implications that can affect your returns. The new capital gains tax rules specify that:

Long-Term Capital Gains (LTCG): For equity mutual funds, gains above Rs 1.25 lakh are taxed at 12.5%. Holding funds longer than one year generally qualifies as long-term for equity investments.

Short-Term Capital Gains (STCG): Gains realized within a year are taxed at 20%.

Having a clear tax strategy is important to manage the impact of these taxes on your returns. You may consult your financial planner or tax advisor to structure withdrawals efficiently and keep tax liabilities manageable.

Investment Horizon and Risk Management

With a 5- to 10-year investment horizon, a balanced risk profile is critical. Here’s a recommended strategy to ensure a well-rounded portfolio:

Allocate according to time frame: Given your timeframe, it may be wise to invest more in large-cap and multi-cap funds initially for stability, then gradually increase exposure to mid-cap and small-cap funds if your risk tolerance grows.

Systematic Withdrawals: Nearing the 5-year mark, consider a systematic withdrawal plan (SWP) to start securing profits. SWPs allow you to take out funds in a structured way, protecting gains while minimizing tax impacts and potential market volatility.

Market Timing and Rebalancing

Market volatility can affect returns, especially in mid- and small-cap funds. Regularly reviewing and rebalancing your portfolio can help you adjust exposure to each category as needed. Your ICICI Direct advisory service can help assess when market conditions favor reallocating funds, ensuring you stay aligned with your goals.

Final Insights

Your portfolio selection indicates a thoughtful approach, diversified across market segments. With regular plans through ICICI Direct, you’re well-positioned to receive professional support, critical for managing your investments as an NRI. Staying focused on your financial goals, rebalancing as needed, and maintaining a tax-efficient strategy will help you make the most of your investments.

Best Regards,

K. Ramalingam, MBA, CFP,

Chief Financial Planner,
www.holisticinvestment.in
https://www.youtube.com/@HolisticInvestment

..Read more

Ramalingam

Ramalingam Kalirajan  |6986 Answers  |Ask -

Mutual Funds, Financial Planning Expert - Answered on Nov 01, 2024

Asked by Anonymous - Oct 31, 2024Hindi
Money
Dear team, Hi I’m 46 years would like to start my investment in MF for 5 to 10 years . Till now I have not invested in any share market or MF. I have selected the following funds: 1. ICICI Pru blue chip fund -Rs 10000. 2. Nippon India Small cap fund- Rs 10000. 3. Nippon India Multi cap fund -Rs 7500. 4. Motilal oswal Mid cap fund- Rs 10000. 5. Quant small cap fund- Rs 5000. 6. HDFC Focused 30 fund- Rs. 7500 Also I am NRI I working in Gulf there the above mentioned plan are regular plan thru ICICI direct as I am unable to update my KYC online. Please suggest me that the above mentioned funds are good to invest for 5 to 10 years
Ans: You’ve taken an excellent step by beginning your journey into mutual funds and stock markets. Diversifying and rebalancing your portfolio is indeed important, and your current enthusiasm for learning and improving your financial health is admirable. I’ll help you answer your questions and outline an optimal approach to maximise returns while managing risk.

Assessing Your Current Mutual Fund Portfolio
Your existing portfolio of nine direct mutual funds reflects your willingness to diversify. However, managing too many funds can lead to overlap and complexities in tracking performance. Here’s a more streamlined approach that ensures you achieve effective diversification without unnecessary fund overlap.

Limit to Essential Fund Categories: Aim to retain only 4-5 core categories. These include a mix of large-cap, mid-cap, and flexi-cap funds, along with a smaller allocation to contra or sectoral funds for tactical growth.

Avoid Index Funds in This Case: Index funds replicate the market and lack active management, which may limit gains, especially during volatile market phases. Actively managed funds allow skilled fund managers to optimise performance based on market trends.

Reconsider Direct Funds: Investing through regular funds with a Certified Financial Planner (CFP) helps you benefit from professional guidance. While direct funds save on distributor fees, they require significant knowledge and time to monitor effectively. An MFD with CFP credentials will help you align your investments with both market trends and personal goals.

Investment Strategy for Your Lump-Sum Amount
With Rs 3.5 lakhs to invest as a lump sum, your next steps are crucial for maximising returns.

1. Choosing the Right Number of Funds
Limit Fund Selection: For the Rs 3.5 lakh investment, focus on a manageable selection of 4-5 funds. Over-diversification may dilute returns without proportionate risk reduction.

Strategic Allocation: Allocate funds in a way that balances growth with stability. For example, allocate portions to large-cap, mid-cap, and flexi-cap funds, with a smaller allocation to a contra fund if you’re open to moderate risk.

Prioritise Active Funds over Passive Index Options: Actively managed funds allow professional adjustments in line with changing market conditions, aiming for higher returns over time.

2. Timing of Lump-Sum Investment
Market Timing vs. Systematic Approach: As markets can fluctuate unpredictably, consider a phased approach, such as a Systematic Transfer Plan (STP). This way, you can gradually move the lump sum from a low-risk fund to equity funds over a few months, reducing the risk of investing all at once during a downturn.

Assessing Current Market Levels: The market downtime you mentioned may appear tempting, but markets may take time to stabilise. By investing in phases, you mitigate risk while capitalising on potential market rebounds.

Suggested Mutual Fund Categories for Long-Term Growth
Since you’re aiming for a 5 to 10-year period, a well-structured portfolio with actively managed funds is crucial. I’ll avoid suggesting specific schemes and instead outline fund categories that align with your goals.

1. Large-Cap Funds for Stability
Why Large-Cap Funds? These funds invest in established companies, offering stability and consistent growth. Over time, they help anchor the portfolio, especially during market volatility.

Ideal Allocation: Allocate about 30-40% of your lump-sum investment to large-cap funds to ensure stability in your portfolio.

2. Mid-Cap Funds for Growth Potential
Mid-Cap Funds’ Role: Mid-cap funds balance stability with higher growth prospects. While they’re slightly more volatile than large-cap funds, they offer strong potential returns.

Ideal Allocation: Consider allocating 20-25% of your lump-sum investment to mid-cap funds to capture this growth.

3. Flexi-Cap Funds for Market Flexibility
Flexi-Cap Benefits: These funds provide flexibility by investing across large, mid, and small-cap stocks based on market conditions. This helps maximise growth potential while managing risk.

Ideal Allocation: Allocate around 25% of your lump-sum investment here. Flexi-cap funds give fund managers room to adapt the fund based on market trends.

4. Contra or Value Funds for Tactical Growth
Tactical Role of Contra Funds: Contra or value funds invest in undervalued stocks, aiming to capitalise when these stocks eventually rise. They add a contrarian growth element to the portfolio.

Ideal Allocation: Allocate a smaller portion, around 10-15%, to a contra fund to enhance returns while maintaining manageable risk.

Tax Implications to Keep in Mind
Understanding tax implications helps optimise net returns. Here’s a snapshot of the applicable taxes:

Equity Mutual Funds: Gains above Rs 1.25 lakh per annum are taxed at 12.5% for long-term capital gains (LTCG). Short-term gains are taxed at 20%.

Debt Mutual Funds: Both LTCG and short-term capital gains (STCG) are taxed as per your income tax slab. If you include debt funds for a part of your portfolio, consider this in your tax planning.

Additional Recommendations to Strengthen Your Financial Position
1. Build an Emergency Fund
Maintain a separate emergency fund covering at least six months’ expenses. This fund acts as a safety net, ensuring you don’t need to dip into your investments for unforeseen expenses.
2. Term Insurance for Financial Security
Ensure adequate term insurance coverage, providing financial stability to your dependents in your absence. This policy type offers high coverage at low costs, making it an ideal safety net.
3. Health Insurance for Your Family
Having comprehensive health insurance prevents your investment corpus from being impacted by medical expenses. Check for policies that cover critical illnesses for robust coverage.
4. Review Portfolio Regularly with a CFP
A Certified Financial Planner can help assess and adjust your portfolio as needed. Regular reviews allow you to stay aligned with your financial goals and market conditions.
5. Consider Goal-Based SIPs for Future Objectives
While your lump-sum investment supports wealth creation, consider setting up goal-based SIPs to address specific future goals, such as a child’s education or retirement.
Final Insights
Your commitment to long-term investment is commendable. With a structured approach and regular reviews, your portfolio can be geared for strong growth over the next 5-10 years. By focusing on actively managed funds, phased investments, and strategic fund selection, you’re well-positioned to achieve both security and growth.

For any further queries or detailed discussions, please feel free to reach out.

Best Regards,
K. Ramalingam, MBA, CFP,
Chief Financial Planner,
www.holisticinvestment.in
https://www.youtube.com/@HolisticInvestment

..Read more

Ramalingam

Ramalingam Kalirajan  |6986 Answers  |Ask -

Mutual Funds, Financial Planning Expert - Answered on Nov 02, 2024

Asked by Anonymous - Oct 31, 2024Hindi
Money
Dear team, Hi I’m 46 years would like to start my investment in MF for 5 to 10 years . Till now I have not invested in any share market or MF. I have selected the following funds: 1. ICICI pru Blue chip fund-Rs 5000 2. Nippon India Small cap fund- Rs 10000. 3. Nippon India Multi cap fund -Rs 7500. 4. Motilal oswal Mid cap fund- Rs 10000. 5. Quant small cap fund- Rs 5000. 6. HDFC Focused 30 fund- Rs. 7500. 7 . ICICI Pru Infrastructure fund Rs 5000. Also I am NRI I working in Gulf and the above mentioned plan are regular plan thru ICICI direct as I am unable to update my KYC online. Please suggest me that the above mentioned funds are good to invest for 5 to 10 years . Thanks & regards
Ans: Your choice of mutual funds is well-diversified across various categories. However, to optimise returns and balance risk, consider a few refinements to your strategy.

1. Equity Exposure Through Blue Chip and Focused Funds

Blue Chip Fund: Investing in large-cap funds like a blue chip fund offers stability. These funds invest in established companies, making them suitable for wealth preservation. A large-cap allocation is vital for your portfolio’s foundation.

Focused Fund: Focused funds concentrate investments in fewer stocks. While they may offer higher returns, they also carry higher risk. A focused fund with limited holdings can be beneficial, but it’s wise to limit its percentage within your overall portfolio.

2. Small Cap and Mid Cap Investments for High Growth Potential

Small Cap Funds: Small-cap funds can deliver high returns, especially over longer periods. However, they are more volatile and may underperform during market downturns. Since you are considering a 5-10 year horizon, you may benefit from a balanced allocation to small-cap funds. This can capture growth while managing volatility.

Mid Cap Fund: Mid-cap funds offer a balance between large-cap stability and small-cap growth. This category can provide significant growth in a growing economy. It’s prudent to invest, but avoid a heavy allocation to maintain portfolio stability.

3. Multi Cap and Sector-Specific Exposure

Multi Cap Fund: Multi-cap funds invest across large, mid, and small-cap stocks, providing diversification. This type of fund can act as a stabiliser, balancing growth and stability. Including a multi-cap fund is ideal for capturing broad market growth.

Sector Fund (Infrastructure): Sector funds like an infrastructure fund are concentrated in specific industries. While they may perform well during industry growth phases, sector funds can underperform when the sector faces challenges. Limit your allocation to sector-specific funds to about 5-10% of your total investment.

Key Considerations as an NRI Investor
1. Regular Plans Through a Certified Financial Planner (CFP)

Direct mutual funds may not offer personalised support, and tracking investments can become difficult without guidance. Opting for regular funds through a Certified Financial Planner (CFP) can provide tailored insights, regular reviews, and potential risk management, which are crucial when you are overseas. Regular funds, through a reliable CFP, can help you maximise returns without compromising your convenience.
2. Limitations of Online KYC and Documentation for NRIs

Completing KYC updates online can be challenging for NRIs. However, working with a trusted platform like ICICI Direct can simplify this process, as you’re already aware. Ensure all documentation, including FATCA and KYC, is accurate to avoid compliance issues.
3. Taxation Implications for NRIs on Mutual Funds

As an NRI, you are liable for taxes on your mutual fund gains. For equity funds, long-term capital gains (LTCG) above Rs 1.25 lakh are taxed at 12.5%, while short-term gains are taxed at 20%. For debt funds, both LTCG and STCG are taxed as per your income slab. Staying aware of these tax implications can help in post-tax return calculations.
Suggested Adjustments to Enhance Returns and Minimise Risk
Reduce Sector Fund Allocation: Limit your investment in sector funds like infrastructure to around 5-10% of your portfolio. Overweighting in sector funds may lead to high volatility, especially if the sector experiences a downturn.

Balanced Allocation to Mid and Small Cap Funds: While small-cap funds can drive returns, they can also be unpredictable. Consider capping your combined allocation to small and mid-cap funds at 30-35% of the total investment. This can enhance growth potential while maintaining balance.

Consider Increasing Large Cap Allocation: Adding a second large-cap or flexi-cap fund can bring stability. Large-cap funds perform well in uncertain market conditions, adding a buffer to your portfolio.

Limit Focused Fund Exposure: As focused funds carry a concentrated risk, consider keeping this allocation below 10% of your portfolio.

Final Insights
A mix of stability from large-cap funds and growth from mid and small-cap funds is ideal. This can help achieve both capital appreciation and protection.

Regular reviews with a Certified Financial Planner are advisable. This will ensure that your portfolio remains aligned with market conditions and your financial goals.

Focus on a balance between growth and stability, especially considering your medium-term investment horizon of 5-10 years.

By making these small adjustments and following a consistent review approach, you can create a portfolio that is balanced, growth-oriented, and suited for the medium term.

Best Regards,

K. Ramalingam, MBA, CFP,

Chief Financial Planner,

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

..Read more

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Help me!!! 1.I'm starting new "work" on my own(challenging for me) but my mind says quit it, be quite & do nothing. I myself don't know that wether the result of work will be +ive or uncompleted like alws. 2. My mind has become like order seeker type, when someone orders me, I do those things with dedicated(but sad from inside) manner. But when myself will try something different(which i fear, but necessary) then. "I QUITS IT" & sometimes I don't even start. 3. I'm like stuck no clue what/whom I want to do in life, I'm in cllg(1 yr) doing (CSE) ,. 4. I want to do/try (sports,talking girls,study,stocks,coding..) many things, but myself, my thoughts(overthinker), R like just be in the place where u are[confused,po*n,think about past/future(being billio..re,olympics..), girl (that u liked & never talked), abusive/beating self,.. sometimes feels like end life, but don't hv courage for that also.. 5. I tried self help books, spirituality, god, self affirmation, writing... & thay affected me(sometimes) but for only some time, then again that devil me comes up &these things never get completed. As no one in my family knows about all these, so that's Y ,I hv to fight/loose/try again, the battles with myself.
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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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