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iiTHE UNIONBUDGET 2013

An Analytical Overview

PREFACE

As soon as the Budget proposals are announced by the Finance Minister, theen re country goes into overdrive for analysing the proposals and the impactthey would have on the economy, stock markets, industry, trade and thecommon man. Our profession is no exception. Therefore, at WIRC we havealways strived to provide the most lucid analysis as soon as possible for thebene t of our fraternity, their clients and the people at large.

This year the Budget proposals have been kept limited considering theeconomic situa on, poli cal compulsions, etc. The Finance Minister has donesome ght manoeuvring to rein in the scal de cit, harness in a on and givesome impetus to industry and investments.

We are pleased to give an analytical overview of the Budget proposals andwould like to thank all the contributors for their painstaking e orts in giving ustheir analysis in such a short me.

We trust that you will nd the publica on useful as a handy guide for be erunderstanding of the Budget proposals.

CA. Shrut Shah CA. Hardik ShahChairperson, Direct Tax Commi ee of Chairman, Indirect Tax Commi ee of WIRC of ICAI WIRC of ICAI

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FOREWORDThe last one year has featured internal as well as external in uences having

a ected the economy and hampered the growth. Amidst the slowdown, highinflation and ballooning current account deficit, the Finance Minister hashad to tread very carefully to lighten the economic burden of the countrywhile pain ng an encouraging and balanced picture to a ract investors, bothdomes c & foreign.

Economic ac vity is expected to be given a boost through higher alloca on(29.4%) towards plan expenditure and increased outlays for socialinfrastructure, educa on, rural development, health and urban development.

The Finance Minister has also emphasized on the development of the youthand empowerment of women, feeling it to be the need of the hour.

The Finance Minister has tried to adopt a carrot and stick approach whiletrying to get the economy back on track. Taking on the challenge of fiscaldeficit headlong the budget aims for fiscal consolidation by curtailingGovernment expenditure, limi ng fuel subsidy, re-looking at disinvestmentopportunities apart from other measures. Certain direct tax proposals areintended to be methods of increasing the tax-GDP ratio by augmentingtax revenues. The imposition of surcharge on the super-rich, increase in

surcharge for the corporate sector, imposi on of Commodi es Transac on Taxon non-agri commodi es are some such measures.

However, incen ve for the manufacturing sector in the form of an investmentallowance of 15% for new plant and machinery exceeding Rs 100 croreis a welcome move. Proposal for continuation of concession on DividendDistribu on Tax for dividends from foreign subsidiaries and onward removalof cascading e ect of tax thereon may help to promote repatria on of morefunds to India.

On the one hand, The Finance Minister has seemed to show a so er stanceby introducing the Service Tax Voluntary Compliance Encouragement Scheme,where as on the other hand, the stringent provisions of increased penaltyand imprisonment gives the message that non-compliances will be seen veryseriously.

I sincerely thank Chairperson of Direct Tax Committee, CA. Shruti Shahand Chairman of Indirect Tax Committee, CA. Hardik Shah for theirefforts in compiling this publication in a short time. I also thank andacknowledge the un ring commitment and immense contribu on made byCA. A. R. Krishnan, CA. S. S. Gupta, CA. Ketan Ved, CA. Paras Savla,CA. N. C. Hegde and CA. Sanjeev Lalan in preparing this publica on.

I wish all the members a successful and prosperous new nancial year!

CA. Mangesh KinareChairman, WIRC of ICAI

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INDEX

Sr. No. Partculars Page Nos.

Foreword ...................................................................................................... i

Preface ..................................................................................................... ii

DIRECT TAXES

I. Rates of Tax ....................................................................................1

II. Individual Taxa on .......................................................................... 9

III. Corporate Taxa on .......................................................................12

IV. An Avoidance Provisions ............................................................18

V. Procedural Provisions ................................................................... 22

VI. Agricultural Income & Land .......................................................... 27

VII. Other Major Amendments ...........................................................28

INDIRECT TAXES

I. CUSTOMS DUTY ........................................................................................... 32

II. CENTRAL EXCISE & CENVAT CREDIT RULES ................................................. 36

III. SERVICE TAX ................................................................................................. 39

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Unless other wise speci cally men oned, the amendments proposed aree ec ve from the Assessment Year (A.Y.) 2014-2015 and are, therefore,applicable to income arising on or a er 1st April, 2013. Speci c men onis made at the relevant places, when the e ec ve date of the proposedamendment is other than A.Y. 2014-15. Reference to the exis ng provisionsmeans the provisions of the Income-tax Act, 1961 (Act) prior to theamendments proposed in the Finance Bill, 2013 (Bill). Any reference tosec ons, unless otherwise stated, is to the sec ons of the Act.

I. RATES OF TAX

1. The following changes have been proposed in the Bill in the rates oftax.

No change in individual tax slab rates. However individualearning gross total income up to ` 5,00,000 is entitled forrebate of ` 2,000 or tax amount, whichever is lower.

Surcharge has been introduced applicable to Individual, HUF,AOP, BOI, AJP, Firm, Local Authority, Co-operative societyearning gross income exceeding ` 10 crores.

Surcharge on companies raised

Domes c Company

a. Total Income upto ` 1 crore Nil

b. Total Income exceeding ` 1 crore butupto ` 10 crore 5%

c. Total Income exceeding ` 10 Crore 10%

Other than Domes c Company

Total Income up to ` 1 crore Nil

Total Income exceeding ` 1 crorebut upto ` 10 crore 2%

Total Income exceeding ` 10 Crore 5%

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Basic exemp on limit for each kind of assessee is as under:

Sr. Persons Amount ( ` )No.

1. Individuals, including women (other 2,00,000than Senior Ci zen / Very SeniorCi zen) HUF, BOI, AOP, Ar cial

juridical person (other than society,local Authority)

2. Senior Ci zen (Age from 60 but 2,50,000less than 80 years)

3. Very Senior Ci zen (Age 80 years 5,00,000and above)

As a relief to marginal tax payer, it is proposed to introducenew sec on 87A providing rebate of ` 2,000 or tax amount,whichever is lower. Relief is available to the tax payer whosetotal income is not exceeding ` 5,00,000.

There is no change in

tax rates for Firms, Domestic Companies, Companyother than Domestic Company and Co-operativeSocie es (other than due to levy of surcharge);

educa onal cess, secondary and higher secondary cessand its applicability;

the rate of Dividend Distribution Tax (DDT) (otherthan due to levy of surcharge);

the rate of Minimum Alternate Tax (MAT) (other thandue to levy of surcharge).

Concessional rate of tax of 15% levied on dividend incomereceived from a foreign subsidiary company extended fordividends received upto 31st March, 2014.

There is no change in Wealth Tax threshold limit and rate oftax.

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Rate of Securi es Transac on Tax in sale of a unit of equityoriented fund reduced to 0.001% from 0.1% and sale offutures from 0.017% to 0.01%.

Commodity Transaction Tax has been introduced @ 0.01%on sale of Commodity Deriva ve, other than on agriculturalcommodity deriva ve.

2. The proposed income-tax rates (including surcharge at the rateapplicable, educational cess @ 2% and secondary and higher

secondary cess @ 1%) for A.Y. 2014-15 have been given in Table 1.These rates are applicable on income earned during the period 1April 2013 to 31st March, 2014.

3. The rates of Dividend Distribution Tax, Securities Transaction Tax,Commodi es Transac on Tax and Wealth Tax are given in Table 2.

TABLE 1

Threshold Tax Rates Par culars Limit for

Surcharge Without With Surcharge Surcharge

Individuals, HUF, AOP & BOI ` 1,00,00,000

Up to ` 2,00,000 NIL NIL ` 2,00,001 ` 2,50,000* 10.3000% 11.3300%

` 2,50,001

`5,00,000** 10.3000% 11.3300%

` 5,00,001 ` 10,00,000 20.6000% 22.6600%

` 10,00,001 ` 1,00,00,000 30.9000% 33.9900%

` 1,00,00,000 and above N.A. 33.9900%

Alternate Minimum Tax # ` 1,00,00,000 19.0550% 20.9605%

* Nil Tax Rate in case the assessee is resident aged 60 years and above butbelow age of 80 years.

** Nil Tax Rate in case the assessee is resident and above the age of 80 years. Resident individual is en tle to claim rebate up to ` 2,000 or tax amount,

whichever is lower. # Applicable in case of individuals, HUF, AOP and BOI having adjusted total

income equal to or exceeding ` 20,00,000 and where a deduc on is claimedunder sec ons 80H to 80TTA (except 80P) and sec on 10AA.

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Limited Liability Partnership

Normal tax ` 1,00,00,000 30.9000% 33.9900%

Alternate Minimum Tax # ` 1,00,00,000 19.0550% 20.9605%#Applicable in case of partnership rms where a deduc on is claimedunder sec ons 80H to 80TTA (except 80P) and sec on 10AA.

Domes c company

Normal Tax ` 1,00,00,000 30.9000 % 32.4450%

` 10,00,00,000 N.A. 33.9900%

Minimum Alternate Tax ` 1,00,00,000 19.0550% 20.0078%

` 10,00,00,000 N.A. 20.9605%

Company other thanDomes c company

Normal Tax ` 1,00,00,000 41.2000% 42.0240%

` 10,00,00,000 N.A. 43.2600%

Minimum Alternate Tax ` 1,00,00,000 19.0550% 19.4361%

` 10,00,00,000 N.A. 20.0078%

Local Authority ` 1,00,00,000 30.9000% 33.9900%

Co-opera ve Society ` 1,00,00,000

Up to ` 10,000 10.3000% 11.3300%

` 10,001 ` 20,000 20.6000% 22.6600%

` 20,001 ` 1,00,00,000 30.9000% 33.9900%

` 1,00,00,000 onwards N.A. 33.9900%

STCG on listed Security

Individuals, HUF, ` 1,00,00,000 15.4500 % 16.9950%AOP & BOI

Partnership Firm ` 1,00,00,000 15.4500 % 16.9950%Domes c Company ` 1,00,00,000 15.4500 % 16.2225%

` 10,00,00,000 N.A. 16.9950%

Company other than ` 1,00,00,000 15.4500% 15.7590%Domes c Company ` 10,00,00,000 N.A. 16.2225%

TABLE 1

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LTCG*

Individuals, HUF, AOP, & BOI ` 1,00,00,000 20.6000% 22.6600%

Partnership Firm ` 1,00,00,000 20.6000% 22.6600%

Domes c company ` 1,00,00,000 20.6000% 21.6300%

` 10,00,00,000 N.A. 22.6600%

Company other than ` 1,00,00,000 20.6000% 21.0120%Domes c Company ` 10,00,00,000 N.A. 21.6300%

*Other than LTCG arising on sale of listed securi es (which are soldotherwise then on stock exchange) which, at the op on of the tax payer,can be taxed at a concessional tax rate of 10% (ignoring the indexa onbene t).

TABLE 2

Par culars Tax Rates

Dividend Distribu on Tax

By Domes c Company 16.9950%

By Money Market Mutual Fund or Liquid fund

For income distributed to Individual/HUF 28.3250%

For income distributed to others 33.9900 %

By other Money MarketMutual Fund or Liquid fund

For income distributed to 13.5187% & individuals / HUF 28.325% -

w.e.f. 1 st June, 2013

For income distributed to others 33.9900 %

By a Mutual Fund under Infrastructure Debt Fund Scheme

For income distributed to non-residents / 5.6650% - w.e.f

Foreign Company 1st

June, 2013Note: Equity Linked Mutual Fund con nues to be exempt from DDT

Buy Back of Shares 22.6600% w.e.f.1 st June, 2013

TABLE 1

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Commodi es Transac on Rate of Tax To be paidTax by

Sale of commodity 0.01% (applicable from Sellerderiva ves, traded in the date to berecognised associa ons no ed)(Other thanAgricultural commodityderiva ves)

Wealth Tax Rate of Tax Threshold limitFor every individual, HUF 1% ` 30,00,000and Company (other thanSec on 25 Companies)

Tax on income distributed to unit holders

4. Rate of tax on an income distributed to individual & HUF by a fund

other than money market mutual fund or a liquid fund has beenraised to 25% from exis ng 12.5%.

5. Income received by the non-resident from infrastructural debt fundis chargeable to tax at the concessional rate of tax of 5%. It is nowproposed to extend concessional rate to income distributed by amutual fund under an Infrastructure debt scheme. Currently rate oftax on income distributed by a mutual fund under an Infrastructure

debt scheme is 12.5% or 30% as the case may be. However, the newproviso states that when any income is distributed by the MutualFund under an Infrastructure debt scheme, the mutual fund wouldbe liable to pay addi onal income tax @ 5% on such distribu on. Theabove amendment is proposed to take e ect from 1st June, 2013.

Taxability of royalty or fees for technical services

6. In terms of sec on 115A of the Act, royalty or fees for technicalservices received by a non-resident pursuant to an agreemententered in to on or a er 1st June, 2005 is taxable at the rate of 10%.

7. The Bill proposes to amend the said sec on 115A to provide thatany amount in the nature of royalty or fees for technical servicesreceived by a non-resident on or a er 1st April, 2014 in pursuance of

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an agreement entered in to a er 31st March, 1976 will be taxable atthe rate of 25%.

8. It may, however, be noted that in spite of this proposed amendment,if the rate for taxa on of royalty or fees for technical servicesunder the relevant DTAA is lower than 25% then the applicable ratewill be that lower rate.

Commodity Transac on Tax

9. Chapter VII of the Finance Bill 2013 introduces new levy in the formof Commodity Transac on Tax (CTT). Brief features of CTT are

Taxable Transaction : Sale of commodity derivatives in respect ofcommodities other than agricultural commodities on recognisedassociation. No tax is levied on sale of agricultural commodityderiva ve and currency deriva ve.

CTT rate: 0.01% on sale value of commodity derivative (non-agricultural commodity)

CTT paid by: Seller

Collection and payment of STT: It is provided that CTT would becollected by the recognised associa on from the seller and paid tothe credit of Central Government within 7 days from end of calendarmonth in which it is collected.

Other procedure: Chapter also provides for other proceduralrequirements like furnishing of return, assessment, rec ca on ofmistake, levy of interest & penalty on delayed payments, penalty fornon- ling of return, non-compliance of no ce, applicability of certainprovisions of Income-tax Act, 1961, appeals, prosecu on etc.

Date of Applicability: From the date of no ca on

It has been also provided that CTT would be allowed as deduc onu/s 36(xvi) while computing income arising out of commodityderiva ve transac ons under the head Pro ts and gains of businessand profession.

Similar provisions were also sought to be introduced by Finance Bill,2008, but were dropped at the me of passage of the Bill. Then rateof CTT proposed was 0.017%.

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II. INDIVIDUAL TAXATION

Assigned Keyman Insurance Policies

10. As per clause (10D) of section 10 amount received under a lifeinsurance policy, other than Keyman insurance cover, is exempton fulfilment of certain conditions. There was an anomaly in theprovisions in respect of sums received on maturity of such assignedKeyman insurance policies by the Keyman concerned. It is nowproposed to amend the Explanation-1 to the said clause w.e.f.1st April, 2013, to provide that even a policy which is assigned, withor without considera on, shall con nue to mean Keyman insurancepolicy. Thus, any sum received by an assignee in respect of suchassigned Keyman insurance policy, whether for considera on or not,shall not be exempt from tax. In e ect the Delhi High Court decisionsin CIT vs. Rajan Nanda [(2012) 349 ITR 8 (Del)] and Escort HeartIns tute & Research Centre vs. CIT [(2013) 30 taxmann.com 4] areproposed to be overruled by the amendment.

Immovable property received for inadequate considera on

11. Presently as per the provisions of sec on 56(2)(vii)(b) any immovableproperty, the stamp duty value of which is less than y thousandrupees, which is received without considera on is taxable. However,if the property is received for inadequate consideration, samehas held to be not coming within the purview of this provision.In order to bring the immovable property received for inadequateconsideration within the purview of this section, it is proposedto replace clause (b) by a new clause. The effect of proposedamendment shall be that receipt of any immovable property for aconsidera on which is less than the stamp duty value by an amountexceeding y thousand rupees, then the di erence in stamp dutyvalue and considera on paid shall be considered to be income undersec on 56(2)(vii).

12. It is also proposed to provide that where the date of an agreementfixing the value of consideration for the transfer of the asset anddate of registra on of the transfer of the asset are not same, thestamp duty value may be taken as on the date of the agreement fortransfer and not as on the date of the registra on of such transfer.This exception shall apply only in those cases where amount ofconsidera on or part thereof for the transfer has been received by

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17. It is proposed to provide a deduc on of not more than ` 1 lakh inrespect of interest payable on loan taken (sanc oned amount not toexceed ` 25 lakhs) by an individual from any nancial ins tu on forthe purpose of acquisi on of a residen al house property, the valueof which does not exceed ` 40 lakhs. Further, in case, where suchinterest payment is less than ` 1 lakh in the previous year endingon 31st March, 2014, i.e. A.Y. 2014-15, the balance amount shall beallowed as deduc on in A.Y. 2015-16.

18. In order to avail the above deduc on, the individual assessee shouldnot own any residen al house on the date of sanc on of loan.

19. Sub-section (4) of section 80EE provides that, where a deductionfor any interest is allowed under section 80EE(1), deduction shallnot be allowed on such interest under any other provisions of theAct for the same or subsequent assessment year. In the explanatorymemorandum it is clarified that Keeping in view the need foraffordable housing, an additional benefit for first-home buyers is

proposed . Before this clari ca on the background of deduc onavailable under sec on 24 is also given. Thus, it would mean that tothe extent of deduc on available under sec on 80EE, no deduc oncan be claimed under sec on 24 and not that bene t of sec on 24shall be lost in respect of balance por on of interest over and aboveone lakh rupees.

20. While under sub-sec on (5) de nes the terms nancial ins tu on and housing nance company are de ned, there is no reference tohousing nance company in any of the preceding sub-sec ons!

Rajiv Gandhi Equity Savings Scheme

21. As per the present provisions of sec on 80CCG, a resident individual,being a rst me retail investor and whose total income during theprevious year does not exceed ten lakh rupees, is eligible to claim adeduc on of y per cent up to maximum of twenty ve thousandrupees in the year of investment, subject to satisfaction of othercondi ons. This deduc on is available only once, i.e. in the year inwhich investment is made for the rst me.

22. As per amendments proposed, the bene t under the said sec onis proposed to be extended to investment in listed units of anequity oriented fund de ned in sec on 10(38). Further, the bene t

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of this sec on is proposed to be extended over a period of three

consecutive assessment years beginning with assessment year inwhich investment is rst made. Also, the condi on as to limit of totalincome of the individual investor in the year in which investment ismade is proposed to be enhanced to twelve lakh rupees from tenlakh rupees, by amending clause (i) of sub-sec on (3).

III. CORPORATE TAXATION

Investment in new assets by manufacturing company

23. A new sec on 32AC is proposed to be inserted to allow deduc onof a sum equal to een per cent of the actual cost of new assetsacquired and installed after the 31st March, 2013 but before1st April, 2015 if the aggregate amount of actual cost of such newassets exceeds one hundred crore. This deduction is available toan assessee which is a company and engaged in manufacture orproduc on of any ar cle or thing. This deduc on is available for twoyears as under

(a) for assessment year commencing on 1st April, 2014, of a sumequal to een per cent of the actual cost of assets acquiredand installed after 31st March, 2013 but before 1st April,2014, if the aggregate investment exceeds rupees one hundredcrore; and

(b) for assessment year commencing on 1st April, 2015, of a sumequal to een per cent of the actual cost of assets acquiredand installed after 31st March, 2013 but before 1st April,2014, as reduced by deduction allowed, if any, as per (a)above.

24. If any new asset is sold or otherwise transferred within a period offive years after installation, then deduction allowed on such newasset shall be deemed to the income of the year in which suchnew asset is sold or otherwise transferred as per the proposedsub-section (2) to section 32AC. The issues that would arise hereis whether the whole of deduc on will be withdrawn or deduc onallowed in respect of new asset that is sold or transferred shall only

be withdrawn, especially in a case where the actual cost of newasset sold or transferred leads to a situa on that the actual cost ofnew assets in aggregate in the year of acquisi on and installa onfalls below the threshold limit of rupees one hundred crore. It is alsointeres ng to note that the sec on does not specify the condi on ofput to use for claim of deduc on and it would su ce if the newassets are acquired and installed.

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25. The deduc on shall not be withdrawn under sec on 32AC(2) where

the new asset is sold or otherwise transferred in connec on with theamalgama on or demerger within a period of ve years. However,the condi ons of sub-sec on (2) shall apply to the amalgamated orresul ng company, as the case may be, as it would have applied tothe amalgama ng company or demerged company as speci ed insec on 32AC(3).

26. This deduc on would be available even if such assets are acquiredand installed in more than one manufacturing business by the samecompany assessee if the aggregate value of actual cost of investmentexceeds one hundred crore rupees.

27. As per sub-section (4) for the purpose of section 32AC, the newassets shall mean any new plant and machinery (other than ship oraircra ), other than the following

(i) any plant or machinery which was earlier used either withinor outside India by any other person;

(ii) any plant or machinery installed in any o ce premises or anyresiden al accommoda on including guest house;

(iii) any office appliances includ ing computers or computerso wares;

(iv) any vehicle; or

(v) any plant or machinery in respect of which hundred per centdeduction is allowed, whether by way of depreciation orotherwise, in compu ng income under the head Pro ts andgains of business or profession of any previous year.

28. It should be noted that actual cost has been defined undersub-sec on (1) to sec on 43 and therefore actual cost of new assetswould have to be computed in accordance with the said provision.

Disallowances in case of State Government Undertaking29. There have been disputes in respect of assessments of some State

Government Undertakings regarding deduc bility of certain privilegefee, licence fee, royalty, etc., levied or charged by State Governmentexclusively on its undertakings. In some cases orders have beenissued to the e ect that surplus arising to such undertakings shall

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vest with State Government. As a result it has been claimed that

such income by way of surplus is not subject to tax.

30. Sec on 40 is proposed to be amended, to disallow certain paymentsmade by State Government Undertakings to State Government,by inser ng a new sub-clause (iib) in clause (a). Thus, payment ofroyalty, licence fee, service fee, privilege fee, service charge or anyother fee or charge, by whatever name called, which is exclusivelylevied on or which appropriated, directly or indirectly from a StateGovernment Undertaking by the State Government will be nowdisallowable.

31. An explana on is also proposed to be inserted to the said sub-clauseto de ne a State Government Undertaking.

Extension of the sunset date under sec on 80IA for the power sector

32. Presently under sec on 80IA(4)(iv), a deduc on of pro ts and gainsis allowed to an undertaking, if it

(a) is set up in any part of India for the genera on or genera onand distribu on of power, if it begins to generate power atany me between 1st April, 1993 to 31st March, 2013;

(b) starts transmission or distribution by laying a network ofnew transmission or distribu on lines at any me between1st April, 1999 to 31st March, 2013;

(c) undertakes substantial renovation and modernisation ofexis ng network of transmission or distribu on lines at anyme between 1st April, 2004 to 31st March, 2013.

It is proposed to provide further time to the undertakings tocommence the above ac vity, to avail the deduc on. Accordingly theterminal date for availing bene t is extended upto 31st March, 2014for the above en es.

Deduc on of addi onal wages33. Under the existing provisions of section 80JJAA a deduction of

amount equal to thirty per cent of additional wages paid to thenew regular workmen employed in any previous year by an Indiancompany in its industrial undertaking engaged in manufacture ofproduc on of ar cle or thing. This deduc on is available for three

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assessment years, including the assessment year in which such

employment is provided. Also, no deduction is available if theindustrial undertaking is formed by splitting up or reconstructionof an exis ng undertaking or amalgama on with another industrialundertaking.

34. It is now proposed to subs tute sub-sec on (1) of the said sec onto restrict the benefit of deduction to profits and gains derivedfrom the manufacture of goods in a factory instead of any industrialundertaking engaged in manufacture or production of article orthing. Further, the computa on of addi onal wages will be reckonedwith employment provided in factory only and not all the workmenemployed by the assessee company.

35. Further, clause (a) of sub-sec on (2) is also proposed to be amendedand the deduction shall not be allowed if the factory is hived offor transferred from another exis ng en ty or acquired by assesseecompany as a result of amalgama on with another company.

36. The reference to the word undertaking wherever it occurs in theexplana on, is proposed to be subs tuted by factory and it is alsoproposed to insert clause (iv) to the explana on to de ne factory asper sec on 2(m) of the Factories Act, 1948.

37. The proposed amendment is to overcome decision of BangaloreBench of ITAT in ACIT vs. Texas Instruments (India) (P.) Ltd. [(2008)115 TTJ 976 (URO)].

Addi onal Income-tax on buy-back of unlisted shares

38. Under the exis ng provisions of Income-tax Act, gains on buy-backof shares are chargeable to tax under the head capital gains undersection 46A. In the explanatory memorandum it is stated thatunlisted companies, as part of tax avoidance scheme, are resor ngto buy-back of shares instead of payment of dividends in order toavoid payment of tax by way of dividend distribution tax (DDT),

par cularly where the capital gains arising to the shareholders areeither not chargeable to tax or are taxable at a lower rate . To curbsuch prac ce, a new Chapter XII-DA is proposed to be inserted w.e.f.1st June, 2013 to provide for taxa on of any amount of distributedincome by a domestic company on buy-back of shares, which arenot listed on a recognised stock exchange, from a shareholder. The

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company shall be liable to pay addi onal income-tax at the rate of

twenty per cent on the distributed income.

39. As per the explanation to sub-section (1) it is proposed to definebuy-back to mean purchase by a company of its own shares inaccordance with provisions of section 72A of the Companies Act,1956. The term distributed income is proposed to be de ned tomean the considera on paid by the company on buy-back of sharesas reduced by the amount which was received by the companyon issue of such shares. Thus, a company shall have to computedistributed income in respect of such shares, which are o ered forbuy-back, by taking in to account the amount which was receivedfor every issue, if shares that are o ered for buy-back were issuedat di erent point of me at di erent issue price.

40. The addi onal income-tax on such buy-back of shares shall have tobe deposited within fourteen days from the date of payment of anyconsidera on to the shareholder. In case of delay in deposit of tax,simple interest at the rate of one per cent shall be payable for everymonth or part thereof on amount of tax not deposited ll the mesuch tax is deposited as per proposed sec on 115QB. Sec on 115QCproposes to treat any principal o cer, of a domes c company, as ano cer in default for failure to deposit the tax as per provisions ofsec on 115QA and all the provisions rela ng to collec on of recoveryof tax shall apply accordingly.

41. Further, it is also proposed to insert clause (34A) in section 10to exempt any income received by a shareholder on account ofbuy-back of unlisted shares which have been taxed under theprovisions of sec on 115QA. This provision shall come into e ectfrom 1st April, 2014.

TDS on payment of interest to non-resident by Indian Company

42. The sec on 194LC provides concessional rate of deduc on of tax atsource @ 5%. Concessional rate is available in respect of intereston money borrowed by an Indian company in foreign currencyand such borrowing is either under a loan agreement or by way ofissue of long-term infrastructure bonds, as approved by the CentralGovernment.

43. It is now proposed to extend the same bene t to investment madethrough a designated bank account in rupee denominated long terminfrastructure bonds. Designated account means an account in a

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bank where foreign currency is deposited for subscribing long term

infrastructure bonds of speci ed company. The above amendment isproposed to take e ect from 1 st June 2013.

Tax on dividends received from a foreign subsidiary

44. Concessional rate of tax of 15% levied on dividend income receivedfrom a foreign subsidiary company extended for dividends receivedupto 31st March, 2014.

Removal of cascading e ect of DDT

45. Sec on 115-O of the Act provides that dividend declared distributedor paid by a domestic company will be subjected to a DividendDistribution Tax [DDT] at the rate of 15%. It also provides thatDDT will not be payable by a company on the dividends received byit from its domes c subsidiary company [ wherein the 1 st men onedcompany holds more than half in the nominal value of equity shares ]if the subsidiary has paid DDT, thereby removing cascading e ect of

DDT in case of a domes c subsidiary company.46. The Bill proposes to remove the cascading effect in respect of

dividends received by a domes c company from its foreign subsidiary[where the domes c company holds more than half in the nominalvalue of equity shares] by providing that dividends received bya domestic company from its foreign subsidiary, which has beensubjected to tax at the rate of 15% under sec on 115BBD, shall notbe subjected to DDT under Sec on 115-O of the Act.

Amount eligible for deduc on as bad debts in case of banks

47. As per clause (a) of sec on 36(1)(viia) in compu ng business income,of certain categories of banks speci ed therein, deduc on is availablefor provision of bad and doub ul debts up to the limit of 7.5 percent of the gross total income (before deduc on under this clauseor chapter VIA) and 10 per cent of aggregate average advance madeby the rural branches of such banks. The limit, in case of banks

incorporated outside India referred to in sec on 36(1)(viia)(b) andnancial ins tu on referred to in sec on 36(1)(viia)(c), is 5 per centof the total income (before claiming deduc on under this clause orchapter VIA).

48. The courts have accepted the proposi on that where two separateprovisions for bad debts are maintained for rural and urban advances

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and if the actual write-off relates to urban advances then same

cannot be set-o against provision for bad debts of rural advances.It has been held that provisions of sec ons 36(1)(vii) and 36(1)(viia)are distinct and independent items of deductions and operate intheir respec ve elds [Catholic Syrian Bank Ltd. vs. CIT (2012) 343ITR 270 (SC)].

49. To overcome the above judicial interpretation explanation 2 isproposed to be inserted to clarify that for the purposes of provisoto clause (vii) of sec on 36(1) and clause (v) of sec on 36(2), theaccount referred to therein shall be only one account in respect ofprovision for bad and doub ul debts under clause (viia) and suchaccount shall relate to all types of advances, including advancesmade by rural branches.

Exemp on to Na onal Financial Holdings Company Limited

50. Na onal Financial Holdings Company Limited (NFHCL) is a companywholly owned by the Central Government and was incorporated tosucceed the Speci ed Undertaking of Unit Trust of India, which itselfwas a successor to erstwhile Unit Trust of India. In sec on 10 a newclause (49) is proposed to be inserted to grant exemp on in respectof any income of NFHCL.

IV. ANTI-AVOIDANCE PROVISIONS

Taxa on of immovable proper es held as stock-in-trade

51. Presently full value of considera on on transfer of any asset, beingland or building or both, is taken as per the value adopted forsuch transfer by any authority of State Government for purpose ofpayment of stamp duty, as per sec on 50C. The said sec on has noapplicability in respect of transfer of immovable property which isheld as stock-in-trade by an assessee [K.R. Palanisamy vs. UOI (2008)306 ITR 61 (Mad), CIT-II vs. Kan Construc on and Colonizers (P.) Ltd.(2012) 208 Taxman 478 (All)].

52. A new sec on 43CA is being proposed to be inserted in Chapter IV-D Pro ts and gains of business or profession. As per the proposedsection where the consideration received or accruing as a resultof an asset (other than a capital asset), being land or building orboth, is less than the value adopted for stamp duty purpose by anauthority of State Government, then the value so adopted for stamp

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duty purpose shall be deemed to be the value of the considera on

received or accruing as a result of such transfer for compu ng pro tsand gains.

53. As per section 43CA(2), the remedies provided for reference toValuation Officer and treatment of value of stamp duty authorityas final, where Valuation Officers value exceeds the stamp dutyvalua on, as contained in sub-sec ons (2) and (3) sec on 50C, canalso be availed in matters falling within the purview of proposedsec on 43CA.

54. It is also proposed to provide that where the date of an agreementfixing the value of consideration for the transfer of the asset anddate of registra on of the transfer of the asset are not same, thestamp duty value may be taken as on the date of the agreement fortransfer and not as on the date of the registra on of such transfer.This exception shall apply only in those cases where amount ofconsidera on or part thereof for the transfer has been received byany mode other than cash on or before the date of the agreementfor transfer of asset.

TDS on payment for transfer of immovable property

55. It is proposed to introduce a new section 194IA to provide fordeduc on of tax at source on payment of considera on for transferof immovable property (excluding agricultural land) by resident incases other than compulsory acquisi on. The proposed new sec onprovides that every transferee, at the me of making payment orcredi ng any sum by way of considera on for transfer of immovableproperty, shall deduct tax at the rate of 1% of such sum, if theconsideration paid or payable for the transfer of such property is

` 50,00,000 or more. Immovable property means land other thanagricultural land or whole / part of the building.

56. Similar provision were also sought to be introduced by Finance Bill2012, but was dropped at the me of passage of the Bill. The above

amendment is proposed to take e ect from 1st

June 2013.Cash contribution to any political party or electoral trust ineligible fordeduc on

57. Presently deduc on is available for any contribu on made, to anypoli cal party or electoral trust, by an Indian company or any person(other than local authority or artificial juridical person wholly or

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partly funded by the Government) under sec ons 80GGB or 80GGC

respectively. A proviso is being proposed to be inserted in boththe sections to deny the benefit of deduction in respect of anycontribution made by way of cash to a political party or electoraltrust.

General An Avoidance Rule

58. The General Anti Avoidance Rule (GAAR) was introduced in theIncome-tax Act by the Finance Act, 2012. These provisions were

to come in to force with e ect from 1st April, 2014. A number ofrepresentations were received against the provisions relating toGAAR. Accordingly, an Expert Commi ee was cons tuted with broadterms of reference for nalising the GAAR guidelines and to preparea road map for implementa on thereof.

The major recommendations of the Expert Committee have beenaccepted. Necessary amendments have been proposed in the GAARprovisions to give effect to the recommendations. Some of theseare

It is proposed to make the GAAR provisions e ec ve from theAssessment Year 2016-2017.

It is proposed that the arrangement will be held to be animpermissible avoidance arrangement only if the mainpurpose of the arrangement is to obtain a tax bene t. This isagainst the current provision providing that it should be themain purpose or one of the main purposes.

The factors like, period or time for which the arrangementhad existed, the fact of payment of taxes by the assessee, andthe fact that an exit route was provided by the arrangement,would be relevant but not su cient to determine whether thearrangement is an impermissible avoidance arrangement. Thecurrent provisions which provided that these factors would not

be relevant is proposed to be amended accordingly. An addi onal condi on has been proposed to be incorporated

to provide that an arrangement shall also be deemed to belacking commercial substance, if it does not have a signi cante ect upon the business risks, or net cash ows of any partyto the arrangement apart from any e ect a ributable to the

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tax bene t that would be obtained but for the applica on of

Chapter X-A.

The Approving Panel shall consist of a Chairperson who is orhas been a Judge of a High Court; one Member of the IndianRevenue Service not below the rank of Chief Commissionerof Income-tax; and one Member who shall be an academicor scholar having special knowledge of ma ers such as directtaxes, business accounts and interna onal trade prac ces. Thecurrent provision that the Approving Panel shall consist of notless than three members being income-tax authori es and ano cer of the Indian Legal Service is proposed to be amendedaccordingly.

The direc ons issued by the Approving Panel shall be bindingon the assessee as well as the income-tax authorities andno appeal against such directions can be made under theprovisions of the Act. The current provisions providing that

the direc on of the Approving Panel will be binding only onthe Assessing Officer have been proposed to be amendedaccordingly.

The Central Government may constitute one or moreApproving Panels as may be necessary and the term of theApproving Panel shall be ordinarily for one year and may beextended from me to me up to a period of three years.

The two separate de ni ons in the current provisions, namely,associated person and connected person will be combinedand there will be only one inclusive provision defining aconnected person.

59. Consequential amendments are also proposed in other sectionsrela ng to procedural ma ers of implemen ng GAAR. These changeswere made by the Finance Act, 2012 and were to be made e ec vefrom 1st April, 2013, however, the same are now proposed to bemade e ec ve from 1st April, 2016.

60. Some important recommenda ons of the Commi ee which have notfound a place in the GAAR Regime proposed are

While determining whether an arrangement is animpermissible avoidance arrangement, it shall be ensured that

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of the assesse. It is now proposed that besides complexity of the

accounts and interest of revenue, special audit can be initiatedhaving regard to following:

a. Volume of the accounts,

b. Doubts about correctness of the accounts,

c. Mul plicity of transac ons in accounts,

d. Specialised nature of business.

The above amendment is proposed to take e ect from 1st June, 2013.

Electronic ling of Wealth-tax returns

64. Return of wealth till date is mandatorily required to be filed inpaper form, along with specified documents. It is now proposedto introduce new section 14A empowering Board to notify classor classes of persons who can file return of wealth which is notaccompanied by statements, receipts, certificates, audit reports,reports of registered valuer or any other documents, which areotherwise under any other provisions of Wealth-tax Act. It is alsoproposed to introduce new sec on 14B empowering Board to no fyclass or classes of persons who would be mandatorily required to lereturn of wealth electronically without any documents.

65. It also provided that such assessee would be required to submit thedocuments on demand made by the Assessing O cer. Consequen al

amendments in the sec on 46 power to make rules by the Board,are also proposed. The above amendment is proposed to take e ectfrom 1st June, 2013.

Tax due for the purpose of recovery

66. Sec ons 167C and 179 provide that, where tax due from a limitedliability partnership (LLP)/private company cannot be recovered,then the partner/director (who was the partner/director of such LLP/

private company during the previous year to which tax due relates)shall be jointly and severally liable for payment of such tax, unless heproves that the non-recovery of tax cannot be a ributed to any grossneglect, misfeasance or breach of duty on his part. These provisionsare intended to recover outstanding demand under the Act from aLLP/private company from the partners/directors of such LLP/private

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company in certain cases. The Delhi High Court in the case of Sanjay

Ghai [(2012) 26 taxmann.com 203] has interpreted the phrase taxdue used in section 179 to hold that it does not include penalty,interest and other sum payable under the Act. Similar view has alsobeen taken by Gujarat High Court in Maganbhai Hansrajbhai Patelvs. ACIT [(2012) 211 Taxman 386].

67. Explana on is proposed to be inserted in sec ons 167C and 179 tobring within the ambit of expression tax due penalty, interest orany other sum payable under the Act. These amendments will takee ect from 1st June, 2013.

Extension of me for approval of recognised provident fund

68. Rule 4 in Part A of Schedule IV to the Act lays down conditionswhich are required to be ful lled by the provident fund to receiveor retain the status of Recognised Provident Fund. Clause (ea)requires provident fund to apply to the Employees Provident FundOrganisa on to obtain exemp on under sec on 17 of the EmployeesProvident Funds and Miscellaneous Provisions Act, 1952.

69. Rule 3 of Part A of Schedule IV provides that in a case whererecogni on to any provident fund has been accorded on or beforethe 31st March, 2006 and such provident fund does not sa sfy thecondi ons set out in clause (ea) of rule 4, the recogni on to suchfund shall be withdrawn, if such fund does not sa sfy, on or beforethe 31st March, 2013, the condi ons set out in the said clause and

any other condi on as speci ed by the Board.70. In order to provide me to Employees Provident Fund Organisa on

for processing the application, due date of 31st March, 2013 hasbeen extended to 31st March, 2014.

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Annual Informa on Return

71. Under sec on 285BA speci ed person are required to furnish AnnualInforma on Return (AIR) in respect of speci ed transac ons. Sec on271FA provide for penalty in case of non- ling of AIR returns. It isproposed to replace exis ng sec on to provide penalty as under

Event Penalty

Failure to furnish return within ` 100 per day

prescribed me limit u/s. 285BA(2)Failure to furnish return within period ` 500 per day (fromspeci ed in no ce issued u/s 285BA(5) the date of expiry of

the period speci ed inthe no ce)

Tax Residency Cer cate

72. The Finance Act, 2012 amended the provisions of section 90 andsec on 90A of the Act to make the submission of a Tax ResidencyCertificate [TRC] containing prescribed particulars compulsoryfor non-residents assessees to avail bene ts under the applicableDouble Tax Avoidance Agreement [DTAA].

73. It is now proposed to amend the said sec on 90 and sec on 90A ofthe Act to provide that the submission of the TRC is a necessary butnot a su cient condi on for claiming bene ts under the applicable

DTAA.74. This position was mentioned in the memorandum explaining the

provisions in the Finance Bill, 2012 but has now been given statutoryforce by incorpora ng it in the sec on 90 and sec on 90 of the Act.This amendment is proposed to be made retrospectively and willapply from the Assessment Year 2013-2014.

75. This particular amendment has created a great furore amongst

stakeholders and apprehensions have been cast that it will give hugediscre on in the hands of the tax authori es who can simply ignorethe TRC and deny DTAA bene ts to the tax payers.

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76. The Finance Minister in a subsequent statement has clari ed that

appropriate clari ca ons will be considered to the Finance Bill toensure that

IT Department not to go beyond TRC and ques on taxpayers;

CBDT Circular 789 on Indo-Mauri us Treaty s ll in force.

Period of limita on for comple on of assessments & reassessments

77. Section 153 of the Act inter-alia provides that the periodcommencing from the date on which the AO directs the assesseeto get his accounts audited under sec on 142 (2A) and ending withthe last date on which the assessee is required to furnish a report ofsuch audit, is to be excluded while compu ng the period of limita onfor the purposes of assessment or reassessment.

78. It is proposed to amend this provision to provide that the followingshall be excluded while compu ng the period of limita on

period commencing from the date on which the AO directs theassessee to get his accounts audited and ending with the lastdate on which the assessee is required to furnish a report ofsuch audit; or

where such direc on is challenged before a court, ending withthe date on which the order setting aside such direction isreceived by the Commissioner.

79. Similarly, the said sec on 153 inter-alia also provides for exclusionof the period commencing from the date on which a reference forexchange of informa on is made by an authority competent underan agreement referred to in sec on 90 or sec on 90A and endingwith the date on which the information so requested is receivedby the Commissioner or a period of one year, whichever is less, incompu ng the period of limita on.

80. This too is proposed to be amended to provide that the periodcommencing from the date on which a reference or first of thereferences for exchange of information is made by an authoritycompetent under an agreement referred to in sec on 90 or sec on90A and ending with the date on which the informa on requested islast received by the Commissioner or a period of one year, whicheveris less, shall be excluded in compu ng the period of limita on.

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81. Similar amendments are also proposed in sec on 153B of the Act

relating to the time limit for completion of a search assessment.These amendments will take e ect from 1st June, 2013.

Applica on of assets seized during search

82. Under the present provisions of sec on 132B, adjustment of seizedassets against any exis ng liabili es is permi ed. The courts haveheld that advance tax liability is also an exis ng liability [PandurangDayaram Talmale (2004) 187 CTR 625 (Bom), Shri Ram S. Sarda vs.

Dy. CIT (2012) 17 taxmann.com 23 (Rajkot)]. It is felt that the saidview is not in consonance with the legisla ve intent and to overcomethis, new Explana on 2 is proposed to be inserted w.e.f. 1st June,2013. Accordingly, it is proposed to explain that exis ng liability shallnot include advance tax payable in accordance with the provisions ofChaper XVII-C.

VI. AGRICULTURAL INCOME & LAND

Amendment in De ni on of Capital Asset

83. Presently from the definition of Capital Asset under clause(14) of section 2, there is an exclusion provided in respectof agricultural land, subject to ful lment of certain speci edconditions. The conditions are that, such land should notbe situated within the jurisdiction of municipality or acantonment board having popula on of 10,000 or more as per

last published census gures or should not be situated within8 kilometres of such municipalities or cantonment board,which the Central Government may no fy.

84. In CIT vs. Madhukumar N. (HUF) [(2012) 208 Taxman 394(Kar)] it has been held that apart from loca on of the land, ano ca on from the Central Government is also required totreat an agricultural land as urban land. It is now proposed todo away with the requirement of no ca on of urban areasand a land shall not be considered to be agricultural land if itis situated within such distance, measured aerially, in followingcircumstances

two kilometres if the popula on of such municipality orcantonment board is between 10,000 to 1,00,000;

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are defined under regulations 2(1)(f) and 2(1)(u), respectively,

of SEBI (Public Offer & Listing of Securitised Debt Instruments)Regulations, 2008 made under SEBI Act, 2002 and SCRA, 1956.Further, securi sa on of standard assets, as per guidelines issued byRBI, shall also qualify for the bene t under this clause.

89. A new Chapter XII-EA containing special provisions rela ng to taxon distributed income by Securitisation Trusts, is proposed to beinserted to provide for taxa on of any amount of income distributedby securitisation trust to its investors. As per section 161(1A), in

case of a trust, if its income consists of or includes pro ts and gainsof business then income of such trust is chargeable at maximummarginal rate in the hands of the trust. In explanatory memorandumit is clarified that special purpose entities set up in the form oftrust to undertake securitisation activities were facing problemdue to absence of special dispensation in respect of taxation,par cularly when the investors were persons which are exempt fromtaxa on, e.g. Mutual Funds. As per proposed sec on 115TA(1) thesecuri sa on trust shall be liable to pay addi onal income-tax on

income distributed to bene ciaries as under (i) 25% if the bene ciary is an individual or a Hindu undivided

family;

(ii) 30% in case the bene ciary is any other person;

It is also provided that, provisions of sub-sec on (1) shall not applyif the distribu on of income is to a person in whose case income,irrespec ve of its nature and source, is not chargeable to tax. The

securi sa on trust shall not be allowed deduc on under any otherprovisions in respect of the income which has been charged to taxunder sub-sec on (1).

90. The tax payable under sub-sec on (1) has to be deposited within14 days from date of distribution or payment of such income. Iftax is not paid within the time provided then simple interest atthe rate of 1% per month or part thereof shall be paid for thedelay as per provisions of section 115TB. Further a prescribed

statement, veri ed in prescribed manner will have to led before15th September in each year giving details of income distributed inthe previous year, tax paid thereon and such other details as maybe prescribed.

91. As per section 115TC it is also proposed to consider the personresponsible for payment of income of the securitisation trust will

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be deemed to be assessee in default, in respect of tax remaining

unpaid and all the provisions of the Income-tax Act for collec on andrecovery shall apply accordingly.

92. Further, it is also proposed that any income received from asecuritisation trust by an investor by way of distribution shall beexempt from tax under clause (35A) of sec on 10.

Pass through status to certain Alterna ve Investment Funds

93. As per the exis ng provisions of sec on 10(23FB) any income of aventure capital company (VCC) or a venture capital fund (VCF) frominvestment in venture capital undertaking (VCU) is exempt. Theincome accruing or arising or received by a person out of investmentmade in VCC or VCF shall be taxable in the same manner as if suchperson had made direct investment in the VCU as per sec on 115U.The SEBI (Alternative Investment Funds) Regulations, 2012 (AIFRegulations) have replaced the SEBI (VCF) Regulations, 1996 andin order to provide benefit of the pass through status to entities

registered under AIF Regula ons explana on to sub-clause (23FB)is proposed to be replaced. This amendment shall take e ect from1st April, 2013 and shall apply to A.Y. 2013-14.

94. As per proposed clause (a) of the new explana on, VCC shall meana company

(A) has been granted a certificate of registration, before21st May, 2012, as a VCF under SEBI (VCF) Regula ons, 1996

or(B) has been granted a cer cate of registra on as VCF as sub-

category I AIF and is regulated under SEBI (AIF) Regula ons,2012 and which ful ls the following condi ons, viz.

(i) it is not listed on a recognised stock exchange;

(ii) it has invested not less than two-thirds of its inves blefunds in unlisted equity shares or equity linked

instruments of VCU; and(iii) it has not invested in any VCU in which its director

or a substantial shareholder (beneficially holding tenper cent of equity shares) holds, either individually orcollec vely, equity shares in excess of een per centof the paid-up equity share capital of such VCU.

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95. As per proposed clause (b) of the new explana on, VCF shall mean

a fund

(A) Operating under a trust deed registered under RegistrationAct, 1908, which

(I) has been granted a certificate of registration, before21st May, 2012, as a VCF under SEBI (VCF) Regula ons,1996 or

(II) has been granted a cer cate of registra on as VCF asa sub-category I AIF under SEBI (AIR) Regula ons, 2012and ful ls the following condi ons, viz.

(i) it has invested not less than two-third of itsinves ble funds in unlisted equity shares or equitylinked instruments of VCU;

(ii) it has not invested in any VCU in which itstrustee or the se ler holds, either individually orcollec vely, equity shares in excess of een percent of the paid-up equity share capital of suchVCU; and

(iii) the units, if any, issued by it are not listed in anyrecognised stock exchange;

or

(B) Opera ng as a venture capital scheme made by the UTI.

Exemp on to income of Investor Protec on Fund of depositories

96. A new sub-section (23ED) is being proposed to be introducedto exempt any income, by way of contribution received from adepository (as de ned under sec on 2(1)(e) of SEBI Act, 1992), ofInvestor Protec on Fund set up in accordance with the regula onsmade under the SEBI Act, 1992 and the Depositories Act, 1996, by a

depository as the Central Government may no fy in this behalf.It is also provided that where any amount standing to the credit ofthe Fund, which is not charged to income-tax during any previousyear, is shared either wholly or in part with a depository, then wholeof such sum shall be deemed to be the income of the year in whichit is so shared and shall be chargeable to income-tax.

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I. CUSTOMS DUTY I) Changes in e ec ve rate of Basic Customs Duty with e ect from

1-3-2013 The following are the prominent amendments in rate of basic

customs du es:

Sr. Chapter Descrip on of E ec ve rate (in %) No. heading goods

ll from 28-2-2013 1-3-2013

1. 27011200 Bituminous coal 5 2

2. 27011920 Steam coal Nil 2

2. 7103 Pre-forms of 10 2 precious andsemi-preciousmetals

2. 84, 85 or Addi onal 20 7.5 5 90 machinery

speci ed in list29 ofno ca on12/2012-Cusfor leatherand footwearindustry

3. 8444 to All Goods 7.5 5 8449 (Machinery &

parts thereofused intex le sector)

4. 5002 Raw Silk 5 15

(not thrown)

5. 85 Integrated 5 10 DecoderReceiver(Set Top Box)

INDIRECT TAXES



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Sr. Chapter Descrip on ofq E ec ve rate (in %) No. heading goods

ll from 28-2-2013 1-3-2013

6. 8903 Yachts and 10 25 other vesselfor pleasureor sport;rowing boatsand canoes

II) Other amendments e ec ve from 1-3-2013

(a) Period of consumption/in stallation of parts or testingequipment has been extended to 1 year from 3 months inrespect of exemp on to maintenance, repair and overhauling

of aircra parts under no ca on 12/2012 (Sr. No. 448). Thesaid exemp on has been extended to MRO of private categoryof aircra s and MRO of parts of aircra s also.

(b) Notification No. 9/2012 providing exemption to customsduty on re-import of cut and polished diamonds has beenamended to provide that a variance of not exceeding 0.01mm in height and circumference and variance not exceeding 1 percent in weight will be allowed for re-import of cut andpolished diamonds.

(c) No ca on 14/2013 has been no ed to provide exemp onfrom whole of duty to trophy when imported into Indiaby National Sports Federation or registered Sports Bodyorganising the interna onal tournament including world cup.

III) Changes e ec ve from Enactment of Finance Act, 2013

(a) Section 47 has been amended to reduce the period forpayment of customs du es from 5 days to 2 days (excludingholidays) from the date of receipt of duly assessed bill ofentry. The interest will be leviable at rate of 15% on paymentof duty a er 2 working days.



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(b) Sec on 28E has been amended to enable exis ng importer

and exporter to apply for advance ruling for any new businessof import or export proposed to be undertaken by them.

(c) Sec on 30 and Sec on 41 are being amended to provide forelectronic ling of Import General Manifest/Export GeneralManifest and to give power to Commissioner to allowthe delivery of such manifest in any other manner whereelectronic ling is not feasible.

(d) Sec on 49 has been amended to provide a me limit of 30days for storage of goods in a warehouse pending clearanceand power has been given to Commissioner to extend theperiod of storage for a further period not exceeding 30 daysat a me.

(e) Sec on 69 is being amended to allow export of warehousedgoods by post on the basis of the label or declarationaccompanying the goods.

(f) Sec on 104 is being amended to provide for certain speci coffences like as evasion or attempted evasion of dutyexceeding ` 50 lakh, fraudulently availing of or attempt toavail of drawback or any exemp on from duty provided underthis Act, if the amount of drawback or exemp on from dutyexceeds ` 50 lakh, etc. as non-bailable.

(g) Monetary limit for the Single Bench of the Tribunal to hearand dispose of appeals from Sec on 129C is being increasedfrom ` 10 lakhs to ` 50 lakhs.

(h) Section 129B will be amended to provide for extension ofstay order after expiry of 180 days and to limit the powerof extension of stay up to a total period of 365 days. Theprovisions further provide for automa c vaca on of the stayorder if the appeal is pending a er 365 days of the stay order.

(i) Clause (d) has been inserted in sec on 142(1) to provide forrecovery from a person from whom money is due or whoholds money for or on account of the defaulter. Thus recoveryprovisions have been introduced to recover the amountfrom person other than the defaulter. Any other person shall

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include banks, insurer, debtors, etc. The person to whom

no ce under sec on 142 is issued will be treated as defaulterif he fails to make payment of such amount.

(j) Sec on 147 has been amended to make agents of the owner,importer or exporter of any goods responsible for makingcorrect self-assessment.

(k) Sec on 135 is being amended to increase monetary limit ofcertain o ences from ` 30 lakh to ` 50 lakh.

(l) Sec on 144 is being amended to provide for non-payment ofduty on any sample of goods which is consumed or destroyedduring the course of tes ng or examina on.

(m) Sections 146 & 146A seeks to change the nomenclature ofcustoms house agents to customs brokers and to disqualifypersons who are convicted of an o ence under the FinanceAct, 1994 to act as an authorised representa ve.

IV) Amendment in levy of Export Duty

(a) The export duty on Bauxite (natural) not calcined or calcined,unprocessed Iimen e at rate of 10% and on upgraded Iimeniteat rate of 5% is levied vide notification 15/2013- Cus dated1-3-2013.

(b) Retrospec ve exemp on from levy of export duty is proposed

to be provided for export of flat rolled products of iron ornon-alloy steel, plated or coated with zinc w.e.f. 1 st March2011.

V) Amendment in Baggage Rules,1998

W.e.f. 1-3-2013, the duty free limits to bring jewellery withoutpayment of duty for an Indian passenger, who has been residingabroad for over one year and a person who is transferring hisresidence to India has been increased up to an aggregate value of

` 50,000/- in case of a gentleman passenger and ` 100,000/- in caseof a lady passenger.

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II. CENTRAL EXCISE & CENVAT CREDIT RULESA. Changes with immediate e ect (i.e. from 1-3-2013)

I. Increase and Decrease in duty

Sr. Product Old Rate New Rate No. upto w.e.f.

28-2-2013 1-3-2013

1 a. Mobiles handsets 1% 6% incl. cellular ofRetail Sales priceof more than

` 2,000/.

2 Silver produced or NIL 4% manufactured duringthe process of zinc orlead smel ng star ngfrom the stage of

zinc or lead ore orconcentrate.

3. Marble slabs and ` 30/ per ` 60/ perles sq. meter. sq. meter.

II. Exemp ons extended:

1. Exemption has been extended to readymade garments

and made ups falling under chapters 61, 62 ad 63 (exceptLaminated Jute Bags falling under 6305, 6309 00 00 and 6310) on condi on that no CENVAT is availed on inputs used in themanufacture of such goods. Exemp on is op onal and unithas an op on to avail the CENVAT credit and pay duty at theapplicable rates.

2. Excise duty on goods falling under chapters 61, 62 & 63 madefrom co on has been reduced 6% provided the said goods donot contain any other tex le material.

3. Full exemption from excise duty is being provided on handmade carpets and carpets and other tex le oor coverings ofcoir or jute, whether or not handmade.



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III. SERVICE TAX

1. PREAMBLE

1.1 The Finance Bill, 2013 (Bill) has proposed to make certain changesin Chapter V of the Finance Act, 1994 (Act), the law governingservice tax, which are effective on the enactment of the Bill.Signi cant changes include the imposi on of personal penal es ondirectors and o cials of a company for speci ed contraven ons and

introduc on of power to arrest. In addi on to the above, the CentralGovernment has also issued no ca ons making some changes inabatements and exemp ons. Some of the no ca ons are e ec vefrom 1-3-2013 and some from 1-4-2013. However, the e ec ve rateof service tax has been maintained at 12.36% (i.e. 12% service tax+ 2% educa on cess + 1% secondary and higher educa on cess).

2. CHANGES EFFECTIVE FROM 1-3-2013

2.1 Abatement in respect of construction of commercial/residentialcomplex services reduced from 75% to 70% except in case ofresidential units having 2000 sq. ft or less carpet area or whereamount charged is less than ` 1 crore.

2.1.1 Construc on of a complex, building, civil structure or part thereofintended for sale to a buyer wholly or partly, except where en reconsideration is received after the issuance of a completion

certificate by the competent authorities, is a declared service[Sec on 66E (b)].

2.1.2 The Central Government had in respect of such services provided anabatement of 75% of the gross amount charged for such servicesvide its notification no. 26/2012 ST dated 20-6-2012 subject toful lment of the following condi ons

(i) no credit in respect of duties paid on input goods used for

providing taxable service has been taken;(ii) the value of land has been included in the gross amount

charged/recovered from the buyer.

(iii) the gross amount charged shall include fair market valueof all goods and services that are supplied by the service



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recipient to the service provider for providing such service as

reduced by

(a) any amount that is charged by him to the serviceprovider towards such goods and services supplied byhim,

(b) any VAT or Sales tax levied.

2.1.3 The above abatement of 75% has now vide No ca on No. 2/2013

ST dated 1-3-2013 been reduced to 70% except in two cases whereit will con nue to be 75% viz.,

(i) Construc on of residen al unit having carpet area of 2000 sq. or less;

(ii) Construc on of residen al unit where gross amount chargedis less than ` 1 crore.

2.1.4 Thus the rate of tax in respect of construction services w. e. f.1-3-2013 would be as follows:

Sl. Construc on service in respect of E ec ve Rate of Tax No. (including cess)

1 Residen al units with carpet area 3.09% of 2000 sq. or less (irrespec ve (25% of 12.36%) of the value of considera on)

2 Residen al units where gross 3.09% amount charged is less than (25% of 12.36%)

` 1 crore (irrespec veof the area)

3 Complex, building, civil 3.708% structure or part thereof not (30% of 12.36%) covered under the above twocategories

2.2 Advance Ruling Mechanism extended to resident public limitedcompanies.

2.2.1 Chapter VA of the Finance Act, 1994 (sec ons 96A to 98) providesfor Advance Ruling mechanism in service tax. Under the existing



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provisions, the advance ruling can be obtained only in rela on to

services proposed to be provided by

(i) (a) a non-resident setting up a joint venture in India incollabora on with a non-resident/resident; or

(b) a resident setting up a joint venture in India incollabora on with a non-resident; or

(c) wholly owned Indian subsidiary company, of which the

holding company is a foreign company.

(ii) a joint venture in India wherein one or more participant /partner/equity holder having substantial interest in theventure is a non-resident.

(iii) any such class or category of residents no ed by the CentralGovernment.

2.2.2 Pursuant to the powers men oned in para 2.1(iii) above, the CentralGovernment has no ed public sector companies w.e.f. 20-8-2009.Now the Central Government has vide Notification No. 4/2013 ST dated 1-3-2013 notified resident public limited companies aseligible to avail the bene t of advance ruling. Resident Public LimitedCompany would mean

(i) a public company as per section 3(1)(iv) of the CompaniesAct, 1956 including a private company which is deemed tobe public company under sec on 43A of the Companies Act,1956; and

(ii) the said company is resident as per Income-tax Act, 1961i.e. it is an Indian company or a company whose control andmanagement of a airs is situated wholly in India.

3. CHANGES EFFECTIVE FROM 1-4-2013

3.1 Changes in Mega Exemp on No ca on

3.1.1. The Central Government had issued a Mega exemp on No ca onNo. 25/2012 ST dated 20-6-2012 last year conferring severalexemp ons. There are some changes to the exemp ons made videNo ca on No. 3/2013 dated 1-3-2013 as explained below.



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3.2 Exemp ons withdrawn

(i) Entry no. 9 : Exemption in respect of Auxiliary educationalservices and renting of immovable property servicesprovided by an educa onal ins tu on in respect of educa onexempted from service tax.

N.B: However such services provided to such educationalins tu on would con nue to be exempt.

(ii) Entry no. 20 : Transporta on by rail or vessel from one placein India to another of the following goods

(a) petroleum or petroleum products;

(b) postal mail or mail bags; and

(c) household e ects.

(iii) Entry no. 24 : Vehicle parking services to general public.

(iv) Entry no. 25 : Services provided to government, a localauthority or governmental authority by way of repair ormaintenance of an aircra .

(v) Clause 2(k)(v) r.w. entries 4 & 34 (b) of Clause 1 : Exemp onin respect of certain speci ed charitable ac vi es viz., en esregistered u/s. 12AA of the Income tax Act, 1961, that areadvancing an object of general public u lity up to ` 25 lakh

in a nancial year in respect of

(a) services provided by them; and

(b) services received from an overseas service provider.

N.B: Exemp on in respect of the charitable ac vi es men oned inClause 2(k)(i) to (iv) would con nue.

3.3 Exemp on curtailed(vi) Entry no. 15 : Exemp on to temporary transfer or permi ng

the use or enjoyment of copyright rela ng to cinematographiclms has been restricted only to cases where such transferor permission is for the purpose of exhibition of films in acinema hall/theatre. Thus, temporary transfer/permi ng the

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an issue arises whether the show cause no ce fails completely orsurvives at least to the extent of the normal period of limitation(presently 18 months for service tax). In Ahmedabad Manufacturing& Calico Printing Co. Ltd. vs. UOI ( 1993) 63 ELT 601 (SC); CCE vs.Hindustan Safety Glass Works Ltd. ( 1995) 77 ELT 40 (SC); and UoIvs. Maheshwari Woollen Mills (1998) 97 ELT 220 (SC), the HonbleSupreme Court held that the demands could be quashed only tothe extent of the extended period of limitation and not for thenormal period. However, in T.N. Dadha Pharmaceu cals v. Collectorof Central Excise (2003) 152 ELT 251 (SC), the entire notice wasquashed, i.e. notice even for the normal period was quashed. Toresolve this con ict, the Finance Act, 2011 had inserted sub-sec on(9) to Section 11A of Central Excise Act, 1944 w.e .f. 8.4.2011 toprovide that if a show cause notice is issued invoking extendedperiod of limitation and the appellate authority, tribunal or courtfound that the extended period is not applicable due to lack of intentto evade etc., the Central Excise O cer shall determine the duty/taxpayable for the normal period as if the show cause no ce was issuedfor the normal period of limita on. Thus the demand for the normalperiod would survive. The Bill now proposes to insert a similarprovision in the service tax law by providing a new sub-sec on (2A)in sec on 73 of the Act on the lines of the excise law.

4.3 Appeals to Tribunal Condona on of delay in case of appeals byassessee

4.3.1 The power of the Tribunal to condone delays in ling an appeal by anassessee appears to have been inadvertently deleted by the FinanceAct, 2012 when the me limit for ling an appeal before the Tribunalby the department u/s. 86 against the order of the CCE or CCE(A),was increased from 3 months to 4 months. The Bill seeks to restorethe power.

4.4 Penalty for failure to register restricted to ` 10,000/- [Sec on 77]

4.4.1. Presently, the penalty for failure to register within due date is thehigher of

(i) ` 10,000/- or

(ii) ` 200 per day during which the default con nues.

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The Bill has now proposed to restrict the maximum amount of

penalty for the above failure to ` 10,000/-.

4.5 Financial penalty on directors, managers, secretary or othero cers in charge of the company for certain contraven ons by thecompany.

4.5.1. The Finance Act, 2011 w.e.f. 8.4.2011 had made Sec on 9AA of theCentral Excise Act applicable to service tax. This provision providesthat if an o ence is commi ed by a company (which includes a rm),the persons liable to be proceeded against and punished are:

(a) the company;

(b) every person, who at the time the offence was committed,was in charge of, and was responsible to, the company forthe conduct of the business except where he proves that theo ence was commi ed without his knowledge or that he hadexercised all due diligence to prevent the commission of sucho ence; and

(c) any director (who in relation to a firm means a partner),manager, secretary or other officer of the company withwhose consent or connivance or because of neglecta ributable to whom the o ence has been commi ed.

4.5.2. The Bill has now proposed to introduce a new section 78A (inaddition to the above) for imposing a financial penalty upto

` 1,00,000/- on directors, managers, secretary or other officersincharge of the company for speci ed contraven ons commi ed bya company namely :

(a) evasion of service tax; or

(b) issuance of invoice, bill or challan without provision of taxableservices contravening the provisions of the Act or the Rulesmade thereunder 2;

(c) availment and u lisa on of credit of taxes/duty without actualreceipt of taxable service or excisable goods either fully orpar ally in viola on of the Act or Credit Rules;

2. Thus issuing invoice for monies received in advance towards taxable serviceto be provided would not be a contraven on.

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(d) failure to pay to the Government any amount collected as

service tax beyond a period of six months from the date onwhich such payment became due.

The aforesaid persons would be liable if

(i) at the me of such contraven on they were in charge of, andresponsible to, the company for the conduct of business; and

(ii) they were knowingly concerned with such contraven on.

4.5.3. In this regard, it may be noted that for the contraven ons men onedin (a), (c), and (d) of para 4.5.2, such persons may also be prosecutedin addi on to su ering a nancial penalty under the above proposedsec on [sec on 89 of the Act r.w. s. 9AA of the Central Excise Act]

4.5.4. Further, in absence of a corresponding amendment in s. 80 of theAct, the defence of reasonable cause u/s. 80 would not be availableto the imposi on of penalty under the above proposed sec on.

4.6 Failure to pay tax collected beyond 6 months maximumimprisonment increased from 3 years to 7 years.

4.6.1. Presently, failure to pay to the Government any amount collected asservice tax beyond a period of six months from the date on whichsuch payment became due is a punishable o ence. The quantum ofpunishment for this o ence is proposed to be increased as follows:

Sl. O ence Present Proposed No. Punishment Punishment by way

by way of of imprisonment imprisonment

1. For amounts up to Up to 1 year Up to 1 year ` 50 lakh

2. Where amount From 6 months From 6 months exceeds up to 3 years up to 7 years

` 50 lakh

3. Second and From 6 months Upto 7 yearssubsequent up to 3 years o ence

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5. RETROSPECTIVE EXEMPTION

(E ec ve on enactment of the Bill)5.1 Retrospec ve exemp on is being extended to the Indian Railways on

the service tax leviable on various taxable services provided by themduring the period prior to the 1st day of July 2012, to the extentshow cause no ces have been issued upto the 28th day of February2013.

6. SERVICE TAX VOLUNTARY COMPLIANCEENCOURAGEMENT SCHEME, 2013(E ec ve on enactment of the Bill)

6.1. Introduc on

6.1.1. In order to encourage voluntary compliance, the Central Governmenthas proposed to introduce a one me amnesty scheme called theService tax Voluntary Compliance Encouragement Scheme, 2013.Under the scheme any person can declare their past tax dues and

pay the same in the manner prescribed whereupon such personwould be eligible for certain immuni es including penalty, interestetc. This scheme will be operational from the date on which theFinance Bill, 2013 receives the assent of the President. The salientfeatures of this scheme are explained below.

6.2. Tax dues eligible for declara on

6.2.1. The tax dues which a person is en tled to declare under the scheme

are :(i) Any service tax (including cess) due and payable;

(ii) Any service tax collected from the service recipient in excessof what is due and paid to the Government;

(iii) Amount collected as service tax from any person (though notrequired to be collected) for the period 1 st October, 2007 to31 st December, 2012 and which is remaining unpaid as on1 st March, 2013.

6.2.2. Tax dues would exclude

(i) Tax dues in respect of which a show cause no ce or an orderis issued or made before 1-3-2013 u/ss. 72, 73 or 73A of theAct.

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(ii) Tax dues pertaining to issues for a period where a show

cause no ce or order has been issued for a previous period.

(iii) Tax dues disclosed in the return but not paid.

6.3. Procedure

6.3.1. Assessee has to make a declaration in a prescribed form on orbefore 31 st December, 2013 to the designated authority (a personto be notified by the Commissioner) who shall acknowledge the

declara on.6.3.2. The declarant has to pay not less than 50% of his declared tax

dues on or before 31 st December, 2013. The balance tax dues areto be paid on or before 30 th June, 2014. If the declarant fails to paythe balance dues by 30 th June, 2014 he will have to pay the samealong with interest (computed from 1 st July, 2014) on or before31 st December, 2014.

6.3.3. On payment of the declared tax dues, the declarant has to furnishthe details of payment along with the acknowledged copy of thedeclara on to the designated authority wherea er the designatedauthority shall issue an acknowledgement of discharge of such taxdues to the declarant in the prescribed form.

6.4. Immunity

6.4.1. The declarant to whom the designated authority has issued an

acknowledgement of discharge of such tax dues shall get immunityfrom penalty, interest or any proceedings under the Act.

6.5. Powers of the department to reject the declara on or to ques onthe declara on

6.5.1. Where a declaration is made by the assessee against whom anyinquiry or investigation has been initiated (by way of search,summons, requisition of documents, etc.) or an audit has been

initiated and is pending as on 1st

March, 2013, the designatedauthority shall by an order, for reasons recorded in wri ng, rejectthe declara on.

6.5.2. Where the Commissioner of Central Excise has reasons to believethat the declara on made by the assessee was substan ally false, hemay serve a no ce on the declarant in respect of such declara on

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requiring him to show cause as to why he should not pay the tax

dues not paid/short paid. However, no such no ce can be issuedafter the expiry of 1 year from the date of filing the declaration.The no ces men oned above shall be governed by the provisions ofsec ons 73/73A of the Act.

6.6. Consequences

6.6.1. The matters that are concluded under this scheme shall not bereopened by any authority or court.

6.6.2. The tax dues paid in pursuance of the declaration are notrefundable and if the assessee fails to pay any declared tax dues, thesame shall be recovered u/s. 87 of the Act.

7. CONCLUSION

This year the Bill has introduced the Jail The assessees in anguish shall Wail

Being caught by Tigers Tail The only hope is the Bail!

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Budget 2013 Wirc

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Transcript of Budget 2013 Wirc