Thursday, 13 November 2014

Major Amendment in Budget 2014 - Direct Taxes

Major Amendment in Budget 2014 - Direct Taxes

CPE Date : 15th November 2014
-          Complied by CA Pawankumar Soni
-          FCA , DISA(ICAI),B.Com


Ø Change of Income Tax Slab:
o   Income tax slab was increased from Rs. 2Lakh to Rs. 2.5Lakhs for individuals.
o   For Senior Citizens increased from Rs. 2.5Lakhs to Rs. 3Lakhs

Ø Increase of limit U/s. 80C
o   Now you can save extra Rs. 50,000 and get tax relief.
o   Now you have to increase your savings/other instruments to get this benefit.
o   Note : Corresponding changes in Increase of PPF Limit is also increased from Rs. 1 Lac to 1.5 Lac (Notification No. GSR 588(E) DT 13/8/2014)

Ø Increase in Interest on Housing Loan limit
o   Interest on housing loan increased from Rs. 1.5 Lakhs to Rs. 2 Lakhs

Ø Capital Gains Tax changes
o   Changes in brief: Budget changed taxation related to non-equity mutual funds like FMPs, Debt Funds, Liquid Funds
o   Need to hold 3 years to become long-term (instead of 1year)
o   Taxed @ 20% (Earlier minimum of 10% without indexation & 20% with indexation)
o   Impact: Now, return from these FMP/Funds will be included in your income if holding period is below 3years. Also it will have retrospective effect on your fixed instrument holdings. For example if you have purchased 1year-FMP in Mar-2014 of Rs. 10,000. The return would be included in your income & taxed based on the present slab. Means it may be taxed at 30%(plus SC+Cess)!!!…if you are in 30% slab.
o   With these changes – you need to rethink of investing in Liquid/Debt Funds & FMP of 1 year vis-à-vis Bank Fixed Deposits.




Ø Forfeited Advance
o   Forfeited advance is now taxable under Other Income instead of adjusting in capital gains.


Let us discuss few of the Amendment in Details
Parities & Anomalies Brought Between Section 40(a)(i) & Section 40(a)(ia) by
Finance Bill has tried to bring parity regarding the above issue by making both the dates specified same as due date of return filling of deductor as per section 139(1). The amendment to section 40(a)(i) has been discussed below in detail .
Here I am quoting the law and the amendment made hereunder.
As per Section40(a)(i) of Income Tax Act 1961, expenses mentioned here under will be disallowed if
“ any interest, royalty, fees for technical services or any other sum chargeable under act , which is payable,
(A)   Outside India or
(B)   In India to a Non Resident, or to a foreign company ,
on which tax is deductible at source under chapter XVIIB, and such tax has not been deducted or, after deduction has not been paid during the previous year, or on or before the due date specified as per section 200(1) or on or before the due date as per section 139(1).
Provided that where in respect of any sum, tax has deducted in any subsequent year or, has been deducted in the previous year but paid after the due date specified as per section 200(1) after the due date specified in section 139(1) , such sum shall be allowed as deduction in computing the income of the previous year in which such tax has been paid.”

Words in Bold are substituted by finance Bill 2014.

Meaning thereby disallowance under Section 40(a)(i) of Income Tax Act 1961 will be attracted
(i)    if the amount paid or payable is interest, royalty ,fees for technical services or any other sum chargeable under the income tax act and
(ii)  Aforesaid sum is paid/payable Outside India to a Non resident or a foreign company or  In India to a Non resident or a foreign company and
(iii) Sum is taxable in the hands of the recipient under the income tax and Tax is deductible at source (TDS) under chapter XVIIB
(iv)  And any of the following default takes place,
Default A : Tax at source has not been deducted or,
Default B: Tax at source has been deducted but has not been paid during the previous year, or       paid after the due date specified in section 139(1).
In case any of the two aforesaid defaults take place, then the payer is not allowed deduction(100%) of such sum paid or payable in that previous year for such previous year.
However one proviso (exception) to above case is where
(i)  Tax has been deducted in the subsequent year of credit or payment or,
(ii)  Tax has been deducted in the previous year but paid in any subsequent year after the time prescribed under section 139(1).
Then such sum will be allowed as deduction in the year in which such tax has been paid.
Here earlier there was an anomaly between section 40 (a)(i) and section 40 (a)(ia) [ discussed later in this article]. Government has tried to bring parity between the two by bringing amendment to the law by Finance Bill 2014.
Lets understand the amendment with help of an example, ABC Ltd. [due date of filling of income tax return is 30th September as per section 139(1)] has to make a payment of Rs 5,00,000 to MR.B as fees for technical services availed in July 2015, MR.A has deducted tax at source on the aforesaid sum but has not deposited due to any reason it with government till 30th September 2016. Prior to the amendment for claiming such payment as expense in the P/Y 15-16 MR. A has to deposit TDS with the government till 30th april 2016(i.e. for any payment credited or paid in any previous year , TDS must be deposited till 30th April of subsequent year following that previous year). But as per amendment such time limit has been extended till due date of filling of return as per section 139(1) of the deductor i.e. ABC Ltd.
Consequently , as per amendment ABC Ltd. can not claim such payment as expense for the previous year 2015-16(500000 is disallowed 100%) . He can claim such sum as expense in the year in which TDS is deposited by him with the government.




However one major difference has been introduced between the two sections by the Finance Bill 2014 . Prior to amendment, in case of default under section 40(a)(ia) [ discussed below] takes place then any sum paid under the aforesaid section is disallowed (100%) in the previous year in which such same is paid or credited in books.As per the Finance bill 2014, the disallowance in case of default is changed from 100% to 30%. Now in case of aforesaid default only 30% of such sum is disallowed and 70% will be given as deduction for the previous year in which such sum is paid or credited. The 30% of such sum will be allowed in the year of payment of TDS. Whereas in case of default under section 40(a)(i) the disallowance is 100% itself.
The amendment is discussed below in detail .
As per Section40(a)(ia) of Income Tax Act 1961, expenses mentioned here under will be disallowed if
“ any interest ,commission or brokerage, rent, royalty, fees for technical services , payable to a RESIDENT, or amounts payable to a contractor or sub- contractor being Resident for carrying out any work (including supply of labour for carrying out any work) or any salary payable under section 192 , on which tax is deductible at source under chapter XVIIB, and such tax has not been deducted or, after deduction has not been paid on or before the due date specified in section 139(1) , thirty percent of any sum payable to a resident.
Provided that where in respect of any sum, tax has deducted in any subsequent year or, has been deducted during the previous year but has been paid after the due date specified in section 139(1) , thirty percent of such sum shall be allowed as deduction in computing the income of the previous year in which such tax has been paid.
Provided further that where an assessee fails to deduct the whole or any part of the tax in accordance with the provisions of chapter XVII-B on any such sum is not deemed to be an assessee in default under the first proviso to section 201(1), then for the purpose of this sub clause , it shall be deemed that assessee has deducted and paid the tax on such sum on the date of furnishing of return of income by the resident payee referred to in the said proviso.”
Words in Bold are inserted by finance Bill 2014.



Meaning hereby disallowance will be attracted under section 40 (a)(ia) if the amount payable isany interest, commission or brokerage, rent, royalty, fees for technical services , payable to a RESIDENT, or amounts payable to a contractor or sub- contractor being resident for carrying out any work  ( including supply of labour for carrying out any work) , on which tax is deductible at source under chapter XVIIB, and tax is not deducted or deducted but not paid to the credit of central government before the due date as per section 139(1) i.e. is the due date of filling of income tax return .
However, again there is an anomaly between the two sections and i.e. in case resident payee ( who has earned the income) has taken such sum for computing income in the return of income(ROI) under section 139 and resident payee has paid tax due on income declared by him in ROI, then the payer(who has to make payment) is not deemed to be defaulted under section 40(a)(ia).
Also salary payable to resident employees were not covered earlier by the said section which now stand covered under the same and all provisions of this section will apply same to salary also as to other nature of payment .
Lets understand this with the help of an example, say, A Ltd. Whose date of filling of return is 30th September pays the following sums without deduction of TDS, Rs. 200000 to MR.B , a resident, as rent(due date of filling of return for MR.B is 31st July) and Rs. 500000 to XYZ LTD , a resident company, as professional fees( due date of filling of return for XYZ LTD is 30th September). The above sum were paid on 1st july, 2015 without deduction of tax. Also MR.B & XYZ LTD has not added such income in their return of income.as per law tax has to be deducted and paid till 30th September i.e. due date of filling of return of A LTD for availing such payment as expense in P/Y 2015-16. Now as per amendment to Finance Bill 2014, 210000 {30% of (200000+500000)} will be disallowed in the previous year 2015-16 and 490000 (700000-210000) will be allowed as expense previous year 2015-16. However had this payment is made to NON RESIDENT under section 40(a)(i) and TDS is not deposited by due date then 100% of amount Rs.700000 would have been disallowed.




Levy of penalty U/s. 276D mandatory for willful default U/s. 142(1) or 142(2A
Failure to produce accounts and documents Levy of penalty made mandatory. It is proposed to remove the monetary limit of fine and also proposed mandatory levy of fine. The existing provisions of section 276D of the Act provide that if a person willfully fails to produce accounts and documents as required in any notice issued under sub-section (1) of section 142 or willfully fails to comply with a direction issued to him under sub-section (2A) of section 142, he shall be punishable with rigorous imprisonment for a term which may extend to one year or with fine equal to a sum calculated at a rate which shall not be less than four rupees or more than ten rupees for every day during which the default continues, or with both.
It is proposed to amend the provisions of the said section so as to provide that if a person willfully fails to produce accounts and documents as required in any notice issued under sub-section (1) of section 142 or willfully fails to comply with a direction issued to him under sub-section (2A) of section 142, he shall be punishable with rigorous imprisonment for a term which may extend to one year and with fine.
Mode of acceptance or repayment of loans and deposits ECS, RTGS and NEFT etc. are now proposed to be allowed as permissible mode to accept or repay the deposit or loan specified under section 269SS and 269T respectively. -

Levy interest U/s. 220 from the date of expiry of period stated in the notice of demand U/s. 156 -
The existing provision contained in sub-section (1) of section 220 provides that any amount specified as payable in a notice of demand under section 156 shall be paid within thirty days of the service of notice at the place and to the person mentioned in the notice. Sub-section (2) states that if the amount specified in the notice is not paid within the period, the assessee shall be liable to pay simple interest at one per cent for every month or part of a month comprised in the period commencing from the day immediately following the end of the period mentioned in sub-section (1) and ending with the day on which the amount is paid. The proviso to sub-section (2) states that where as a result of an order under sections 154, 155, 250, 254, 260, 262, 264 or sub-section (4) of section 245D, the amount on which interest payable under this section had been reduced, the interest shall be reduced accordingly and the excess interest paid, if any, shall be refunded.
Liability of the assessee to pay interest is based on the theory of continuity of the proceedings and the doctrine of relation back. Accordingly, it is proposed to insert a new sub-section in section 220 so as to provide that where any notice of demand has been served upon an assessee and any appeal or other proceeding, as the case may be, is filed or initiated in respect of the amount specified in the said notice of demand, then such demand shall be deemed to be valid till the disposal of appeal by the last appellate authority or disposal of proceedings, as the case may be and such notice of demand shall have effect as provided in section 3 of the Taxation Laws (Continuation and Validation of Recovery Proceedings) Act, 1964.
It is further proposed to provide that where as a result of an order under sections specified in the first proviso, the amount on which interest was payable under this section had been reduced and subsequently as a result of an order under said sections or section 263, the amount on which interest was payable under section 220 is increased, the assessee shall be liable to pay interest under sub-section (2) of the said section on the amount payable as a result of such order, from the day immediately following the end of the period mentioned in the first notice of demand referred to in sub section (1) of the said section and ending with the day on which the amount is paid.

Grants Power of Survey for verification of TDS defaults -
Presumptive income amount increased to Rs. 7500 for Business of Plying, Hiring or Leasing Goods Carriages -
The existing provisions of section 44AE of the Act provides for presumptive taxation in the case of an assessee who is engaged in the business of plying, hiring or leasing goods carriages and not owning more than ten goods carriages at any time during the previous year. Income from the said business is calculated as under:
Type of Goods carriage
Amount of presumptive income
Heavy goods vehicle (HGV)
Rs.5,000 for every month (or part of a month) during which the goods carriage is owned by the taxpayer.
Vehicle other than HGV
Rs. 4,500 for every month (or part of a month) during which the goods carriage is owned by the taxpayer.
The amount of presumptive income was revised by the Finance (No.2) Act, 2009. Further, the existing provisions make a distinction between HGV and vehicle other than HGV for specifying the amount of presumptive income.
Considering the erosion in the real values of the amount of specified presumptive income due to inflation over the years and also in order to simplify this presumptive taxation scheme, it is proposed to provide for a uniform amount of presumptive income of Rs.7,500 for every month (or part of a month) for all types of goods carriage without any distinction between HGV and vehicle other than HGV.

Budget 2014 – Capital gains arising from transfer of an asset by way of compulsory acquisition - :
The existing provisions contained in section 45 provide for charging of any profits or gains arising from transfer of a capital asset. Sub-section (5) of the said section provides for dealing with capital gains arising from transfer by way of compulsory acquisition where the compensation is enhanced or further enhanced by the court, Tribunal or any other authority. Clause (b) of the said sub-section provides that where the amount of compensation is enhanced or further enhanced by the court it shall be deemed to be the income chargeable of the previous year in which such amount is received by the assessee. There is uncertainty about the year in which the amount of compensation received in pursuance of an interim order of the court is to be charged to tax, due to court orders. Accordingly, it is proposed to provide that the amount of compensation received in pursuance of an interim order of the court, Tribunal or other authority shall be deemed to be income chargeable under the head ‘Capital gains’ in the previous year in which the final order of such court, Tribunal or other authority is made. –

Trading in derivative by Company mainly engaged in Trading of Shares will be treated as Speculative -
Losses in Speculation Business The existing provisions of section 73 of the Act provide that losses incurred in respect of a speculation business cannot be set off or carried forward and set off except against the profits of any other speculation business. Explanation to section 73 provides that in case of a company deriving its income mainly under the head “Profits and gains of business or profession” (other than a company whose principal business is business of banking or granting of loans and advances), and where any part of its business consists of purchase or sale of shares, such business shall be deemed to be speculation business for the purpose of this section.
Sub-section (5) of section 43 defines the term speculative transaction as a transaction in which a contract for purchase or sale of any commodity, including stocks and shares, is settled otherwise than by way of actual delivery. However, the proviso to the said section exempts, inter alia, transaction in respect of trading in derivatives on a recognized stock exchange from its ambit.
It is proposed to amend the aforesaid Explanation so as to provide that the provision of the Explanation shall also not be applicable to a company the principal business of which is the business of trading in shares.

Exemption U/s. 54EC cannot exceed Rs. 50 Lakh despite investment in two Years -
Capital gains exemption on investment in Specified Bonds The existing provisions contained in sub-section (1) of section 54EC of the Act provide that where capital gain arises from the transfer of a long-term capital asset and the assessee has, within a period of six months, invested the whole or part of capital gains in the long-term specified asset, the proportionate capital gains so invested in the long-term specified asset, out of the whole of the capital gain, shall not be charged to tax. The proviso to the said sub-section provides that the investment made in the long-term specified asset during any financial year shall not exceed fifty lakh rupees. However, the wordings of the proviso have created an ambiguity. As a result the capital gains arising during the year after the month of September were invested in the specified asset in such a manner so as to split the investment in two years i.e., one within the year and second in the next year but before the expiry of six months. This resulted in the claim for relief of one crore rupees as against the intended limit for relief of fifty lakh rupees. Accordingly, it is proposed to insert a proviso in sub-section (1) so as to provide that the investment made by an assessee in the long-term specified asset, out of capital gains arising from transfer of one or more original asset, during the financial year in which the original asset or assets are transferred and in the subsequent financial year does not exceed fifty lakh rupees.
Benefit U/s. 54 / 54F available only if investment is made in one residential house situated in India –
Capital gains exemption in case of investment in a residential house property The existing provisions contained in sub-section (1) of section 54, inter alia, provide that where capital gain arises from the transfer of a long-term capital asset, being buildings or lands appurtenant thereto, and being a residential house, and the assessee within a period of one year before or two years after the date of transfer, purchases, or within a period of three years after the date of transfer constructs, a residential house then the amount of capital gains to the extent invested in the new residential house is not chargeable to tax under section 45 of the Act. The existing provisions contained in sub-section (1) of section 54F, inter alia, provide that where capital gains arises from transfer of a long-term capital asset, not being a residential house, and the assessee within a period of one year before or two years after the date of transfer, purchases, or within a period of three years after the date of transfer constructs, a residential house then the portion of capital gains in the ratio of cost of new asset to the net consideration received on transfer is not chargeable to tax. The benefit was intended for investment in one residential house within India. Accordingly, it is proposed to amend the aforesaid sub-section (1) of section 54 so as to provide that the rollover relief under the said section is available if the investment is made in one residential house situated in India. It is further proposed to amend the aforesaid sub-section (1) of section 54F so as to provide that the exemption is available if the investment is made in one residential house situated in India.

Loophole allowing Double deduction to Charitable Trust Related to Capital Assets and Depreciation plugged –
Existing scheme of section 11 as well as section 10(23C) provides exemption in respect of income when it is applied to acquire a capital asset. Subsequently, while computing the income for purposes of these sections, notional deduction by way of depreciation etc. is claimed and such amount of notional deduction remains to be applied for charitable purpose. Therefore, double benefit is claimed by the trusts and institutions under the existing law. The provisions need to be rationalised to ensure that double benefit is not claimed and such notional amount does not get excluded from the condition of application of income for charitable purpose. In view of the above, it is also proposed to amend the Act to provide that under section 11 and section 10(23C), income for the purposes of application shall be determined without any deduction or allowance by way of depreciation or otherwise in respect of any asset, acquisition of which has been claimed as an application of income under these sections in the same or any other previous year -        
TDS on non-exempt payments made under life insurance policy -
Under the existing provisions of section 10(10D) of the Act, any sum received under a life insurance policy, including the sum allocated by way of bonus on such policy is exempt subject to fulfillment of conditions specified under the said section. Therefore, the sum received under a life insurance policy which does not fulfill the conditions specified under section 10(10D) are taxable under the provisions of the Act. In order to have a mechanism for reporting of transactions and collection of tax in respect of sum paid under life insurance policies which are not exempted under section 10(10D) of the Act, it is proposed to insert a new section in the Act to provide for deduction of tax at the rate of 2 per cent. on sum paid under a life insurance policy, including the sum allocated by way of bonus, which are not exempt under section 10(10D) of the Act. In order to reduce the compliance burden on the small tax payers, it has also been proposed that no deduction under this provision shall be made if the aggregate sum paid in a financial year to an assessee is less than Rs.1,00,000/-.

Summary on Changes of Tax Deduction at Source (TDS)
·         To claim the expenditure, TDS on payment made to non-residents can be deposited before filing of return [Sec 40(a)(i)]
·          In case of non-deduction or non-payment of TDS from certain payments made to residents, only 30% of the expenditure shall be disallowed. [Sec 40(a)(ia)]
·         Disallowance u/s 40(a)(ia) shall extend to all payments on which tax is deductible
·         Time limit for 2 years to treat payer as assessee in default has been dispensed with.
·         Time limit of 6 years for TDS Statements not filed, extended to 7 years.
An income tax authority may for the purpose of checking of compliance of TDS may survey any premises and enquire about books of accounts etc u/s 133A

Other amendments
·         Corporate Social Responsibility (CSR) expenditure not allowed as deduction u/s 37
·         Transfer of Government Security (carrying a periodic payment of interest) by one non-resident to other non-resident shall be exempt from capital gains tax.
·         Transaction in respect of trading in Commodity derivatives carried out in recognized association and chargeable to CTT is not speculative transaction.
·         New Section 133C inserted to empower the prescribed income tax authority to issue notice to person, whose information is in possession of such authority, requiring him to furnish information or documents.
·         Sec 285BA includes more transactions and reportable accounts to be furnished by specified persons to the income tax authority.
·         Assessment of income of a person other than the searched person u/s 153C only if the Assessing officer of such other person is satisfied that books etc seized or requisitioned have a bearing on the determination of the total income of such other person.
·         Credit of Alternate Minimum Tax u/s 115C shall be allowed.




Thank you for your Patience Hearing

No comments:

Post a Comment