Direct Tax Chapter

Tax Rates under New Tax Regime

Individuals and HUF

Net income range	Income tax rates	Surcharge	Health and Education Cess
Up to 2,50,000	Nil	Nil	Nil
Rs. 2,50,000-Rs. 5,00,000	5% of (total income minus Rs.2,50,000	Nil	4% of income -tax
Rs. 5,00,000-Rs. 7,50,000	Rs. 12,500+10% of (total income minus 5,00,000	Nil	4% of income-tax
Rs. 7,50,000-Rs. 10,00,000	Rs. 37,500+15% of (total income minus Rs. 7,50,000	Nil	4% of income-tax and surcharge
Rs. 10,00,000 – Rs 12,50,000	Rs. 75,000+20% of total income minus Rs 10,00,000	Nil	4% of income-tax and surcharge
Rs 12,50,000 – Rs 15,00,000	Rs. 1,25,000+25% of total income minus Rs 12,50,000	Nil	4% of income-tax and surcharge
R s 1 5 , 0 0 , 0 0 0 – R s 1,00,00,000	Rs. 1,87,500+30% of total income minus Rs 15,00,000	10%	4% of income-tax and surcharge
R s . 1 , 0 0 , 0 0 , 0 0 0 – R s 2,00,00,000	Rs. 27,37,500+30% of total income minus Rs 1,00,00,000	15%	4% of income-tax and surcharge
R s 2 0 0 , 0 0 , 0 0 0 – R s 500,00,000	Rs. 57,37,500+30% of total income minus Rs 2,00,00,000	25%	4% of income-tax and surcharge
Rs 500,00,000 – above	Rs. 1,47,37,500+30% of total income minus Rs 5,00,00,000	37%	4% of income-tax and surcharge

1.  New provisions are inserted for tax rates in respect of individual or HUF (section 115BAC of the Act)

• The taxpayer is provided an option to choose before the due date of filing of income tax return, from the newly inserted slab provisions or Tax Slabs under old regime as for the previous year which continue with the exemption model. The tax exemption can be exercised from AY 2021-22.
• Where the income includes income from business, the option once exercised cannot be withdrawn unless the business ceases to exist. Whereas in other cases i.e. income not including business income, the option is exercisable annually.
• Rebate under section 87A- a resident individual including senior citizen (whose net income does not exceed Rs. 500,000) continues. It is deductible from income-tax before calculating education cess. The amount of rebate is 100 per cent of income-tax or Rs. 12,500, whichever is less.
• Maximum surcharge where total income includes income under section 111A, 112A or 115AD is restricted to 15%.
• No AMT will be chargeable where this provision is opted.
• The different tax rates for senior citizen or super senior citizen are not applicable under new tax regime.
• The following exemption cannot be claimed under new regime

Section	Type of Exemption
10(5)	Leave Travel Concession
10(13A)	House Rent Allowance
10(14)	Any Special allowance incurred for the purpose of business
10(17)	Allowances to MPs/MLAs
10(32)	Minor Child Income Inclusion
10(AA)	Exemption for SEZ unit contained
16	Standard deduction, deduction for entertainment allowance and employment/ professional tax
24	Interest under section 24 in respect of self-occupied or vacant property referred to in sub-section (2) of section 23.
32(1)(iia)	Additional deprecation
32AD	Deductions under Investment in New Plant & Machinery in notified backward areas.
33AB	Deductions under Tea development a/c, coffee development a/c & rubber development a/c
33ABA	Deductions under Site restoration funds.
35 (2AA)	Various deduction for donation for or expenditure on scientific research contained in sub-clause (ii) or sub-clause (iia) or sub-clause (iii) of sub-section (1) or sub-section (2AA) of section 35
35AD	Deduction in respect of expenditure on specified businesses.
35 CCC	Deduction on expenditure on agricultural extension project.
57(iia)	Deduction from family pension
Chapter VIA	Any deduction under chapter VIA (like section 80C, 80CCC, 80CCD, 80D, 80DD, 80DDB, 80E, 80EE, 80EEA, 80EEB, 80G, 80GG, 80GGA, 80GGC, 80IA, 80-IAB, 80- IAC, 80-IB, 80-IBA, etc).

Firms

 

• However, deduction under sub-section (2) of section 80CCD (employer contribution on account of employee in notified pension scheme) and section 80JJAA (for new employment) can be claimed.
• Conveyance Allowance and daily allowance during the performance of duty will be available

1. A firm is taxable at the rate of 30 percent for the assessment year 2021-22. Surcharge is 12 per cent of income- tax if net income exceeds Rs 1 crore. Health and Education Cess – 4% of income tax inclusive of surcharge.
2. Alternate minimum tax- Tax payable by firm cannot be less than 18.5 per cent [+SC + (EC+SHEC) or HEC] of “adjusted total income” as per section 115JC.

Corporates

Company	AY 2021-22
Where total turnover or gross receipts of the FY 2018-19 does not exceed Rs 400 crore rupees	25%
Company undertaking manufacturing activity post 1 October 2019 under section 115BAA (subject to conditions)	15%
Company undertaking power generation	15%
Other domestic company under section 115BAB (subject to conditions)	22%
Other than domestic company	40%

1. Corporate Tax Rate

(i) Health and Education Cess continues at 4% on both domestic as well as foreign company.

 

Cooperative society

5.

To extend the reduced tax rates to corporates of 15% or 22%, it is proposed to insert a new provision under section 115BAD to provide a co-operative society resident in India an option to pay tax at 22% for assessment

year 2021-22 onwards.

6.

The other conditions as provided under section 115BAA and section 115BAB will apply to cooperative society

as well.

7.

The surcharge of 10% will be applicable over and above the tax rate.

8.

The alternate minimum tax (“AMT”) payable under 115JC and credit of carry forward AMT under section 115JD will also not apply, if the provisions of 115BAD are opted. If it is not opted by the Cooperative society, the tax

rate of 30% with AMT payable @ 18.5% continue to apply.

Company	If net income does not exceed Rs.1 Crore	If net income is in the range of Rs.1 Crore – Rs 10 crore	If net income exceeds Rs.10 Crore
Domestic Company other than 115BAA or section 115BAB	–	7%*	12%**
Domestic Company opting for lower rate of 15% or 22%	10%
Foreign Company	–	2%*	5%**

1. No change in surcharge rate for corporates

In other cases (including sections 92CE(2) (primary adjustment under transfer pricing), 115-O (dividend distributed), 115QA (buy-back of shares), 115R (distributed income to unit holders), 115TA (distributed income to investors) or 115TD (tax on accreted income of trusts and institutions)), the surcharge shall be levied at the rate of twelve per cent.

*Marginal relief – In the case of a company having a net income of exceed Rs. 1 crore, the amount payable as income-tax and surcharge shall not exceed the total amount payable as income-tax on total income of Rs. 1 crore by more than the amount of income that exceeds Rs. 1 crore.

**Marginal relief – In the case of a company having a net income of exceeding Rs. 10 crore, the amount payable as income-tax and surcharge shall not exceed the total amount payable as income-tax and surcharge on total income of Rs. 10 crore by more than the amount of income that exceed Rs. 10 crore.

1. Minimum Alternate Tax

	If book profit does not exceed Rs. 1 crore				If book is in the range of Rs. 1 crore – Rs. 10 crore				If book profit exceed Rs. 10 crore
	IT	SC	HEC	Total	IT	SC	HEC	Total	IT	SC	HEC	Total
Domestic company	18.5	–	0.74	19.24	18.5	1.295	0.7918	20.5868	18.5	2.22	0.8288	21.5488
Foreign company	18.5	–	0.74	19.24	18.5	0.37	0.7548	19.6248	18.5	0.925	0.777	20.202

New Provisions Other than TDS

Expense in relation to Dividend Income

 

1. Currently, clause (i) of section 57 of the Act provides that in respect of income from dividends other than dividend under section 115O or interest on securities, commission paid or remuneration to banker or any other person for releasing of dividend can be claimed as an expense.

However, from AY 2021-22 it is proposed to amend section that in respect of dividend income only interest expense upto 20% of the dividend will be allowed including the interest received from domestic company.

Reinstatement of section 80M

1. Section 80M as it existed before its removal by the Finance Act, 2003 to remove the cascading effect on dividend distributed is reintroduced from AY 2020-21. It provides that where the gross total income of an assessee, being a domestic company, includes any income by way of dividends from a domestic company, a deduction will be available for the dividend received by any other domestic company.
2. The deduction of the dividend received by the other company shall be restricted to the extent of the dividend

distributed by the domestic company. Further the domestic company claiming such set off shall only be restricted to dividend so received one month prior to the date of filing of return by the recipient domestic company.

1. The deduction under section 80M shall also be available to the companies opting for the lower tax rate i.e. under section 115BAA @ 15% and section 115BAB @ 22%.

Dividend Distribution Tax Withdrawn

1. Currently, as per the provisions of section 115O, any amount declared, distributed or paid by a domestic company by way of dividend shall be charged to additional tax. It is applicable whether the dividend is interim or otherwise. Further, the company (or the shareholders) cannot claim any deduction from taxable income in respect of dividend tax levied under section 115 –O. Also, the individual receiving the dividend in excess of 10,00,000 was liable to pay tax on the dividend received in the individual hands.
2. Similarly, under section 115R, specified companies and Mutual Funds are liable to pay additional income-tax at the specified rate on any amount of income distributed by them to its unit holders.
3. It is proposed to exempt the dividend declared, distributed or paid from or after 1 April 2020, which shall be taxable in the hands of the recipient of the dividend from the shares or units of mutual funds (resident or non- resident).

Residential Status

1. The basic condition of being resident under sub-section 1 of section 6 provides that an individual is said to be a resident in India, if in the previous year individual is
   1. In India for more than 182 days or more or
   2.  60 days in previous year and 365 days or more during the four years immediately preceding the previous year

It is proposed to reduce the number of days from 182 to 120 days in previous year.

1. Currently, a citizen of India, spending more than 182 days outside India in a previous year is not chargeable to tax in India. However, a proviso is proposed to be inserted under clause (1) of section 6 which intends to tax the citizens of India for the reason of number of days of their stay in India are non-resident in India and are also not liable to tax in any other country or territory by reason of his domicile or residence or any criteria of similar nature.

Thus, if a resident in India is out of India in previous year for more than 120 days (from AY 2021-22) and his income is not liable to tax outside India for any reason, he shall be liable to pay tax on such income in India, irrespective of his residential status in that year in India.

1. Clause (6) of section 6 provides for the conditions as to when an Individual or HUF can be said to be a “not ordinarily resident” in India in any previous year. Currently, the sub-clause provides two conditions to become resident but not ordinarily resident. The conditions are:
   1. For Individual – He has been resident in India in at least 2 out of 10 years or 730 days in 7 preceding years
   2. For HUF – Manager of HUF has been resident in India in at least 2 out of 10 years or 730 days in 7 preceding years

It is proposed to amend the above two conditions from AY 2021-22 as under:

• For Individual – Has been a resident in India in 7 out of 10 preceding years
• For HUF – Manager of HUF has been resident in India in 7 out of 10 preceding years

Incentives to Sovereign Wealth fund or subsidiary of Abu Dhabi Investment Authority

1. In order to promote investment of sovereign wealth fund, including the wholly owned subsidiary of Abu Dhabi Investment Authority (ADIA), it is proposed to insert a new clause in section 10 to provide exemption to any income of a specified person
   • in the nature of dividend,
   • interest or
   • long-term capital gains arising from an investment made by it in India, whether in the form of debt or equity,

in a company or enterprise carrying on the business of developing, or operating and maintaining, or developing, operating or maintaining any infrastructure facility

1. The investment shall be required to be made on or before 31 March 2024. Further, there are certain conditions to be fulfilled to claim the exemption which includes that in case of sovereign wealth fund, the assets shall vest in the Government of the foreign country upon dissolution and Its earnings are credited either to the account of the Government of the foreign country or to any other account designated by that Government such that no portion of the earnings inures any benefit to any private person

Expanding the income under Salaries

1. Currently, sub-clause (vii) of clause 2 of section 17 provides the definition of perquisites provided by the employer as part of salary. It provides that perquisites shall include any contribution to an approved superannuation fund by the employer more than Rs 1.5 lac.

 

1. From AY 2021-22, it is proposed to amend the sub-clause to include any contribution made to the account of the assessee by the employer which exceeds Rs 7.5 lac instead of Rs 1.5 lac in
2. a recognised provident fund;
3. the scheme referred to in sub-section (1) of section 80CCD; and
4. an approved superannuation fund,
5. It is further proposed to tax any annual accretion by way of interest, dividend or any other amount on the above contributions as perquisite. The calculation thereof will be prescribed.

Income deemed to accrue or arise in India

Explanation 1 & 2

1. As per the provisions of section 9 following income accruing or arising to the assessee in any place outside India, whether directly or indirectly would be deemed to accrue or arise in India-
2. through or from any business connection in India
3. through or from any property in India
4. through or from any asset or source of income in India
5. through the transfer of a capital asset situate in India.

The explanation 1 to the section provides the extent of income chargeable in India through that business connection.

1. Through Finance Act 2018, the explanation 2A was inserted to define significant economic presence in India. It is proposed to amend explanation 2A the definition from AY 2022-23 as under:

Nature of Transaction	Condition
transaction in respect of any goods, services or property carried out by a non-resident with any person in India including provision of download of data or software in India	aggregate of payments arising from such transaction or transactions during the previous year exceeds such amount as may be prescribed
systematic and continuous soliciting of business activities or engaging in interaction	such number of users in India, as may be prescribed

1. It is further proposed that the the transactions or activities shall constitute significant economic presence in India, whether or not—
2. the agreement for such transactions or activities is entered in India; or
3. the non-resident has a residence or place of business in India; or
4. the non-resident renders services in India:
5. The income chargeable in case of business having significant economic presence is proposed to be restricted to income as is attributable to the transactions or activities proposed.
6. In furtherance to the proposed amendment in the definition of significant economic presence, the computation in explanation 1 is restricted to the business other than the business having significant economic presence

 

Explanation 3A

1. A new explanation is proposed to be inserted from AY 2021-22 clarifying that income attributable to the operations carried out in India as referred in explanation 1 shall include income from –
   • advertisement which targets a customer who resides in India or a customer who accesses the advertisement through internet protocol address located in India
   • sale of data collected from a person who resides in India or from a person who uses internet protocol address located in India
   • sale of goods or services using data collected from a person who resides in India or from a person who uses internet protocol address located in India

Accordingly, the online giants like Goggle or Facebook which are earning from advertisement through cyber traffic originating from India either on advertisements or sale of data collected from IP used in India is proposed to be chargeable to tax in India.

Charitable or Religious Trust

1. Continuing with a major compliance requirement, the Hon’ble Finance Minister has amongst a slew of other measures, realigned the benefit accorded to funds trusts, institutions, university, educational institution, hospital or medical institution to the grant of approval by the Principal Commissioner or Commissioner upon an application made in this behalf by the concerned fund or institution.
2. A new section 12AB is proposed to be inserted specifying the procedure of registration of trusts & institutions. It provides that where the application is made for registration, upon successful passing of the order in writing will be registered for a period of five years. The application for registration shall be rejected only by an order in writing rejecting such application and also cancelling its registration after affording a reasonable opportunity of being heard.
3. Section 11 with effect from 1 day of June 2020
   • Clause (7) of Section 11 has been proposed to be amended to include registration of trusts or institutions under either 12AA or under the newly inserted sec 12AB.
   • The trust/institutions whose registration has become inoperative under the 12AA, may apply to get its registration operative under section 12AB.
4. Section 12A
   • The conditions for allowability of Section 11 & Section 12 are proposed to be amended. In sub – section (1), a new clause (ac) is inserted as follows:

• where the trust or institution is registered under section 12A /12AA, within three months from the date on which the clauses has come into force;
• where the trust or institution is registered under section 12AB and the period of the said registration is due to expire, at least six months prior to expiry of the said period;
• where the trust or institution has been provisionally registered under section 12AB, at least six months prior to expiry of period of the provisional registration or within six months of commencement of its activities, whichever is earlier;
• where registration of the trust or institution has become inoperative due to the first proviso to sub- section (7) of section 11, at least six months prior to the commencement of the assessment year from which the said registration is sought to be made operative;
• within a period of 30 days from any modification / adoption of objects, where undertaken.
•  in any other case, at least one month prior to the commencement of the previous year relevant to the assessment year from which the said registration is sought,

1. Section 12AA of the Act which currently provides for procedure of registration is proposed to be omitted on or after the 1st day of June, 2020.”
2. Filing of statement of donation by donee to cross-check claim of donation by donor.
   • At present, there is no reporting obligation by the exempt entity receiving donation/ any sum in respect of such donation/ sum. It is proposed the entities receiving donation/ sum may be made to furnish a statement in respect thereof, and to issue a certificate to the donor/ payer and the claim for deduction to the donor/ payer may be allowed on that basis only.
   • The entities receiving donation/ sum may be made to furnish a statement in respect thereof, and to issue a certificate to the donor/ payer and the claim for deduction to the donor/ payer may be allowed on that basis only. In order to ensure proper filing of the statement, levy of a fee and penalty may also be provided in cases where there is failure to furnish the statement
3. An entity making fresh application for approval under clause (23C) of section 10, for registration under section 12AA, for approval under section 80G for receiving donations, shall be provisionally approved or registered for three years on the basis of application without detailed enquiry even in the cases where activities of the entity are yet to begin and then it has to apply again for approval or registration which, if granted, shall be valid from the date of such provisional registration. The application of registration subsequent to provisional registration should be at least six months prior to expiry of provisional registration or within six months of start of activities, whichever is earlier.

Proposed Amendments in Finance Bill – 2020 9

WS & Associates LLP

Certain Activities not to constitute business connection in India

1. Section 9A of the Act provides for a special regime in respect of offshore funds by providing them exemption from creating a “business connection” in India on fulfilment of certain conditions. Considering the initial hardships faced by the fund managers, it is proposed to amend as under:
2. for the purpose of calculation of the aggregate participation or investment in the fund, directly or indirectly, by Indian resident, contribution of the eligible fund manager during first three years up to twenty-five crore rupees shall not be accounted for; and
3. if the fund has been established or incorporated in the previous year, the condition of monthly average of the corpus of the fund to be at one hundred crore rupees shall be fulfilled within twelve months from the last day of the month of its establishment or incorporation.

The above amendment is proposed from AY 2020-21 i.e applicable for FY 2019-20

Significant Economic Presence

1. It is proposed to defer the applicability of SEP to AY 2022-23 “since discussion on this issue is still going on in G20-OECD BEPS project”, For the purposes of determining SEP of a non-resident in India, threshold for the aggregate amount of payments arising from the specified transactions and for the number of users were required to be prescribed in the Rules. As G20-OECD report is expected by the end of December 2020, “these numbers have not been notified yet.”;

 

1. The amendment is proposed to be effective from 1st April, 2021 and will, accordingly, apply in relation to AY 2021-22 and subsequent AYs. However, for attribution of income related to SEP transaction or activities the amendment will take effect from 1st April, 2022 and will, accordingly, apply in relation to AY 2022-23 and subsequent AYs.

Amendment of section 44AB

1. To enable pre-filling of returns in case of persons having income from business or profession, it is required that the tax audit report may be furnished by the said assessees at least one month prior to the due date of filing of return of income

Clause	Existing	Proposed
44AB (a) (In case of Business turnover limit)	1 crore	5 crore
Condition of cash transaction	Not Applicable	Turnover or gross receipts during the previous year, in cash, does not exceed five per cent. Payments made including amount incurred for expenditure, in cash, during the previous year does not exceed five per cent.

Aligning purpose of entering into Double Taxation Avoidance Agreements (DTAA) with Multilateral Instrument (MLI)

1. India has signed the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (commonly referred to as MLI) along with representatives of many countries, which has since been ratified. India has since deposited the Instrument of Ratification to OECD, Paris along with its Final Position in terms of Covered Tax Agreements (CTAs), Reservations, Options and Notifications under the MLI, as a result of which MLI has entered into force for India on 1st October, 2019 and its provisions will be applicable on India’s DTAAs from FY 2020-21 onwards.
2. In alignment of the above, it is proposed it is proposed to amend clause (b) of sub-section (1) of section 90 and clause (b) of sub-section (1) of section 90A of the Act so as to provide that the Central Government may enter into an agreement with the Government of any country outside India or specified territory outside India for, inter alia, the avoidance of double taxation of income under the Act and under the corresponding law in force in that country or specified territory, as the case may be, without creating opportunities for non- taxation or reduced taxation through tax evasion or avoidance (including through treaty-shopping arrangements aimed at obtaining reliefs provided in this agreement for the indirect benefit of residents of any other country or territory).

Carry forward and set off of accumulated loss and unabsorbed depreciation in case of amalgamation

1. Section 72AA of the Act Section 72AA of the Act provides for carry forward of accumulated losses and unabsorbed depreciation allowance in the case of amalgamation of banking company with any other banking institution. However, the benefit is restricted to scheme sanctioned and brought into force by the Central Government under sub-section (7) of section 45 of the Banking Regulation Act, 1949.

 

1. It is proposed to extend the benefit of this section to amalgamation of,-
2. One or more corresponding new bank or banks with any other corresponding new bank under a scheme brought into force by the Central Government under section 9 of the Banking Companies (Acquisition and Transfer of Undertakings) Act, 1970 or under section 9 of the Banking Companies (Acquisition and Transfer of Undertakings) Act, 1980, or both, as the case may be, or
3. One or more Government company or companies with any other Government company under a scheme sanctioned and brought into force by the Central Government under section 16 of the General Insurance Business (Nationalisation) Act, 1972.

Tax Deducted/collected at Source

1. TDS on Salary – section 192

Currently ESOPs are taxed as perquisites under section 17(2) of the Act read with Rule 3(8)(iii) of the Rules.

Particulars	Current Taxability
Tax on perquisite as income from salary	at the time of exercise
Tax on income from capital gain	at the time of sale.

It is proposed to insert a new Sub- section (1C) to provide a benefit to the ESOPs received from the eligible start-up under 80-IAC, to pay tax on income arising from ESOP within fourteen days of

1. After expiry of 48 months from end of relevant assessment year or
2. From the date of sale of Specified equity or sweat equity share or
3. From the date where the person ceases to be the employees of the start-up

Similar amendments have been proposed in section 191 (for assessee to pay the tax direct in case of no TDS) and in section 156 (for notice of demand) and in section 140A (for calculating self-assessment).

1. TDS on Dividends- section 194
   • Currently TDS on dividends is applicable where the dividend paid is more than Rs 2,500 at the rates in force. As the dividend was chargeable to tax in the hands of the domestic company declaring, distributing or paying, the rates in force for withholding tax on dividend was Nil.
   • The amendment is proposed to affix the tax rate @ 10% instead of rates in force considering that the dividend will be chargeable to tax in the hands of recipient. It is also proposed to amend the limit of Rs 2,500 to Rs 5,000.
2. TDS on Interest other than interest on securities – Section 194A
   •  Currently Individual or HUF whose Sales or turnover or gross receipts from business exceed 1 crore are liable to withhold taxes under section 194A. Pursuant to the amendment in section 44AB wherein the limit for the tax audit of the MSME is extended to 5 crore, it is proposed to include the following

as well, being liable for withholding taxes:

• Professionals having sales or turnover of Rs 50 lakh during preceding financial year;
• Co-Operative Society where the total sales, gross receipts or turnover of the co-operative society exceeds 50 crore rupees during preceding financial year in which interest paid or credited

1. TDS on payments made by Contractors – Section 194C
   • Similar to the provisions of section 194A, currently Individual or HUF whose Sales or turnover or gross receipts from business exceed 1 crore are liable to withhold taxes under section 194C. Thus, Pursuant to the amendment in section 44AB wherein the limit for the tax audit of the MSME is extended to 5 crore, it is proposed to include the professionals where the gross total income is Rs 50 lakh from the profession during the immediately preceding financial year in which such sum is credited or paid to the account of the contractor.
   • Clause (iv) of the Explanation to section 194C defines “work”. Sub-clause (e) of this definition includes manufacturing or supplying a product according to the requirement or specification of a customer by using material purchased from such customer within the definition.
   • It is further proposed to extend the definition of work under section 194C to provide that in a contract manufacturing, the raw material provided by the assessee or its associate i.e. the related party as defined under section 40A(2b) shall also fall within the purview of the ‘work’ under section 194C. Thus, in case the raw material is provided by the assessee or any of its associates, it will be liable to withhold tax under section 194C of the Act.
2. The amendment in relation to the change in definition of person liable to withhold tax, post proposed amendment in section 44AB for the limit of tax audit of MSME is also proposed in section 194H, 194I and 194J.
3. TDS on payments made for Managerial or Consultancy Services

Currently, payment made as fees for technical services covered under section 194J of the Act is liable for withholding of tax @ 10% where the total payment made exceeds Rs 30,000. The term “fees for

technical services” is defined under section 9(1)(viib) of the Act and includes any services in the nature of technical, managerial or consultancy.

It is proposed to amend the tax rate for the payment made for managerial and consultancy services from 10% to 2%. The withholding tax rate for professional services continues at 10%.

1. Newly Introduced sections for TDS
2. Section 194K
   • A new section from AY 2021-22, for withholding of tax is proposed to provide that any person responsible for paying to a resident any income in respect of units of a Mutual Fund specified under clause (23D) of section 10 or units from the administrator of the specified undertaking or units from the specified company shall at the time of credit of such income to the account of the payee or at the time of payment thereof by any mode, whichever is earlier, deduct income-tax there on at the rate of 10%.
   • Section 194A only covers for the dividend paid by the domestic company. In consonance with the proposed amendment under section 115O and taxing the dividend income in the hands of the recipient, the dividend paid on the Mutual Funds is also proposed to be liable for withholding of tax.

The threshold limit is proposed for Rs 5,000

1. Section 194O

 



It is proposed to insert a new section 194-O from AY 2021-22 in the Act for withholding tax on payments made by e-commerce operator for sale of goods or provision of service facilitated by it

through its digital or electronic facility or platform.



The TDS is required to be withheld @ 1% of the gross amount of sale or services or both. However, where the amount is paid to Individual or HUF and the amount paid is less than Rs 5 lac and they have furnished their Permanent Account Number (PAN) or Aadhaar number to the e-commerce

operator, no TDS will be withheld.



Where the seller or service provider does not provide PAN, the maximum TDS rate under this

section 1ill be 5% instead of 20% as provided for other section under section 206AA.

Applicable TDS rates for ready reference for AY 2021-22

Section	Nature of payment	Threshold	TDS (Sc:nil EC nil Shec: nil
192	payment of salary	As per slab rates	As per slab rates
192A	payment of taxable accumulated balance of provident fund	50,000	10
193 a. b.	Interest on securities Interest on (a) debentures/securities for money issued by on behalf of any local authority /statutory corporation, (b) listed debentures of a company [not being listed securities in demat form], (c) any security of the central or state Government [ie.8%saving (taxable ) bonds ,2003,and 7.75% Savings (taxable) Bonds ,2018 but not- any other Government security ]	10,000	10
	Any other interest on securities (including interest on non listed debentures		10

Section	Nature of payment	Threshold	TDS (Sc:nil EC nil Shec: nil
194 a. b.	Deemed dividend under section 2(22)(e) any other dividend *Payment by any mode to be included	5,000	10 10
194A	Interest other than interest on securities Senior Citizen (paid by bank) Any other person	50,000 40,000	10
194BB	Winnings from lottery or crossword puzzle or card game or other game of any sort or winning from horse races	10,000	30
194C	Payment or credit to a resident contractor/ sub- contractor- payment/ credit to an individual or a Hindu Undivided family payment/credit to any person other then an Individual or a Hindu Undivided family	30,000 Single transaction s 100,000 during the year	1 2
194D	Insurance commission– -if recipient as a resident (other then a company) -if recipient as a domestic company	15,000	5 10
194DA	payment in Respect of life insurance policy_ – From june 1,2016	100,000	1
194EE-	payment in respect of deposits under National shavingScheme,1987- -From 1,june 2016	2500	10
194F	payment on account of repurchase of units of MF or UTI	–	20
194G	Commission on sale of lottery tickets	15,000	5
194H	Commission or brokerage Now Individual or HUF – Sales or turnover or gross receipts from business exceed 1 crore or 50 lakh in case of profession during preceding financial year shall be liable to deduct income-tax.	15,000	5
194I	Rent a, rent of plant and machinery b, rent of land or building or furniture or fitting	240,000	5
194IA	Payment /credit of consideration to a resident transferor for transfer of any immovable property (other then rural agricultural land)	50,00000	1
194J	Professional fees, technical fees, royalty or remuneration to a director or any sum referred to in clause (va) of section 28 Technical or consultancy services (not being professional services) Any other case	30,000	2 10
194K	Payment in respect on income in respect of –Units of Mutual fund/Administrator/Specified Company	5000	10
194LA	Payment of compensation on acquisition of certain immovable property	2,50,000	10
194LBA( 1)	Payment of the nature referred to in section (23FC)(a) by business trust to resident unit holders	–	10

 

Section	Nature of payment	Threshold	TDS (Sc:nil EC nil Shec: nil
194LBB	Payment in respect of units of investment fund specified in section 115UB	–	10
194LBC( 1)	Payment in respect of an investment in a securitization trust specified in clause (d) of the Explanation occurring after section 115TCA (with effect from june 1, 2016)- -Individual or a Hindu undivided family -Any other person	–	25 30
194LC	interest paid to non-residents on the borrowings before 1st July, 2023 by way of issue of any long-term infrastructure bond interest payable to a non-resident on borrowings by way of long term bond or RDB before 1 July 2023		5 4
194O	Payment of certain sums by e-commerce operator to e- commerce participants	Rs 5,00,000 if payment made to Individual or HUF	1
195	Payment/ credit of other sums	–	As per relevant clause
196C	Payment /credit of interest of foreign currency bonds or GDR	–	10
196D	Payment /credit of income from securities (not being dividend, short term or long-term capital gain) to FII	–	20

1.  Newly Introduced clauses for TCS – section 206C
2. Clause 1G
   • In order to widen and deepen the tax net, it is proposed to insert a new sub-section (1G) in the said section 206C to levy TCS on
     • overseas remittance under the Liberalized Remittance Scheme (“LRS”) of the Reserve Bank of India from a buyer;
     • for sale of overseas tour package,
   • Under the LRS, all resident individuals, including minors, are allowed to freely remit up to USD 2,50,000 per financial year (April – March) for any permissible current or capital account transaction or a combination of both. It is proposed to collect TCS @ 5% where the payment exceeds seven lakh rupees or more, in a financial year for remittance out of India under the LRS of RBI. However, where the PAN/Aadhaar is not provided, the tax rate will be 10% instead of 5%.
   • Further, a seller of an overseas tour program package who receives any amount from any buyer of a tur package is also proposed to withhold TCS @ 5%.
   • However, no TCS is to be collected, if the buyer is liable to deduct TDS under any provision of the Act and has deducted such amount.
3. Clause 1H

• A new clause is proposed for withholding of TCS on the sale of goods above Rs 50 lakh, other than the goods covered in sub-section (1) or sub-section (1F) i.e. sale of motor vehicle exceeding 10 lac or (1G) i.e. tour packages or remittance under LRS above Rs 7 lac, section 206C to levy TCS on sale of goods, as under:
• motor vehicle exceeding 10 lac or (1G) i.e. tour packages or remittance under LRS above Rs 7 lac, section 206C to levy TCS on sale of goods, as under:

Limits	Percentage Applicable	Non- PAN/Aadhaar Cases
Above Rs 50 Lacs.	0.1 per cent on consideration received	1% on consideration received

• Only those sellers whose total sales, gross receipts or turnover from the business carried on by it exceed ten crore rupees during the financial year immediately preceding the financial year, shall be liable to collect such TCS.

1. The amendment in relation to the change in definition of person liable to collect tax, post proposed amendment in section 44AB for the limit of tax audit of MSME is also proposed in section 206C.
2. The section 203AA which provides for issuance of form 16 /16A post withholding and deposit of TDS by the deductor is proposed to be omitted from 1 June 2020. Thus, the deductor will not be liable to issue any certificate to the deductee. However, a new section 285BB is proposed to be inserted wherein the person authorized by the income tax authority shall upload such statement (to be prescribed) on the online portal.

Clarificatory Amendments and Others

1. The definition of “Royalty” under section 9(1)(vi) of the Act is proposed to be amended to withdraw the exemption provided to the income from sale, distribution or exhibition of cinematographic films.

 

1. Amendment in section 35AD is proposed to align with section 115ABA and 115ABB to provide an option to the assessee to opt for the benefit of 100% of the capital expenditure.
2. The existing provisions of section 80EEA of the Act provide for a deduction in respect of interest on loan taken from any financial institution for acquisition of an affordable residential house property. The deduction allowed is up to one lakh fifty thousand rupees and is subject to certain conditions. One of the conditions is that loan has been sanctioned by the financial institution during the period from 1st April, 2019 to 31st March, 2020. It is proposed to extend the period of period of sanctioning of loan by the financial institution is proposed to be extended to 31st March, 2021.
3. The existing provisions of section 80-IBA of the Act, inter alia, provide that where the gross total income of an assessee includes any profits and gains derived from the business of developing and building affordable housing projects, there shall, subject to certain conditions specified therein, be allowed a deduction of an amount equal to one hundred per cent of the profits and gains derived from such business. The conditions contained in the section, inter alia, prescribe that the project is approved by the competent authority during the period from 1st June, 2016 to 31st March, 2020. the period of approval of the project by the competent authority is proposed to be extended to 31st March, 2021
4. The current provisions under section 80-IAC allows a start up exemption of 100% of its profits for 3 consecutive years out of 7 years from its incorporation where the eligible start-up is incorporated on or after 1 April 2016 but before 1 April 2021. The period of 7 years is proposed to be extended to 10 years provided the turnover of the start-up does not increase 100 crore rupees in any of the years since incorporation.
5. It is proposed to amend section 92CB and section 92CC of the Act to cover determination of attribution to PE within the scope of Safe Harbor Rules and Advance Pricing Agreement. With respect to section 92CB, the amendment will take effect from 1st April 2020 and will, accordingly, apply in relation to the assessment year 2020-21 and subsequent assessment years
6. It is proposed to amend the due date for filing the return of income from 30 September (in case of no international transaction) to 31 October companies / other persons who are required to get their accounts audited.
7. Provisions of section 10, section 10A, section 12A, section 32AB, section 33AB, section 33ABA, section 35D, section 35E, section 44AB, section 44DA, section 50B, section 80-IA, section 80-IB, section 80JJAA, section 92F, section 115JB, section 115JC and section 115VW of the Act are proposed to be amended for filing of audit reports before one month of filing of return.
8. It is proposed to increase in safe harbour limit of 5% to 10% under section 43CA (Special provision for full value of consideration for transfer of assets other than capital assets), section 50C (Special provision for full value of consideration for transfer of Land & Building) and section 56 (income from other sources including income from immovable property) of the Act to 10 per cent
9. The Provision of section 115A has been proposed to be amended, to exempt filling of return where taxes on Royalty and FTS are paid and has been deducted in India at a rate not less then prescribed in the section
10. A new section 119A is proposed to be entered to empower the Central Board of Direct Taxes to adopt and declare a Taxpayer’s Charter and issue such orders, instructions, directions or guidelines to other income- tax authorities as it may deem fit for the administration of such Charter.
11. The provisions of section 144C for filing application before Dispute Resolution panel are proposed to be amended to include non-resident assessee other company and foreign company. Further, it is also proposed to amend the provisions to increase the scope of section from variation in income or loss of the assessee, to any variation (including expenses as well).

 

1. Similar to the introduction of e-assessment in previous finance Act, the proposals are made for e-appeal by introducing sub-section (6A) in section 250 of the Act to notify an e-appeal scheme for disposal of appeal.
2. For the ease of the compliance it is proposed to amend section 140 (return by whom to be verified) and section 288 (appearance by authorized representative)

Company	Company	LLP	LLP	Section 288	Section 288
Existing	Proposed	Existing	Proposed	Existing	Subsection 2
MD or MD is not able to verify for any unavoidable reason or where there is no MD, any director of the company. by the insolvency professional appointed by such AA	It is proposed to amend above clause to enable any other person prescribed by the Board to verify the return of income.	By the designated partner of the LLP or by any partner, in case there is no such designated partner	It is proposed to amend above clause to enable any other person prescribed by the Board to verify the return of income.	Person related to assessee Legal practitioner Accountant	It is proposed to amend to enable any other person, as may be prescribed by the Board, to appear as an authorized representative

Indirect Tax Chapter

Custom Act, 1962

As the finance minister indicated in her speech, the amendments to The Customs Act, 1962 (hereinafter referred as “the Customs Act”)are focused towards, restricting claims under free trade agreements posing threats to the domestic industry, strengthening provisions relating to the safeguard duties applied when surge in imports cause serious injury to domestic industry and strengthening the anti-dumping provisions . Following is a brief overview of the proposed amendments to the Customs Act:

1. Proposed amendment to Section 11 (2) (f), to substitute the words “gold or silver” with the words “good, silver or any other goods”.

Section 11 deals with Central government’s power to prohibit import or export of goods and the clause (f) to sub-section (2) specifically deals with such prohibition with the purpose of prevention of serious injury to the economy of the country by uncontrolled import or export.

1. Proposed substitution of the Explanation 4 to Section 28, by the following explanation with effect from 29 March 2018:

“For the removal of doubts, it is hereby declared that notwithstanding anything to the contrary contained in any judgment, decree or order of the Appellate Tribunal or any Court or in any other provision of this Act or the rules or regulations made thereunder, or in any other law for the time being in force, in cases where notice has been issued for non-levy, short-levy, non-payment, short-payment or erroneous refund, prior to the 29th day of March, 2018, being the date of commencement of the Finance Act, 2018, such notice shall continue to be governed by the provisions of section 28 as it stood immediately before such date.”

The Explanation 4 currently reads as:

“For the removal of doubts, it is hereby declared that in cases where notice has been issued for non-levy, not paid, short-levy or short-paid or erroneous refund after the 14th day of May, 2015, but before the date on which the Finance Bill, 2018 receives the assent of the President, they shall continue to be governed by the provisions of section 28 as it stood immediately before the date on which such assent is received.”

1. Following proposed amendments to In Section 28AAA (1):

• Substitution of the words “by such person”, by “or any other law, or any scheme of the Central Government, for the time being in force, by such person”
• Insertion of the after the words “or regulations” after the words “the rules”
• Substitution of the words “with respect to”, by “or duty credit issued under section 51B, with respect to” in Explanation 1

Section 28AAA, deals with recovery of duties in cases, where an instrument issued to a person has been obtained by him by means of collusion, willful misstatement or suppression of facts and such instrument is utilized under the provisions of the Customs Act or rules made or notifications issued thereunder by a person other than the person to whom such instrument was issued. The duty relatable to such utilisation of instrument shall be deemed never to have been exempted or debited and such duty shall be recovered from the person to whom the said instrument was issued.

Further, the Explanation 1 defines instrument to mean any scrip or authorisation or licence or certificate or such other document, by whatever name called, issued under the Foreign Trade (Development and Regulation) Act, 1992, with respect to a reward or incentive scheme or duty exemption scheme or duty remission scheme or such other scheme bestowing financial or fiscal benefits, which may be utilised under the provisions of the Customs Act or the rules made or notifications issued thereunder.

1. Proposed insertion of a new Chapter VAA dealing with “Administration Of Rules Of Origin Under Trade Agreement” in the Customs Act. The chapter prescribes the procedure to be followed for:

• claiming preferential rate of duty under any trade agreement
• verification of such claim by the proper officer, which may result in suspension or disallowance of such claim
• refusal of preferential tariff treatment, without verification under specified circumstances

1. The heading for the Chapter VIIA (Payments through electronic cash ledger) of the Customs Act has been proposed to be amended and read as “Payments through electronic cash ledger and electronic duty credit ledger
2. Proposed insertion of a new Section 51B, under which the Central Government can issue notifications to specify the manner in which it shall issue duty credit,-
   1. in lieu of remission of any duty or tax or levy, chargeable on any material used in the manufacture or processing of goods or for carrying out any operation on such goods in India that are exported; or
   2. in lieu of such other financial benefit subject to such conditions and restrictions as may be specified therein.

Such duty credit shall be maintained in the customs automated system in the form of an electronic duty credit ledger of the person who is the recipient of such duty credit and may be used by the person to whom it is issued or the person to whom it is transferred, towards making payment of duties payable under the Customs Act or under the Customs Tariff Act, 1975, subject to such prescribed conditions and restrictions.

1. Proposed insertion of the following sub-clause under Section 111 of the Customs Act:

“(q) any goods imported on a claim of preferential rate of duty which contravenes any provision of Chapter VAA or any rule made thereunder.”

Section 111 deals with confiscation of goods and conveyances and imposition of penalties Chapter VAA is the newly proposed chapter for “Administration Of Rules Of Origin Under Trade Agreement”.

1. Proposed insertion of the following sub-clause under Section 156 of the Customs Act:

“(i) the form, time limit, manner, circumstances, conditions, restrictions and such other matters for carrying out the provisions of Chapter VAA.”

Section 156 deals with the general powers to make rules and Chapter VAA is the newly proposed chapter for “Administration Of Rules Of Origin Under Trade Agreement”.

1. Proposed insertion of the following sub-clause under Section 157 (2) of the Customs Act:

“(i) the form, time limit, manner, circumstances, conditions, restrictions and such other matters for carrying out the provisions of Chapter VAA.”

Section 157 deals with the general powers to make regulations and Chapter VAA is the newly proposed chapter for “Administration Of Rules Of Origin Under Trade Agreement”.

Customs Tariff Act, 1975

1. Section 8B of The Customs Tariff Act, 1975 (hereinafter referred to as ‘CTA’) , which deals with the powers of the central government to impose safeguard duty has been proposed to be substituted, with a new section.

The current section allowed the Central government, if it was satisfied that an article is being imported into India in such increased quantities and under such conditions so as to cause or threaten to cause injury to domestic industry, to only impose safeguard duties.

The proposed amendment now grants additional powers to the Central Government to apply such safeguard measures, as it may deem fit, including application of tariff-rate quota or such other measure, as considered appropriate. The proposed section also provides guidance on the level of the tariff-rate quote and allocation thereof to the supplying countries.

1.  The Standard rates of custom duty, as specified under the First Schedule of CTA, has been proposed to be amended as follows, with effect from 1 April 2020:

Tariff Item	Description of goods	Standard Rate of duty
		Existing	Proposed
0802 32 00	Almonds (Shelled and Chestnuts)	30%	100%
3824 99 00	Prepared binders for foundry moulds or cores; Chemical products and preparations of the Chemical or allied industries (including those Consisting of mixtures of natural products), Not elsewhere specified or included	10%	17.5%
6401	waterproof footwear with outer soles and uppers of rubber or of plastics, the uppers of which are neither fixed to the sole nor assembled by stitching, riveting, nailing, screwing, plugging or similar processes	25%	35%
6402	other footwear with outer soles and uppers of rubber or plastics	25%	35%
6403	footwear with outer soles of rubber, plastics, leather or composition leather and uppers of leather	25%	35%
6404	footwear with outer soles of rubber, plastics, leather or composition leather and uppers of textile material	25%	35%
6405	other footwear	25%	35%
6702	artificial flowers, foliage and fruit and parts thereof; articles made of artificial flowers, foliage or fruit	10%	20%
6911 10 11	Tableware of bone china and soft porcelain	10%	20%
6911 10 19	Tableware, others	10%	20%
6911 10 21	kitchenware, of bone china and soft porcelain	10%	20%
6911 10 29	kitchenware, others	10%	20%
6911 90 20	Water filters of a capacity not exceeding 40 litres	10%	20%
6911 90 90	tableware, kitchenware, other household articles and toilet articles, of porcelain or china, others	10%	20%

Tariff Item	Description of goods	Standard Rate of duty
		Existing	Proposed
6912 00 10	Ceramic tableware, kitchenware, other household articles and toilet articles, other than of porcelain or china : Tableware	10%	20%
6912 00 20	Ceramic tableware, kitchenware, other household articles and toilet articles, other than of porcelain or china : Kitchenware	10%	20%
6912 00 40	Ceramic tableware, kitchenware, other household articles and toilet articles, other than of porcelain or china:Clay articles	10%	20%
6912 00 90	Ceramic tableware, kitchenware, other household articles and toilet articles, other than of porcelain or china: Others	10%	20%
7013	Glassware of a kind used for table, kitchen, toilet, office, indoor decoration or similar purposes (other than that of heading 7010 or 7018)	10%	20%
7018 10 20	Glass beads, imitation pearls, imitation precious or semi-precious stones and similar glass smallwares: Beads	10%	20%
7118	Coin	10%	12.5%
7323	table, kitchen or other household articles and parts thereof, of iron or steel; iron or steel wool; pot scourers and scouring or polishing pads, gloves and the like, of iron or steel	15%	20%
7418 10	Table, kitchen or other household articles and parts thereof; Pot scourers and scouring or polishing pads, gloves and the like:	10%	20%
7615 10	Table, kitchen or other household articles and parts thereof; pot scourers and scouring or polishing pads, gloves and the like: Pressure cookers, solar collectors:	10%	20%
8301 10 00	padlocks and locks (key, combination or electrically operated), of base metal; clasps and frames with clasps, incorporating locks, of base metal; keys for any of the foregoing articles, of base metal – padlocks	10%	20%
8301 30 00	padlocks and locks (key, combination or electrically operated), of base metal; clasps and frames with clasps, incorporating locks, of base metal; keys for any of the foregoing articles, of base metal – Locks of a kind used for furniture	10%	20%
8301 40 10	padlocks and locks (key, combination or electrically operated), of base metal; clasps and frames with clasps, incorporating locks, of base metal; keys for any of the foregoing articles, of base metal: Combination locks	10%	20%
8301 40 90	padlocks and locks (key, combination or electrically operated), of base metal; clasps and frames with clasps, incorporating locks, of base metal; keys for any of the foregoing articles, of base metal: Others	10%	20%
8301 50 00	padlocks and locks (key, combination or electrically operated), of base metal; clasps and frames with clasps, incorporating locks, of base metal; keys for any of the foregoing articles, of base metal: Clasps and frames with clasps, incorporating – locks	10%	20%
8301 60 00	padlocks and locks (key, combination or electrically operated), of base metal; clasps and frames with clasps, incorporating locks, of base metal; keys for any of the foregoing articles, of base metal: Parts	10%	20%
8301 70 00	padlocks and locks (key, combination or electrically operated), of base metal; clasps and frames with clasps, incorporating locks, of base metal; keys for any of the foregoing articles, of base metal: – Keys presented separately	10%	20%

 

Tariff Item	Description of goods	Standard Rate of duty
		Existing	Proposed
8304 00 00	filing, cabinets, card-index cabinets, paper – trays, paper rests, pen trays, office-stamp stands and similar office or desk equipment, of base metal, other than office furniture of heading 9403	10%	20%
8305	fittings for loose-leaf binders or files, letter clips, letter corners, paper clips, indexing tags and similar office articles, of base metal; staples in strips (for example, for offices, upholstery, packaging), of base metal	10%	20%
8306	bells, gongs and the like, non-electric, of base metal; statuettes and other ornaments, of base metal; photograph, picture or similar frames, of base metal; mirrors of base metal	10%	20%
8310	Sign-plates, name-plates, address-plates and Similar plates, numbers, letters and other Symbols, of base metal, excluding those of Heading 9405	10%	20%
8414 30 00	Compressors of a kind used in refrigerating equipment	10%	12.5%
8414 51 40	Table, floor, wall, window, ceiling or roof fans, with a self-contained electric motor of an output not exceeding 125 W: Railway carriage fans	7.5%	10%
8414 51 90	Table, floor, wall, window, ceiling or roof fans, with a self-contained electric motor of an output not exceeding 125 W: Other	7.5%	20%
8414 59 10	Air circulator	7.5%	10%
8414 59 30	Industrial fans and blowers	7.5%	10%
8414 59 90	Air or vacuum pumps, air or other gas compressors and fans; ventilating or recycling hoods incorporating a fan, whether or not fitted with filters : other	7.5%	10%
8414 59 20	Blowers, portable	7.5%	20%
8414 80 11	Table, floor, wall, window, ceiling or roof fans, with a self-contained electric motor of an output not exceeding 125 W: Gas compressors of a kind used in air-conditioning equipment	10%	12.5%
8418 10 10	Refrigerators, freezers and other refrigerating or freezing equipment, electric or other; heat pumps other than air conditioning machines of heading 8412.5: Commercial type	7.5%	15%
8418 30 10	Refrigerators, freezers and other refrigerating or freezing equipment, electric or other; heat pumps other than air conditioning machines of heading 8412.5: Commercial type electrical	7.5%	15%
8418 30 90	Refrigerators, freezers and other refrigerating or freezing equipment, electric or other; heat pumps other than air conditioning machines of heading 8412.5: Other	10%	15%
8418 40 10	Freezers of the upright type, not exceeding 900 l capacity- Electrical	7.5%	15%
8418 40 90	Freezers of the upright type, not exceeding 900 l capacity- Other	7.5%	15%
8418 50 00	Other furniture (chests, cabinets, display counters, show-cases and the like) for storage and display, incorporating or freezing equipment – Other refrigerating or freezing equipment; heat pumps :	7.5%	15%
8418 61 00	Heat pumps other than air-conditioning machines of heading 8415	7.5%	15%

Tariff Item	Description of goods	Standard Rate of duty
		Existing	Proposed
8418 69 10	Ice making machinery	7.5%	15%
8418 69 20	Water cooler	10%	15%
8418 69 30	Vending machine, other than automatic vending machine	10%	15%
8418 69 40	Refrigeration equipment or devices specially used in leather industries for manufacturing of leather articles	7.5%	15%
8418 69 50	Refrigerated farm tanks, industrial ice cream freezer	7.5%	15%
8418 69 90	refrigerators, freezers and other refrigerating or freezing equipment, electric or other; heat pumps other than air conditioning machines of heading 8412.5: Others	7.5%	15%
8419 89 10	Pressure vessels, reactors, columns or towers or chemical storage tanks	7.5%	10%
8421 39 20	air purifiers or cleaners	10%	15%
8421 39 90	centrifuges, including centrifugal dryers; filtering or purifying machinery and apparatus, for liquids or gases: Others	10%	15%
8504 40 10	Electric inverter	15%	20%
8504 40 21	Dip bridge rectifier	10%	20%
8504 40 29	Static converters: Others	15%	20%
8504 40 30	Battery chargers	15%	20%
8504 40 40	Voltage regulator and stabilizers (other than automatic)	15%	20%
8504 40 90	Static converters: Others	15%	20%
8509 40 10	electro-mechanical domestic appliances, with self contained electric motor, other than vacuum cleaners of heading 8508 : Food grinders	10%	20%
8509 40 90	electro-mechanical domestic appliances, with self contained electric motor, other than vacuum cleaners of heading 8508 : Other	10%	20%
8509 80 00	electro-mechanical domestic appliances, with self contained electric motor, other than vacuum cleaners of heading 8508 : Other appliances	10%	20%
8510 10 00	shavers, hair clippers and hair-removing appliances, with self- contained electric motor: Shavers	10%	20%
8510 20 00	shavers, hair clippers and hair-removing appliances, with self- contained electric motor: Hair clippers	10%	20%
8510 30 00	Hair-removing appliances	10%	20%
8515 11 00	Soldering irons and guns	7.5%	10%
8515 19 00	electric (including electrically heated gas),laser or other light or photobeam, ultrasonic, electron beam, magnetic pulse or plasma arc soldering, brazing or welding machines and apparatus, whether or not capable of cutting; electric machines and apparatus for hot spraying of metals or cermets: Other	7.5%	10%
8515 21 10	Automatic spot welding machinery	7.5%	10%

 

Tariff Item	Description of goods	Standard Rate of duty
		Existing	Proposed
8515 21 20	Automatic butt welding machinery	7.5%	10%
8515 21 90	electric (including electrically heated gas),laser or other light or photobeam, ultrasonic, electron beam, magnetic pulse or plasma arc soldering, brazing or welding machines and apparatus, whether or not capable of cutting; electric machines and apparatus for hot spraying of metals or cermets: Other	7.5%	10%
8515 29 00	electric (including electrically heated gas),laser or other light or photobeam, ultrasonic, electron beam, magnetic pulse or plasma arc soldering, brazing or welding machines and apparatus, whether or not capable of cutting; electric machines and apparatus for hot spraying of metals or cermets: Other	7.5%	10%
8515 31 00	Fully or partly automatic	7.5%	10%
8515 39 10	AC arc welding machinery	7.5%	10%
8515 39 20	Argon arc welding machinery	7.5%	10%
8515 39 90	Machines and apparatus for arc (including plasma arc) welding of metals: Other	7.5%	10%
8515 80 10	High-frequency plastic welding machine	7.5%	10%
8515 80 90	Other machines and apparatus:	7.5%	10%
8516 10 00	Electric instantaneous or storage water heaters and immersion heaters	10%	20%
8516 21 00	Storage heating radiators	10%	20%
8516 29 00	Electric space heating apparatus and electric soil heating apparatus	10%	20%
8516 31 00	Hair dryers	10%	20%
8516 32 00	Other hair-dressing apparatus	10%	20%
8516 33 00	Hand-drying apparatus	10%	20%
8516 40 00	Electric smoothing irons	10%	20%
8516 60 00	Other ovens; cookers, cooking plates, boiling rings, grillers and roasters	10%	20%
8516 71 00	Coffee or tea makers	10%	20%
8516 72 00	Toasters	10%	20%
8516 79 10	Electro-thermic fluid heaters	10%	20%
8516 79 20	Electrical or electronic devices for repelling insects (for example, mosquitoes or other similar kind of insects)	10%	20%
8516 79 90	electric instantaneous or storage water heaters and immersion heaters; electric space heating apparatus and soil heating apparatus; electro-thermic hair-dressing apparatus (for example, hair dryers, hair curlers, curling tong heaters) and hand dryers; electric smoothing irons; other electro-thermic appliances of a kind used for domestic purposes; electric heating resistors, other than those of heading 8545	10%	20%
8516 80 00	Electric heating resistors	10%	20%

 

Tariff Item	Description of goods	Standard Rate of duty
		Existing	Proposed
8517 70 10	populated, loaded or stuffed printed circuit boards	10%	20%
9401	seats (other than those of heading 9402), whether or not convertible into beds, and parts thereof	20%	25%
9403	other furniture and parts thereof	20%	25%
9404	mattress supports; articles of bedding and similar furnishing (for example, mattresses, quilts, eiderdowns, cushions, pouffes and pillows) fitted with springs or stuffed or internally fitted with any material or of cellular rubber or plastics, whether or not covered	20%	25%
9405	lamps and lighting fittings including searchlights and spotlights and parts thereof, not elsewhere specified or included; illuminated signs, illuminated name-plates and the like, having a permanently fixed light source, and parts thereof not elsewhere specified or included	20%	25%
9503	tricycles, scooters, pedal cars and similar wheeled toys; dolls’ carriages; dolls; other toys; reduced-size (“scale”) models and similar recreational models, working or not; puzzles of all kinds	20%	60%
9603	brooms, brushes (including brushes constituting parts of machines, appliances or vehicles), hand operated mechanical floor sweepers, not motorised, mops and feather dusters; prepared knots and tufts for broom or brush making; paint pads and rollers; squeegees (other than roller squeegees)	10%	20%
9604 00 00	hand sieves and hand riddles	10%	20%
9615	combs, hair-slides and the like, hairpins, curling pins, curling grips, hair-curlers and the like, other than those of heading 8516, and parts thereof	10%	20%
9617	vacuum flasks and other vacuum vessels, complete with cases; parts thereof other than glass inner	10%	20%

• registered persons engaged in making any supply of services through an electronic commerce operator who is required to collect tax at source under the CGST Act

 

1. Proposed amendment to Section 2 (14), the Central Goods and Services Tax Act, 2017 (hereinafter referred to as the CGST Act), which defines “Union Territory”. The proposed amendment seeks to include the new formed Union Territory of Ladakh within the purview of the CGST Act.
2. Proposed amendment to the Section 10 (2)(b)/(c) and (d), of the CGST Act for insertion of words “or services” after the words “of goods”.

Section 10(2) deals with the eligibility conditions for the registered persons to opt for the Composition levy scheme. As per the proposed amendment, the following registered persons shall become ineligible to opt for the composition scheme:

• • registered persons engaged in making supply of services, which are not leviable to tax under the CGST Act
  • registered persons engaged in making any inter-state supply of services

Central Goods and Services Tax

Proposed Amendments in Finance Bill – 2020 25

WS & Associates LLP

1. Proposed amendment to Section 16 (2) of the CGST Act, to omit the words “invoice relating to such”.

Section 16 (4) provides the time limit for availment of input tax credit (‘ITC’) in respect of any invoice or debit note for supply of goods or services or both. Under the current scenario, ITC in respect of a debit note could be not be availed after:

• • the due date of furnishing of the return under section 39 (GSTR3/3B) for the month of September following the end of financial year to which invoice relating to such debit note pertains to, or
  • furnishing of the relevant annual return, whichever is earlier.

As per the proposed amendment, the ITC for a debit note can be availed based on the financial year to which the debit note pertains to, instead of the financial year to which the invoice, for the debit note pertains to.

1. Proposed amendments to the Section 29 (1) (c) of the CGST Act, to be substituted with the following:

“(c) the taxable person is no longer liable to be registered under section 22 or section 24 or intends to opt out of the registration voluntarily made under sub-section (3) of section 25:”

Section 29 deals with the cancellation of the registration and as per the proposed amendment, any registered person, who though was not liable to be registered under the provisions of the CGST Act, chose to register voluntarily, can apply to the proper officer for cancellation of such registration.

1.  Proposed substitution of proviso to Section 30 (1), with the following:

“Provided that such period may, on sufficient cause being shown, and for reasons to be recorded in writing, be extended,–

1. by the Additional Commissioner or the Joint Commissioner, as the case may be, for a period not exceeding thirty days;
2. by the Commissioner, for a further period not exceeding thirty days, beyond the period specified in clause (a).”

Section 30(1) deals with revocation of cancellation of registration. Under the current scenario, an application for revocation of cancellation is required to be made within 30 days from the date of service of cancellation order. As per the proposed amendment, the Additional Commissioner or the Joint Commissioner can extend the due date for such application for a period not exceeding 30 days. In addition, the Commissioner may extend the due date for a further period not exceeding 30 days.

1. Proposed substitution of proviso to Section 31 (2), with the following:

“Provided that the Government may, on the recommendations of the Council, by notification,–

1. specify the categories of services or supplies in respect of which a tax invoice shall be issued, within such time and in such manner as may be prescribed;
2. subject to the condition mentioned therein, specify the categories of services in respect of which–
   1. any other document issued in relation to the supply shall be deemed to be a tax invoice; or
   2. tax invoice may not be issued.”

Section 31 sub-section (2) deals with the issuance of tax invoices. While under the current provisions, the government could have specified a prescribed period for issuance of tax invoice in respect of the

registered persons, the proposed amendment seeks to allow the Government to specify the category of services or supplies and prescribe the time period for issuance of tax invoice in respect of such category. In effect, a different time period may now be prescribed for different categories of services or supplies.

1. Proposed amendment to the Section 51 of the CGST Act, for substitution of sub-section (3) with “A certificate of tax deduction at source shall be issued in such form and in such manner as may be prescribed.” and omission of sub-section (4).

Section 51(3) dealt with issuance of certificate of tax deducted at source and Section 51 (4) prescribed late fees on delay in issuance of such certificate. While under the current scenario, the act specified the details to be included in such certificate, the proposed amendment omits such details from the act and also deletes the clause for the late fees. In effect, the form and manner in which the TDS certificate is to be issued shall be separately prescribed.

1. Proposed amendment to the Section 109 (6), for omission of words “except for the State of Jammu and Kashmir” and omission of the proviso.

Section 109(6) deals with constitution of the Appellate Tribunal and benches thereof by the Central Government, which so far, excluded creation of Appellate tribunal in State of Jammu and Kashmir and provided for State Appellate Tribunal constituted under the Jammu and Kashmir Goods and Services Tax Act, 2017. The proposed amendment omits such exclusion, now that Jammu & Kashmir is a union territory.

1.  Proposed insertion of new sub-section 1A to section 122, which reads as follows:

“(1A) Any person who retains the benefit of a transaction covered under clauses (i), (ii), (vii) or clause (ix) of sub-section (1)and at whose instance such transaction is conducted, shall be liable to a penalty of an amount equivalent to the tax evaded or input tax credit availed of or passed on.”

Section 122 deals with penalties for certain offences and provided for a penalty upto a maximum of Rs. 10,000. The proposed amendment, seeks to remove this cap and provides for a penalty equivalent to the tax evaded or input tax credit availed of or passed on. The specified offences are as follows:

• • supplies any goods or services or both without issue of any invoice or issues an incorrect or false invoice with regard to any such supply;
  • issues any invoice or bill without supply of goods or services or both in violation of the provisions of the CGST Act or the rules made thereunder;
  • takes or utilises input tax credit without actual receipt of goods or services or both either fully or partially, in contravention of the provisions of the CGST Act or the rules made thereunder
  • takes or distributes input tax credit in contravention of section 20, or the rules made thereunder

1. Proposed amendment to Section 132 (1) of the CGST Act, for:
   • Substitution of the words “Whoever commits any of the following offences”, with the words “Whoever commits, or causes to commit and retain the benefits arising out of, any of the following offences’’
   • Substitution of clause (c), with “(c) avails input tax credit using the invoice or bill referred to in clause

(b) or fraudulently avails input tax credit without any invoice or bill

• • and omission of words “, fraudulently avails input tax credit” is sub-clause (e)

Section 132 (1) deals with punishment of certain offences. The proposed amendment seeks to expand the scope of this section and make the persons who cause to commit and retain the benefit of the offence to also be liable to such punishments, in addition to person committing such offence.

1. Proposed amendments to Section 140 of the CGST Act, with effect from 1 July 2017, to include the words “within such time” in the various sub-sections.

Section 140, deals with the transitional arrangements for input tax credit and the proposed amendments seek to allow the Central Government to prescribe the time period within which the transitional credits may be availed.

1. Proposed amendments to Section 168 (2), for substitution for the words, brackets and figures “sub-section
2. of section 66, sub-section (1) of section 143”, the words, brackets and figures “sub-section (1) of section 143, except the second proviso thereof”

The Section 168 deals with the powers to issue instructions and directions and the sub-section provided that Commissioner as specified under various sections shall mean a Commissioner or Joint Secretary posted in the Board (Central Board of Indirect Taxes & Customs). The proposed amendment seeks to reduce the powers vested in the Commissioner or Joint secretary of the board to:

• • determine the expenses of examination and audit of records, including of remuneration of the chartered accountant or cost accountant, for the special audit
  • specify goods, which the principal may supply from the place of business of job worker, without declaring it as his additional place of business.

1. Proposed amendment to the proviso of Section 172 (1), for substitution of the words “three years” with the words “five years”.

Section 172 authorises the Central government, on recommendation of the GST Council, to issue removal of difficulty orders with regard to any provisions relating to any provisions of the CGST Act. Such orders can, however, not be issued after the expiry of three years from the commencement of the CGST act.

It has now been proposed, to allow the Central Government to issue such orders upto the expiry of five years from the commencement of the CGST act.

1. Proposed amendments to Schedule II of the CGST Act, for omission of the words “whether or not for a consideration” with effect from 1 July 2017.

The Schedule II deals with the “Activities to be treated as supply of goods and services”. In the current scenario, transfer of business assets, even if without a consideration, was treated as a supply of goods or services where:

• • goods forming part of the assets of a business are transferred or disposed of by or under the directions of the person carrying on the business so as no longer to form part of those assets
  • by or under the direction of a person carrying on a business, goods held or used for the purposes of the business are put to any private use or are used, or made available to any person for use, for any purpose other than a purpose of the business

The proposed amendment seeks to exclude the transfer of assets in the above state scenarios from the scope of Schedule II, when such transfers are made without a consideration. It is noteworthy, that as per Section 7 of the CGST Act, only the transactions specified in Schedule I are treated as supply even if made without consideration.

1. Proposed retrospective exemption from, or levy or collection of, central tax in following cases:

Heading	Description	E x i s t i n g Rate	R e v i s e d Rate	Effective Date
2301	supply of fishmeal	2.5%	Nil	1st day of July, 2017 and ending with the 30th day of September, 2019 (both days inclusive)
8483	supply of pulley, wheels and other parts	14%	6%	1st day of July, 2017 and ending with the 31stday of December, 2018 (both days inclusive).
8432, 8433 and 8436	used as parts of agricul tural machinery	14%	6%

Further, it is proposed that no refund shall be provided which has been collected in respect of said goods.

1. Proposed amendment to give retrospective effect to notification of the Government of India in the Ministry of Finance (Department of Revenue) number G.S.R. 708(E), dated the 30th September, 2019 issued under clause (ii) of proviso to subsection (3) of section 54 of the CGST Act.

The notification sought to disallow the refund of compensation cess in case of inverted duty structure for tobacco and manufactured tobacco substitutes. The proposed amendment seeks to give retrospective effect to the notification.

 

1. Proposed amendment to the proviso of Section 25 (1), for substitution of the words “three years” with the words “five years”.

Section 25 authorises the Central government, on recommendation of the GST Council, to issue removal of difficulty orders with regard to any provisions relating to any provisions of the Integrated and Goods Services Tax Act (hereinafter referred toa as IGST Act). Such orders can, however, not be issued after the expiry of three years from the commencement of the IGST Act.

It has now been proposed, to allow the Central Government to issue such orders upto the expiry of five years from the commencement of the IGST act.

1. Proposed retrospective exemption from, or levy or collection of, integrated tax in following cases:

Integrated Goods and Services Tax

Heading	Description	E x i s t i n g Rate	R e v i s e d Rate	Effective Date
2301	supply of fishmeal	5%	Nil	1st day of July, 2017 and ending with the 30th day of September, 2019 (both days inclusive)
8483	supply of pulley, wheels and other parts	28%	12%	1st day of July, 2017 and ending with the 31stday of December, 2018 (both days inclusive).
8432, 8433 and 8436	used as parts of agricul tural machinery	28%	12%

Further, it is proposed that no refund shall be provided which has been collected in respect of said goods.

Union Territory Goods and Services Tax

1. Proposed amendment to the Section 1 (2) of the Union Territory Goods and Services Tax Act, 2017 (hereinafter referred to as ‘the UTGST Act’) which defines the scope of this Act. The proposed amendment seeks to include the new formed Union Territory of Ladakh within the purview of the UTGST Act.
2. Proposed amendment to the Section 2 (8) of the the UTGST Act, which defines “Union Territory”. The proposed amendment seeks to include the new formed Union Territory of Ladakh within the purview of the UTGST Act.
3. Proposed amendment to the proviso of Section 26 (1), for substitution of the words “three years” with the words “five years”.

Section 26 authorises the Central government, on recommendation of the GST Council, to issue removal of difficulty orders with regard to any provisions relating to any provisions of the UTGST Act. Such orders can, however, not be issued after the expiry of three years from the commencement of the UTGST Act.

It has now been proposed, to allow the Central Government to issue such orders upto the expiry of five years from the commencement of the UTGST act.

1. Proposed retrospective exemption from, or levy or collection of, integrated tax in following cases:

 

Further, it is proposed that no refund shall be provided which has been collected in respect of said goods.

Goods and Services Tax (Compensation to States) Act, 2017

103. As per the Goods and Services Tax (Compensation to States) Act, 2017 law, the Centre compensates the states to ensure that their revenue during the transition period, is protected at the level of 14% over the base tax collection in 2015-16.

Section14 of this act, authorises the Central government, on recommendation of the GST Council, to issue removal of difficulty orders with regard to any provisions relating the compensation to states during the transition period. Such orders can, however, not be issued after the expiry of three years from the commencement of this act.

It has now been proposed, to allow the Central Government to issue such orders upto the expiry of five years from the commencement of this act.

Heading	Description	E x i s t i n g Rate	R e v i s e d Rate	Effective Date
2301	supply of fishmeal	2.5%	Nil	1st day of July, 2017 and ending with the 30th day of September, 2019 (both days inclusive)
8483	supply of pulley, wheels and other parts	14%	6%	1st day of July, 2017 and ending with the 31stday of December, 2018 (both days inclusive).
8432, 8433 and 8436	used as parts of agricul tural machinery	14%	6%

1. Proposed levy of health cess @ 5% as duty of customs on import of medical equipment’s. The goods proposed to be in scope of this levy are:

• Instruments and appliances used in medical, surgical, dental or veterinary sciences, including scientigraphic apparatus, other electromedical apparatus and sight-testing instruments [Heading 9018 of the First Schedule to CTA]
• Mechano-therapy appliances; massage apparatus; psychological aptitude-testing apparatus; ozone therapy, oxygen therapy, aerosol therapy, artificial respiration or other therapeutic respiration apparatus [Heading 9019 of the First Schedule to CTA]
• Other breathing appliances and gas masks, excluding protective masks having neither mechanical parts and replaceable filters [Heading 9020 of the First Schedule to CTA]
• Orthopaedic appliances, including crutches, surgical belts and trusses; splints and other fracture appliances; artificial parts of the body; hearing aids and other appliances which are worn or carried, or implanted in the body, to compensate for a defect or disability [Heading 9021 of the First Schedule to CTA]
• Apparatus based on the use of X-rays or of alpha, beta or gamma radiations, whether or not for medical, surgical, dental or veterinary uses, including radiography or radiotherapy apparatus, X-ray tubes and other X- ray generators, high tension generators, control panels and desks, screens, examination or treatment tables, chairs and the like [Heading 9022 of the First Schedule to CTA]

The Indian Stamp Act, 1899

1. Insertion of Proviso to sub-section 2 of section 9A of the Indian Stamp Act, 1899 (hereafter in this referred to as ‘the Stamp Act’), which deals with “Instruments chargeable with duty for transactions in stock exchanges and depositories”.

 

Presently, any transaction in securities i.e. issue, sale or transfer of securities, whether through stock exchange or depository, is chargeable to stamp duty as per rate provided in Schedule I of the Stamp Act and such instruments needs not to be stamped.

The proposed amendment has been made to provide exemption from stamp duty in respect of instruments of transaction in stock exchanges and depositories established in any International Financial Services Centre set up under section 18 of the Special Economic Zones Act, 2005.

1. Proposed insertion of new Section 73B pertaining to “Power to issue directions and authorise certain authorities to issue instructions, circulars and guidelines”.

It has been proposed to give powers to the Central Government to issue directions and to authorise SEBI or RBI to issue instructions, circulars or guidelines for carrying out the provisions of Part AA of Chapter II of the act. i.e. instruments chargeable to stamp duty.

1. The above stated amendments to the Stamp Act have been proposed to be effective 1 April 2020.

The Prohibition of Benami Property Transactions Act, 1988

1. Proposed substitution of Section 9 (1) (b) which deals with the ‘Qualifications for appointment of Chairperson and Members’ of the adjudication authority under the act, effective 1 April 2020.

As per proposed amendment, a person, if he is qualified for appointment as District Judge, can also be appointed as Chairperson or Member of the adjudicating authority.

The Election Commission (Conditions of Service of Election Commissioners and Transaction of Business) Act, 1991

1. Proposed amendment to Section 8, which deals with ‘Other conditions of service’ for Election Commissioners, effective 1 April 2021.

Currently, the income-tax exemptions on the value of rent-free residence, conveyance facilities, sumptuary allowance, medical facilities and other such conditions of services, as are applicable to Judge of the Supreme Court under Chapter IV of the Supreme Court Judges (Conditions of Service) Act, 1958 and the rules made there under, are also extended to the Election Commissioners.

It has now been proposed to amend the said section so as to do away with this the income-tax exemption as applicable to the Chief Election Commissioner and other Election Commissioners.

First Schedule to the Central Excise Tariff Act, 1985

1.  Following is a summary of the proposed revised rates of Excise duty in respect of the tobacco and petroleum products:

Tariff Item	Description of goods	Unit	Rate of duty
2402 20 10	Other than filter cigarettes, of length not exceeding 65 millimetres	Tu	R s . 2 0 0 thousand	p e r
2402 20 20	Other than filter cigarettes, of length exceeding 65 millimetres but not exceeding 70 millimetres	Tu	R s . 2 5 0 thousand	p e r
2402 20 30	Filter cigarettes of length (including the length of the filter, the length of filter being 11 millimetres or its actual length, whichever is more) not exceeding 65 millimetres	Tu	R s . 4 4 0 thousand	p e r
2402 20 40	Filter cigarettes of length (including the length of the filter, the length of filter being 11 millimetres or its actual length, whichever is more) exceeding 65 millimetres but not exceeding 70 millimetres	Tu	R s . 4 4 0 thousand	p e r
2402 20 50	Filter cigarettes of length (including the length of the filter, the length of filter being 11 millimetres or its actual length, whichever is more) exceeding 70 millimetres but not exceeding 75 millimetres	Tu	R s . 5 4 5 thousand	p e r
2402 20 90	Other	Tu	R s . 7 3 5 thousand	p e r
2402 90 10	Cigarettes of tobacco substitutes	Tu	R s . 6 0 0 thousand	p e r
2403 11 10	Hookah or gudaku tobacco	Kg	25%
2403 19 10	Smoking mixtures for pipes and cigarettes	Kg	60%
2403 19 21	Other than paper rolled biris, manufactured without the aid of machine	Tu	R s . 1 . 0 0 thousand	p e r
2403 19 29	Other	Tu	R s . 2 . 0 0 thousand	p e r
2403 19 90	Other	kg.	25%
2403 91 00	“Homogenised” or “reconstituted” tobacco	kg.	25%
2403 99 10	Chewing tobacco	kg.	25%

Tariff Item	Description of goods	Unit	Rate of duty
2403 99 20	Preparations containing chewing tobacco	Kg.	25%
2403 99 30	Jarda scented tobacco	kg.	25%
2403 99 40	Snuff	kg.	25%
2403 99 50	Preparations containing snuff	kg.	25%
2403 99 60	Tobacco extracts and essence	kg.	25%
2403 99 90	Other	kg.	25%
2709 20 00	Petroleum crude	kg.	Rs. 50 per tonne

 

 

W S & Associates LLP. is a Chartered Accountancy firm, rendering comprehensive professional services which include Tax Consultancy – International and Domestic, Valuation, Advisory on issues covered under Double Taxation Avoidance Agreements, Expat Taxation, Audit, Management Consultancy, Accounting Services, Secretarial services etc.

W S & Associates LLP. is a professionally managed firm. The team consists of distinguished chartered accountants, corporate financial advisors and tax consultants. The firm represents a combination of specialized skills, which are geared to offer sound financial advice and personalized proactive services. Those associated with the firm have regular interaction with industry and other professionals which enables the firm to keep pace with contemporary developments and to meet the needs of its clients.

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