The document provides details about India's Undisclosed Foreign Income and Assets Compliance Window. It summarizes the key aspects of the one-time compliance procedure and UFIA Act, including a 30% tax rate on undisclosed foreign assets and income, computation of tax, and assessment procedures. No deductions or exemptions are allowed and penalties of up to 300% of tax can be imposed. The compliance window allows declaring foreign assets by September 2015 with tax payment by December 2015 at a total rate of 60% to avoid prosecution.
Black money compliance window & Blank Money Act AnalysisAshwani Rastogi
The document provides details about India's Undisclosed Foreign Income and Assets Compliance Window. It summarizes the key aspects of the one-time compliance procedure and UFIA Act, including a 30% tax rate on undisclosed foreign assets and income, computation of tax, and assessment procedures. No deductions or exemptions are allowed and penalties of up to 300% of tax can be imposed. The compliance window allows declaring foreign assets by September 30, 2015 and paying tax by December 31, 2015 at a total rate of 60% to avoid prosecution.
Presentation on investment and taxation of NRI - Special privileges Sanjay Agrawal
The document discusses various definitions and concepts related to NRIs under FEMA and Income Tax Act including:
- Definitions of NRI, PIO, OCI, PRI, PROI under FEMA and their meanings.
- Legal framework of FEMA governing NRI investments including relevant regulations.
- Definitions of person, resident, non-resident under Income Tax Act and their tax treatment.
- Special privileges and exemptions available to NRIs under the Income Tax Act for various types of incomes like salary, house property, capital gains etc. as well as relief under double taxation avoidance agreements.
This document discusses taxation provisions for non-resident Indians (NRIs). It defines an NRI as an individual who is a citizen of India or person of Indian origin who is not a resident as per the Income Tax Act. Residential status is important for determining the scope of income taxable and availability of tax concessions. For NRIs, income earned in India from employment, house property, capital gains and other sources is taxable in India. Special provisions provide preferential tax rates for investment income and long-term capital gains from specified foreign exchange assets if reinvested in India. To claim relief under double taxation avoidance agreements, NRIs must obtain a tax residency certificate from their country of residence.
The document discusses provisions related to non-residents under Indian law. It defines a non-resident individual as an Indian citizen who stays abroad for employment, business, vacation or uncertain duration. It also considers persons posted in UN organizations and on foreign assignments as non-residents. Further, it discusses tax rates and exemptions applicable to different types of investment and other income earned by non-residents.
AGRICULTURAL INCOME
Sec.10(1) exempts Agricultural Income from Income-Tax. Bu virtue of Sec.2(1)a the expression “Agricultural Income” means : •Any Rent or Revenue derived from Land which is situated in India and is used for
agricultural purposes. [Sec. 2(1A)(a)] •Any income derived from such land : Use for Agricultural purposes ; or Used for agricultural operations means- irrigating and harvesting , sowing, weeding, digging, cutting etc. It involves employment of some human skill, labour and energy to get some income from land Condition-1 : Income derived from Land
Condition-2 : Land is used for Agricultural Purposes
Condition-3 : Land is situated in India
A Person can be Resident (R) or Non Resident (NR) under both FEMA & I. Tax Acts
A Person can be Resident under one of the Acts & Non Resident under the another
Section 2(v) of FEMA
Section 6 of the ITA, 1961
This document discusses the incidence of tax on individuals and other taxpayers based on their residential status and where their income is received or accrued. It defines Indian income and foreign income and outlines which types of income are taxable in India for residents and ordinarily residents, residents but not ordinarily residents, and non-residents. Examples are also provided to illustrate how to calculate total income based on residential status and income details.
This document provides an overview of income tax law in India. It discusses the key constituents of income tax law including the Income Tax Act of 1961, Income Tax Rules of 1962, circulars, notifications, judicial decisions and more. It also covers topics like residential status, previous year, assessment year, and types of income that are taxable according to residential status.
Black money compliance window & Blank Money Act AnalysisAshwani Rastogi
The document provides details about India's Undisclosed Foreign Income and Assets Compliance Window. It summarizes the key aspects of the one-time compliance procedure and UFIA Act, including a 30% tax rate on undisclosed foreign assets and income, computation of tax, and assessment procedures. No deductions or exemptions are allowed and penalties of up to 300% of tax can be imposed. The compliance window allows declaring foreign assets by September 30, 2015 and paying tax by December 31, 2015 at a total rate of 60% to avoid prosecution.
Presentation on investment and taxation of NRI - Special privileges Sanjay Agrawal
The document discusses various definitions and concepts related to NRIs under FEMA and Income Tax Act including:
- Definitions of NRI, PIO, OCI, PRI, PROI under FEMA and their meanings.
- Legal framework of FEMA governing NRI investments including relevant regulations.
- Definitions of person, resident, non-resident under Income Tax Act and their tax treatment.
- Special privileges and exemptions available to NRIs under the Income Tax Act for various types of incomes like salary, house property, capital gains etc. as well as relief under double taxation avoidance agreements.
This document discusses taxation provisions for non-resident Indians (NRIs). It defines an NRI as an individual who is a citizen of India or person of Indian origin who is not a resident as per the Income Tax Act. Residential status is important for determining the scope of income taxable and availability of tax concessions. For NRIs, income earned in India from employment, house property, capital gains and other sources is taxable in India. Special provisions provide preferential tax rates for investment income and long-term capital gains from specified foreign exchange assets if reinvested in India. To claim relief under double taxation avoidance agreements, NRIs must obtain a tax residency certificate from their country of residence.
The document discusses provisions related to non-residents under Indian law. It defines a non-resident individual as an Indian citizen who stays abroad for employment, business, vacation or uncertain duration. It also considers persons posted in UN organizations and on foreign assignments as non-residents. Further, it discusses tax rates and exemptions applicable to different types of investment and other income earned by non-residents.
AGRICULTURAL INCOME
Sec.10(1) exempts Agricultural Income from Income-Tax. Bu virtue of Sec.2(1)a the expression “Agricultural Income” means : •Any Rent or Revenue derived from Land which is situated in India and is used for
agricultural purposes. [Sec. 2(1A)(a)] •Any income derived from such land : Use for Agricultural purposes ; or Used for agricultural operations means- irrigating and harvesting , sowing, weeding, digging, cutting etc. It involves employment of some human skill, labour and energy to get some income from land Condition-1 : Income derived from Land
Condition-2 : Land is used for Agricultural Purposes
Condition-3 : Land is situated in India
A Person can be Resident (R) or Non Resident (NR) under both FEMA & I. Tax Acts
A Person can be Resident under one of the Acts & Non Resident under the another
Section 2(v) of FEMA
Section 6 of the ITA, 1961
This document discusses the incidence of tax on individuals and other taxpayers based on their residential status and where their income is received or accrued. It defines Indian income and foreign income and outlines which types of income are taxable in India for residents and ordinarily residents, residents but not ordinarily residents, and non-residents. Examples are also provided to illustrate how to calculate total income based on residential status and income details.
This document provides an overview of income tax law in India. It discusses the key constituents of income tax law including the Income Tax Act of 1961, Income Tax Rules of 1962, circulars, notifications, judicial decisions and more. It also covers topics like residential status, previous year, assessment year, and types of income that are taxable according to residential status.
Tax Bulletin Draft Notification on POEM - Section 115JH of the ActVispi T. Patel
The CBDT has issued a Draft Notification issued on June 15, 2017 for exception, modification and adaptation in respect of a foreign company said to be resident in India due to its place of effective management (POEM) being in India, under Section 115JH of the Income-tax Act, 1961.
This document discusses income tax in India. It notes that personal and corporate income taxes are major sources of central government revenue. Income tax law in India is governed by the Income Tax Act of 1961 and applies to individuals, Hindu Undivided Families, companies, and other persons and entities. Income is categorized into several heads such as salary, house property, business/profession, capital gains, and other sources, and tax rates vary based on residential status and income level.
The document discusses residential status and the scope of total income under the Indian Income Tax Act. It defines the three categories of residential status as resident but not ordinarily resident, resident and ordinarily resident, and non-resident. An individual's residential status is determined based on the number of days spent in India in the relevant financial year and previous years. If the conditions of 182 days in a year or 60 days in the current year plus 365 days in the last 4 years are met, the individual is considered a resident. Exceptions to this rule are provided for citizens working abroad or visiting India. The document further explains how to classify a resident as ordinarily resident or non-ordinarily resident and the tax treatment based on residential status.
The document provides an overview of a basic course on the Foreign Exchange Management Act (FEMA) and taxation of foreign remittances presented by Mr. Paresh P. Shah. It discusses key topics that will be covered in the course including an overview of FEMA, important definitions, fundamentals of FEMA, current account transactions, capital account transactions, foreign direct investment in India, overseas direct investments, immovable property in India, exports and imports. It also lists various abbreviations commonly used and provides summaries of some key sections of FEMA related to dealing in foreign exchange, holding foreign exchange, current account transactions and capital account transactions.
The document discusses residential status under Indian income tax law and foreign exchange regulations. It defines resident, non-resident, and ordinarily resident status and the tests to determine each. It also outlines the scope of income that is taxable in India for residents and non-residents based on their residential status. Finally, it provides background on the author and her experience in foreign exchange, taxation, and international transactions matters.
This document discusses the different income tax return (ITR) forms in India and who can use each form. ITR-1 can be used by individuals with income from salary, one house property, and other sources. ITR-2 can be used by individuals with income from salary, house property, capital gains, and other sources. ITR-4 can be used by individuals with business/profession income. ITR-4S can be used by small businesses and individuals with certain income. ITR-5 is for firms, AOPs, and BOIs. ITR-6 is for companies. ITR-7 is for charitable trusts, political parties, certain institutions, and scientific research universities.
- Payment of salary to a non-resident director for services rendered outside of India is not considered income that accrues or arises in India, or deemed received in India, and is thus not taxable in India.
- Under FEMA, payment of remuneration to a director would be classified as a current account transaction, allowed without restrictions.
- A company can remit up to $250,000 annually without approval under India's Liberalized Remittance Scheme for current account transactions.
The document summarizes changes made to India's income tax provisions for the 2013-14 fiscal year that affect salaried individuals. Key points include:
1) Income tax rates remain unchanged, but a 5% surcharge is introduced for domestic companies with income over 1 crore rupees.
2) A rebate of 2000 rupees is provided for individuals with total income up to 5 lakh rupees.
3) A new section 80EE provides a deduction for interest on home loans sanctioned from April 2013 to March 2014, up to 1 lakh rupees.
4) The limit for deductible life insurance premium is raised to 15% of sum assured for
Mr. Paresh P. Shah presented on the taxation of non-residents in India. He discussed the need and rationale for taxing non-residents based on their connection to the country. He defined resident and non-resident status under the Foreign Exchange Management Act and Income Tax Act and compared the definitions. He then covered topics such as determining residential status, the scope of taxation for non-residents under the Income Tax Act, income deemed to accrue or arise in India, and the source rule for income such as royalties and fees for technical services. The presentation provided an overview of the key considerations and rules for taxing non-residents in India.
Need & the Rationale
Definition of Non Resident under Foreign Exchange Management Act, 1999 (FEMA) & Income Tax Act, 1961 (ITA)
FEMA & ITA compared
Non Resident taxation
Computation of Income
Minimum Alternate Tax for foreign company
Exemptions to non-residents
Tax Deduction at Source
Wealth Tax & Gift Tax
Tax proposals in Finance Act, 2013 – Amendments & GAAR
Questions & Answers
This document provides an overview of taxation of non-residents in India. It defines non-residents under the Foreign Exchange Management Act and Income Tax Act and compares the definitions. It discusses the taxation of various types of income for non-residents such as business income, salaries, dividends, interest, royalties and fees for technical services based on the source rule. It also covers computation of income, exemptions, tax deduction at source, impact of tax treaties, and recent amendments introduced in the Finance Bill 2012.
Why does India need FDI, How will FDI benefit us, What will be the disadvantages? Read everything you wanted to know about Foreign Direct Investment and the role played by Foreign Exchange Management Act, in this Research Report from Resurgent India
Returning NRIs face important tax and regulatory considerations when returning to India permanently. As residents, their global income and assets will be subject to Indian laws. NRIs have preferential tax status for some years if they have lived abroad for long periods. They can retain foreign investments but must convert foreign bank accounts to Indian resident status. Comprehensive financial and tax planning is needed to smoothly transition an NRI's financial affairs to Indian regulatory compliance.
This document provides an overview and introduction to the Foreign Exchange Management Act (FEMA) presented by Mr. Paresh P. Shah.
It begins with an overview of FEMA, including its objectives to facilitate external trade and payments and promote an orderly foreign exchange market. It discusses key sections of FEMA and amendments made by the Finance Act of 2015. It then defines important terms under FEMA such as capital account transactions, current account transactions, resident in India, and resident outside India.
The document also summarizes the fundamentals of FEMA, including that foreign exchange belongs to the Government of India except with permission, and that dealing in foreign exchange by residents in India and outside India is regulated. It highlights sections
The Foreign Exchange Management Act (FEMA) was enacted in 1999 to consolidate and amend the laws governing foreign exchange in India. It aims to facilitate external trade and payments and promote an orderly foreign exchange market. FEMA regulates inbound and outbound investments between India and other countries. It provides for RBI control over capital account transactions, realization of export proceeds through authorized dealers, and adjudication of offenses. FEMA replaced the more restrictive Foreign Exchange Regulation Act of 1973 and liberalized foreign exchange controls to align with India's emerging pro-liberalization policies.
Fast track notes on income tax.Total Tax With maximum Effective Question'sEducation At The Edge
The Income-tax Act, 1961,Income under the head
salary,Income under the head house property,
Income under the head business and profession,
Income under the head capital gains,
Income under the head other sources,Revenue Vs Capital, RESIDENTIAL STATUS,CALCULATION OF INCOME TAX,CLUBBING OF INCOMES,SET OFF & CARRY FORWARD OF LOSSES,INCOME FROM AGRICULTURE,DEDUCTIONS FROM GTI,EXEMPTED INCOMES,ASSESSMENT PROCEDURE,ADVANCE TAX AND INTEREST PAYABLE ,TAX DEDUCTED AT SOURCE,CHARITABLE OR RELIGIOUS TRUSTS,SERVICE TAX,VALUE ADDED TAX (VAT),
This document provides an overview of a basic course on the Foreign Exchange Management Act (FEMA) and taxation of foreign remittances presented by Mr. Paresh P. Shah. It outlines the key topics to be covered including definitions under FEMA, fundamentals of FEMA such as restrictions on dealings in foreign exchange, holdings of foreign assets, and capital account transactions. It also lists some important sections of FEMA and provides brief explanations. The document serves as an agenda or program for the course that will educate participants on FEMA regulations and their implications.
- The residential status of an individual or entity determines whether income earned inside or outside India is taxable in India.
- There are different residential statuses for individuals/HUFs and other entities like firms. For individuals, the statuses are resident and ordinarily resident, resident but not ordinarily resident, and non-resident.
- Determining the residential status involves assessing whether basic or additional conditions are met based on the number of days spent in India in the relevant period. Meeting these conditions establishes whether one is a resident and ordinarily resident, or resident but not ordinarily resident.
Este menú ofrece una variedad de opciones para el almuerzo y la cena, incluyendo ensaladas, guisos, pescados y carnes, acompañados de pan y bebidas. Los postres incluyen flanes, tartas, helados y fruta. Los precios varían desde 6.50€ para un plato único hasta 26€ para el menú completo con vino y postre.
1) The document discusses the aims and objectives of teaching English in India. It states that the main aim is to help students acquire practical command of the English language through listening, speaking, reading and writing.
2) It defines objectives as desired goals of instruction and lists characteristics of good objectives like being precise, based on psychology, and focusing on changing student behavior.
3) The main objectives of teaching English are described as language development and literary development, with the focus differing by class and age of students. Developing abilities in understanding, speaking, reading and writing English are also objectives.
Tax Bulletin Draft Notification on POEM - Section 115JH of the ActVispi T. Patel
The CBDT has issued a Draft Notification issued on June 15, 2017 for exception, modification and adaptation in respect of a foreign company said to be resident in India due to its place of effective management (POEM) being in India, under Section 115JH of the Income-tax Act, 1961.
This document discusses income tax in India. It notes that personal and corporate income taxes are major sources of central government revenue. Income tax law in India is governed by the Income Tax Act of 1961 and applies to individuals, Hindu Undivided Families, companies, and other persons and entities. Income is categorized into several heads such as salary, house property, business/profession, capital gains, and other sources, and tax rates vary based on residential status and income level.
The document discusses residential status and the scope of total income under the Indian Income Tax Act. It defines the three categories of residential status as resident but not ordinarily resident, resident and ordinarily resident, and non-resident. An individual's residential status is determined based on the number of days spent in India in the relevant financial year and previous years. If the conditions of 182 days in a year or 60 days in the current year plus 365 days in the last 4 years are met, the individual is considered a resident. Exceptions to this rule are provided for citizens working abroad or visiting India. The document further explains how to classify a resident as ordinarily resident or non-ordinarily resident and the tax treatment based on residential status.
The document provides an overview of a basic course on the Foreign Exchange Management Act (FEMA) and taxation of foreign remittances presented by Mr. Paresh P. Shah. It discusses key topics that will be covered in the course including an overview of FEMA, important definitions, fundamentals of FEMA, current account transactions, capital account transactions, foreign direct investment in India, overseas direct investments, immovable property in India, exports and imports. It also lists various abbreviations commonly used and provides summaries of some key sections of FEMA related to dealing in foreign exchange, holding foreign exchange, current account transactions and capital account transactions.
The document discusses residential status under Indian income tax law and foreign exchange regulations. It defines resident, non-resident, and ordinarily resident status and the tests to determine each. It also outlines the scope of income that is taxable in India for residents and non-residents based on their residential status. Finally, it provides background on the author and her experience in foreign exchange, taxation, and international transactions matters.
This document discusses the different income tax return (ITR) forms in India and who can use each form. ITR-1 can be used by individuals with income from salary, one house property, and other sources. ITR-2 can be used by individuals with income from salary, house property, capital gains, and other sources. ITR-4 can be used by individuals with business/profession income. ITR-4S can be used by small businesses and individuals with certain income. ITR-5 is for firms, AOPs, and BOIs. ITR-6 is for companies. ITR-7 is for charitable trusts, political parties, certain institutions, and scientific research universities.
- Payment of salary to a non-resident director for services rendered outside of India is not considered income that accrues or arises in India, or deemed received in India, and is thus not taxable in India.
- Under FEMA, payment of remuneration to a director would be classified as a current account transaction, allowed without restrictions.
- A company can remit up to $250,000 annually without approval under India's Liberalized Remittance Scheme for current account transactions.
The document summarizes changes made to India's income tax provisions for the 2013-14 fiscal year that affect salaried individuals. Key points include:
1) Income tax rates remain unchanged, but a 5% surcharge is introduced for domestic companies with income over 1 crore rupees.
2) A rebate of 2000 rupees is provided for individuals with total income up to 5 lakh rupees.
3) A new section 80EE provides a deduction for interest on home loans sanctioned from April 2013 to March 2014, up to 1 lakh rupees.
4) The limit for deductible life insurance premium is raised to 15% of sum assured for
Mr. Paresh P. Shah presented on the taxation of non-residents in India. He discussed the need and rationale for taxing non-residents based on their connection to the country. He defined resident and non-resident status under the Foreign Exchange Management Act and Income Tax Act and compared the definitions. He then covered topics such as determining residential status, the scope of taxation for non-residents under the Income Tax Act, income deemed to accrue or arise in India, and the source rule for income such as royalties and fees for technical services. The presentation provided an overview of the key considerations and rules for taxing non-residents in India.
Need & the Rationale
Definition of Non Resident under Foreign Exchange Management Act, 1999 (FEMA) & Income Tax Act, 1961 (ITA)
FEMA & ITA compared
Non Resident taxation
Computation of Income
Minimum Alternate Tax for foreign company
Exemptions to non-residents
Tax Deduction at Source
Wealth Tax & Gift Tax
Tax proposals in Finance Act, 2013 – Amendments & GAAR
Questions & Answers
This document provides an overview of taxation of non-residents in India. It defines non-residents under the Foreign Exchange Management Act and Income Tax Act and compares the definitions. It discusses the taxation of various types of income for non-residents such as business income, salaries, dividends, interest, royalties and fees for technical services based on the source rule. It also covers computation of income, exemptions, tax deduction at source, impact of tax treaties, and recent amendments introduced in the Finance Bill 2012.
Why does India need FDI, How will FDI benefit us, What will be the disadvantages? Read everything you wanted to know about Foreign Direct Investment and the role played by Foreign Exchange Management Act, in this Research Report from Resurgent India
Returning NRIs face important tax and regulatory considerations when returning to India permanently. As residents, their global income and assets will be subject to Indian laws. NRIs have preferential tax status for some years if they have lived abroad for long periods. They can retain foreign investments but must convert foreign bank accounts to Indian resident status. Comprehensive financial and tax planning is needed to smoothly transition an NRI's financial affairs to Indian regulatory compliance.
This document provides an overview and introduction to the Foreign Exchange Management Act (FEMA) presented by Mr. Paresh P. Shah.
It begins with an overview of FEMA, including its objectives to facilitate external trade and payments and promote an orderly foreign exchange market. It discusses key sections of FEMA and amendments made by the Finance Act of 2015. It then defines important terms under FEMA such as capital account transactions, current account transactions, resident in India, and resident outside India.
The document also summarizes the fundamentals of FEMA, including that foreign exchange belongs to the Government of India except with permission, and that dealing in foreign exchange by residents in India and outside India is regulated. It highlights sections
The Foreign Exchange Management Act (FEMA) was enacted in 1999 to consolidate and amend the laws governing foreign exchange in India. It aims to facilitate external trade and payments and promote an orderly foreign exchange market. FEMA regulates inbound and outbound investments between India and other countries. It provides for RBI control over capital account transactions, realization of export proceeds through authorized dealers, and adjudication of offenses. FEMA replaced the more restrictive Foreign Exchange Regulation Act of 1973 and liberalized foreign exchange controls to align with India's emerging pro-liberalization policies.
Fast track notes on income tax.Total Tax With maximum Effective Question'sEducation At The Edge
The Income-tax Act, 1961,Income under the head
salary,Income under the head house property,
Income under the head business and profession,
Income under the head capital gains,
Income under the head other sources,Revenue Vs Capital, RESIDENTIAL STATUS,CALCULATION OF INCOME TAX,CLUBBING OF INCOMES,SET OFF & CARRY FORWARD OF LOSSES,INCOME FROM AGRICULTURE,DEDUCTIONS FROM GTI,EXEMPTED INCOMES,ASSESSMENT PROCEDURE,ADVANCE TAX AND INTEREST PAYABLE ,TAX DEDUCTED AT SOURCE,CHARITABLE OR RELIGIOUS TRUSTS,SERVICE TAX,VALUE ADDED TAX (VAT),
This document provides an overview of a basic course on the Foreign Exchange Management Act (FEMA) and taxation of foreign remittances presented by Mr. Paresh P. Shah. It outlines the key topics to be covered including definitions under FEMA, fundamentals of FEMA such as restrictions on dealings in foreign exchange, holdings of foreign assets, and capital account transactions. It also lists some important sections of FEMA and provides brief explanations. The document serves as an agenda or program for the course that will educate participants on FEMA regulations and their implications.
- The residential status of an individual or entity determines whether income earned inside or outside India is taxable in India.
- There are different residential statuses for individuals/HUFs and other entities like firms. For individuals, the statuses are resident and ordinarily resident, resident but not ordinarily resident, and non-resident.
- Determining the residential status involves assessing whether basic or additional conditions are met based on the number of days spent in India in the relevant period. Meeting these conditions establishes whether one is a resident and ordinarily resident, or resident but not ordinarily resident.
Este menú ofrece una variedad de opciones para el almuerzo y la cena, incluyendo ensaladas, guisos, pescados y carnes, acompañados de pan y bebidas. Los postres incluyen flanes, tartas, helados y fruta. Los precios varían desde 6.50€ para un plato único hasta 26€ para el menú completo con vino y postre.
1) The document discusses the aims and objectives of teaching English in India. It states that the main aim is to help students acquire practical command of the English language through listening, speaking, reading and writing.
2) It defines objectives as desired goals of instruction and lists characteristics of good objectives like being precise, based on psychology, and focusing on changing student behavior.
3) The main objectives of teaching English are described as language development and literary development, with the focus differing by class and age of students. Developing abilities in understanding, speaking, reading and writing English are also objectives.
OPS 571 Final Exam
1) __________ is when the activities in the stage must stop because there is no place to deposit the item just completed
A. Buffering
B. Blocking
C. Starving
D. Pacing
2) According to your text, the most common process metric is
A. productivity
B. efficiency
C. utilization
D. throughput time
3) Declining product prices
A. increase the manufacturing costs
B. lower the break-point
C. result in lower manufacturing costs
D. increase the break-even point
4) The type of processing structure that is used for producing discrete products at a controlled rate is
A. job shop
B. batch
C. assembly line
D. project
5) The best process flow structure to use for making automobiles is
A. job shop
B. batch shop
C. group technology cell
D. assembly line
6) The break-even analysis is a standard approach to determine alternative processes A break-even analysis chart usually present alternati
1) Shane discovers his friend Jerry dead in the forest after hearing his screams. He sees a dark figure standing nearby.
2) Weeks later, Shane is having nightmares and refuses to go to counseling. He zones out while walking and has a near miss with a car.
3) At counseling, Shane reveals that he saw who killed Jerry but does not provide details before his father interrupts the session. The story implies that Shane discovers evidence that his father was the one who killed Jerry.
The document analyzes various design elements of a magazine cover called 'Q'. It discusses how the use of the artist's first name makes the audience feel more connected. It also notes several unconventional design choices, like placing the main image in the top third instead of splitting it evenly. Overall, the analysis examines how the layout, images, and stylistic choices come together to create a unique and appealing design for the magazine's target rock music audience.
Cindy Erickson is an experienced marketing communications professional with over 15 years of experience leading teams and managing projects from concept to completion. She has worked in various industries including insurance, food, and equipment protection. Her background includes expertise in public relations, branding, advertising, and event planning. She currently works as a Global Manager for Pentair leading an international marketing communications team.
The document discusses selecting an image for the front cover of a magazine. It notes that the images created so far have an indie style rather than a "pop picture" look desired for the cover. While few images are available now, more will be created that resemble typical pop magazine cover photos with celebrities smiling or making funny faces to look less professional. The document also lists some potential magazine cover taglines or "straplines" focusing on music celebrities.
This document summarizes the results of a knife crime survey of over 5,000 students in West Yorkshire. Key findings include:
- Slightly over 50% of students believed media coverage of knife crime is inaccurate.
- Over 50% felt media coverage does not affect them personally.
- Students saw a strong connection between knife crime and TV/films but not music.
- Around 25% had carried a knife at some point, usually for legitimate reasons like cooking.
- Around 1 in 50 students reported regularly carrying a knife, usually citing protection as the reason.
- 1 in 4 students knew someone who carries a knife.
- 1 in 3 students reported worrying about local knife crime and the
This document provides an overview of restorative justice and restorative practices. It discusses:
1. The differences between restorative practice, which aims to build relationships proactively, and restorative justice, which repairs relationships reactively following harm.
2. A range of restorative practices like circles, questions, and conferences that can be used proactively or reactively.
3. The development of restorative justice as an alternative to punitive criminal justice systems that view crimes as offenses against society rather than individuals. Restorative approaches seek to involve victims and negotiate restitution.
IPC media is a large publishing company founded in the UK in 1968 that owns over 60 brands accessible across magazines, online, mobile and tablets. It publishes the popular music magazine NME. Bauer media group owns successful music magazines like Kerrang! and Mojo and reaches 22 million people across over 107 brands. EMAP publishing was founded in 1947 and publishes 17 magazines but none related to music. Development Hell Ltd publishes the 33-year old music magazine Mixmag focused on house music but has no website. The document concludes IPC media would be the best publisher for a new music magazine due to its wide platform reach and NME's similar audience.
The document is a presentation on emerging food technologies from the University of Sri Jayewardabepura. It discusses ultrasound technology, providing background information and definitions. The fundamental theory of ultrasound is explained, noting how it generates longitudinal waves and cavitation. Applications of ultrasound in food science and technology are outlined, such as inactivation of microorganisms, extraction, freezing, and increasing the efficiency of unit operations. Advantages include producing products with fewer additives and higher quality, while disadvantages include potential off-flavors and limited commercial use. In conclusion, ultrasound is a specialized technology that requires further research for industrial applications.
The Arduino Uno kit is a microcontroller board that allows users to build electronic projects. It contains an Arduino Uno board, various electronic components like LEDs and buttons that can be connected to the board, and instructions for making simple projects. The kit is designed for beginners and makers to learn basic concepts of electronics, coding, and physical computing through hands-on projects.
The document summarizes key aspects of the Undisclosed Foreign Income and Assets (Imposition of Tax) Bill, 2015 in India. It discusses (1) the background and objectives of the bill which are to tax undisclosed foreign income and assets and punish those generating illegitimate money, (2) key features of the bill including penalties for concealment of foreign income/assets and criminal liability for tax evasion, and (3) important definitions related to the bill such as "resident", "undisclosed foreign income and asset", and rules around computing total undisclosed income and disallowing expenses/losses against such income.
Hitesh D. Gajaria explains Black Money Tax Law - Aug 2015Hitesh Gajaria
India enacted the Black Money (Undisclosed Foreign Income and Assets) and Imposition of Tax Act, 2015 w.e.f 1 July, 2015
Stringent Tax and Penalty aggregating 120% of the Undisclosed Foreign Assets and Income Plus Prosecution with Rigorous Imprisonment 3 months to 7 years Plus Fine
Limited One Time Compliance Window to come Clean with Tax 30% and Penalty 30% available until 30th September 2015 - payment by 31st December 2015
This Presentation gives an Overview of the Act and Rules and is meant to share knowledge and is Not a Substitute for appropriate Professional Advice
Hitesh D. Gajaria Black Money Law - 1 Aug 2015Hitesh Gajaria
Black Money (Undisclosed Income and Assets) and Imposition of Tax Act, 2015 is the latest statute effective from 1 July 2015, with a One Time Compliance (OTC) (30 Sept. 2015) and Payment of Tax and Penalty (31 Dec. 2015) Opportunity
This is a very Stringent Act - Outside the OTC Window Tax will be levied @ 120% together with Prosecution - 6 months to 7 Years Rigorous Imprisonment + Fine
Time Is Short for the OTC and unless Extended could lead to difficulty in compliance
Income tax-ppt-revised-130617182402-phpapp01 (1)kiyansh
- Tax is a mandatory payment made to the government without any direct benefit in return. The authority to levy tax comes from the constitution.
- The key objectives of taxation are to generate revenue, redistribute wealth, act as a deterrent, and give citizens representation.
- India has a three-tier system of taxation comprising the Union, State, and Local governments. The main taxes levied include income tax, customs duties, excise, sales tax, and corporate tax.
The document discusses the process of e-filing income tax returns in India. It provides definitions of key terms related to income tax returns such as assessment year, previous year, and total income. It outlines the various forms used to file returns based on an individual's or HUF's income sources. It also summarizes recent amendments made to the income tax return forms, including additional schedules on foreign assets/income and a new schedule to report personal assets and liabilities.
This document provides information about an Advanced Taxation course for Tax Year 2021 taught by Fawad Hassan. The syllabus covers Income Tax (weighted 50-55%), Sales Tax (30-35%), and Federal Excise Law (10-15%). The goal is to help students score at least 50% on the CFAP-5 exam. The document outlines practice material and important concepts to focus on, including relevant laws, locating topics in statutes, and practice problems. It also provides an overview of Pakistan's tax collection system and the key questions to consider for Income Tax, including tax year, person status, residential status, tax regimes, income sources, and apportioning deductions.
THIS IS MY FIRST PRESENTATION OF BLACK MONEY BILL. I WILL PUT MY SINCERE EFFORTS AND TRIED MY BEST TO MAKE THIS PRESENTATION USEFUL AND EASILY UNDERSTANDABLE.
THANKS
CA DEEPAK KAPOOR
DIRECT TAX CONSULTANT
The document provides an overview of the CFAP-05 Advanced Taxation course for Tax Year 2018. It includes details about the trainer, dos and don'ts for studying taxation, the course syllabus weighting and expectations. It then covers key concepts related to income tax including tax year, types of persons, residential status, tax regimes, geographical source of income, and apportionment of deductions. The document provides examples and explanations for each of these taxation concepts. It also discusses various provisions for tax collected or deducted at source which constitute final tax. The summary covers the essential concepts and structure of the taxation course in 3 sentences.
Understanding the Impact of Finance Act, 2020 on Residential Status of Indivi...Taxmann
Overview of the Presentation:
1. Under the provisions of the Income-tax Act, an individual becomes a resident of India based on, his/her number of days of stay in India. The condition of ‘number of days’ is relaxed in case of a Person of Indian origin (PIO) / Citizen of India (COI), visiting India. Also, India unlike other countries classifies residents into Resident & Ordinary Resident (ROR)and Resident but Not Ordinary Resident (RNOR).
2. In few countries an individual becomes tax resident based on citizenship irrespective of whether he/she lives in that country or not. Examples: USA, Eritrea
3. The Finance Act, 2020 (FA 2020)has introduced citizenship-based residency provisions for Indian citizens apart from restricting the relaxations granted to COI/PIO visiting India. Further, the FA 2020 has also increased the criteria of qualifying RNOR
Prime Minister Modi announced that Rs. 6,500 crore of undisclosed income had been declared under the Black Money Act as part of a one-time compliance window. This allows those with undisclosed foreign assets to declare them by September 30, 2015 by paying a tax and penalty totaling 60% of the assets' fair market value to receive amnesty. The Act aims to curb black money and targets undisclosed foreign income and assets not previously declared in tax returns, imposing a 30% tax on such amounts. It provides an opportunity for tax evaders to come clean before more stringent provisions take effect.
Advanced Taxation (CFAP5) by Fawad Hassan [Lecture1]Fawad Hassan
The document provides an overview of the CFAP-05 Advanced Taxation course taught by Fawad Hassan. It outlines expectations, the syllabus weighting, and key taxation concepts that will be covered including the 6 basic questions of income tax (tax year, type of person, residential status, tax regime, source of income, apportionment of deductions). It also summarizes Pakistan's revenue collection system and different tax regimes including the normal tax regime, separate block, final tax, and minimum tax. Key taxation laws such as income tax, sales tax, and federal excise are also mentioned.
The document defines key terms related to income tax in India such as assessee, assessment year, gross total income, previous year, and residential status. It explains that an assessee is a person liable to pay tax and includes individuals, HUFs, companies, firms, etc. Assessment year means the year following the previous year in which income is earned. Gross total income is the aggregate income from all sources. Residential status determines the scope of income taxable in India and can be resident, resident but not ordinarily resident, or non-resident. Income tax is deducted at source for certain types of income like salary, interest, rent, etc. and is considered advance tax.
Trainer: Fawad Hassan provides training for the Advanced Taxation (CFAP-05) course. The course covers Income Tax, Sales Tax, Federal Excise Law, and professional ethics over a tax year 2020. The syllabus places the highest weighting on Income Tax. The target is to help students score at least 50% by developing a practical understanding of taxation laws. Practice material includes past ICAP papers and kits. Key points include understanding the relevant Acts, locating topics, and practicing reverse tracking of issues. Revenue collection in Pakistan involves various taxes collected by the Federal Board of Revenue.
1 Types of ITR forms to be filed for FY 22-23.pptxAASTHAJAISWAL35
This document provides information on the different types of Income Tax Return (ITR) forms for the financial year 2022-23 in India. It explains that ITR forms are specified by the Income Tax Act and different forms apply depending on the taxpayer's sources and amount of income. ITR-1 is for individuals with income from salary, one house property or other sources. ITR-2 is for individuals and HUFs with various income sources. ITR-3 is for individuals and HUFs with income from business or profession. ITR-4 is for individuals, HUFs and firms with income from presumptive taxation schemes. ITR-5 is for firms, LLPs, AOPs
Income tax in India is governed by the Income Tax Act of 1961. Individuals and entities are taxed based on their residential status and total income under various heads including income from salaries, house property, business/profession, capital gains, and other sources. Tax rates and exemptions vary based on taxpayer type. The Central Board of Direct Taxes governs income tax collection which is a major source of government revenue.
This document provides information about an Advanced Taxation course for Tax Year 2019 taught by Fawad Hassan. It outlines the syllabus, practice material, expectations, and income tax framework. The syllabus focuses on Income Tax (50-55%), Sales Tax (30-35%), and Federal Excise Law (10-15%). The document explains key income tax concepts like the tax year, types of persons, residential status, tax regimes, geographical source of income, and apportionment of deductions in 3 sentences or less.
INCOME TAXXX RELATED POWER POINT PRESENTATIONBojamma2
- The document discusses various topics related to income tax in India including the introduction of income tax, the need to pay taxes, tax slabs, key terms, types of income such as salary income and its components, exemptions under section 10 including leave travel allowance and house rent allowance, and deductions available under the Income Tax Act.
- It provides an overview of the history and development of income tax in India since 1860 and explains the various expenditures incurred by the government that require funding through tax collection.
- The document also addresses common questions around why citizens need to pay taxes and what the government does with the tax revenue collected.
1) It defines key income tax terms like assessee, assessment, income year, tax day, and total income according to the Income Tax Ordinance of 1984.
2) It outlines the process for income tax return submission and different deadlines for individuals, companies, and financial companies.
3) It describes the income tax slabs and rates in Bangladesh, including special rates for certain groups.
4) It provides details about the minimum tax amounts in different areas.
5) It briefly explains the processes of normal assessment and universal self-assessment.
Income%20tax%20ppt%2023.01.2024.pdf Income taxSaniyaSultana9
This document provides an introduction and overview of key concepts related to income tax in India. It defines income tax and when it came into effect. It describes the different types of assessees (ordinary, deemed, in default) and explains exemption limits and slabs. It also defines key terms like person and assessment year. It distinguishes between direct and indirect taxes and components of each. Goods and Services Tax (GST) and its components are explained. Finally, the five heads of income under which a person's income is classified for tax purposes are outlined as salary, house property, business/profession, capital gains, and other sources.
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Black Money Compliance Window
The Undisclosed Foreign Income And Assets (Imposition Of Tax) Bill, 2015
{UFIA Act, 2015}
Surprises continued..
CA. Ashwani Rastogi
ashwani.rastogi.ca@gmail.com
+91 9990999281
+91 9810999281
New Delhi
2nd July 2015
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C O N T E N T S
Matter Covered Page No.
One time compliance procedure 3
One time compliance NOT OPEN FOR 4
Highlights of the UFIA Act 5
Analysis of the UFIA Act
• Applicability of the UFIA Act 6-7
• Undisclosed foreign income and assets 8-10
• Computation of tax on UFIA 11-15
• Assessment procedures & Treaty protection 16
• FEMA and UFIA – Issues 17
• Mandatory filing of IT Return &
disclosure requirement
18
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One time compliance procedure
Positioned as not being an amnesty scheme – there is no immunity from penalty
Merely an opportunity for persons to come clean and become compliant before the stringent
provisions of the new Act come into force
One time compliance scheme window (with a time limit to be notified) for disclosing any UFA
acquired from income chargeable to tax under ITA for any assessment year prior to AY 2016-17*
Any person can make declaration (format and the due date to be notified) in respect of UFAs and
pay tax on it @ 30% plus penalty (equal to tax) i.e. total 60%
Tax will be on value of UFA as on the date of enactment of this new legislation
No exemption, deduction or set-off of any carried forward losses
Amount of UFA so declared shall not be included in the total income of any assessment year in
ITA
No reopening of assessment due to disclosure under this scheme - Declaration will not affect
finality of completed assessment
Contents of declaration cannot be used as evidence for imposing penalties under any other law
or for prosecution under ITA, Wealth tax, FEMA, Companies Act 2013, or Customs Act 1962
No Wealth Tax on UFA declared. Assets declared by firm shall not be considered in computing
net wealth of individual partner or value of interest of any partner
*Central Government indicated that Declaration has to filled by 30th September 2015 and Tax need to be
discharged by 31st December 2015 – Source Aaj Tak Media dt. 1st July 2015
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One time window NOT OPEN for the following persons:
Any person who has been issued an order of detention under the Conservation of Foreign
Exchange and Prevention of Smuggling Activities Act, 1974 (subject to certain conditions
Any person who is subject to prosecution for any offence punishable under Chapter IX or Chapter
XVII of the Indian Penal Code, the Narcotic Drugs and Psychotropic Substances Act, 1985, the
Unlawful Activities (Prevention) Act, 1967, the Prevention of Corruption Act, 1988
Any person notified under section 3 of the Special Court (Trial of Offences Relating to
Transactions in Securities) Act, 1992
Any person against whom notice of assessment has been issued under ITA
Any person against whom time limit for furnishing of notice of assessment has not expired due to
search, survey under the ITA
Any person against whom information has been received in respect of UFA from competent
authority under a formal pact (cases like account holders of HSBC Geneva which has not been
disclosed, whether or not having any balance)
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Highlights of the UFIA Act
Act is effective from 1 April 2016 onwards (Assessment Year 2016-17) and extends to whole of
India
Applicable to all persons resident in India. In case of Individuals, it applies to ordinary resident
under ITA
Flat 30% tax rate (without surcharge and cess) on the value of total undisclosed foreign income
and asset
No exemption, deduction , set-off and carry forward of losses under ITA, no set off of foreign tax
credit will be allowed on UFIA
Additional 300% penalty for non-disclosure of foreign income or an asset. Rs.10 Lakhs
penalty for non-filing of return / not furnishing complete details of foreign assets
Rs.10 Lakhs penalty for non-filing of return / not furnishing complete details of foreign assets
Prosecution for various violations (including abetment) including rigorous imprisonment from 3
to 10 years.
Tax and penalty proposed to be calculated at current value of assets instead of original purchase
price
One time compliance opportunity before commencement of the UFIA Act (just notified) : 30% tax
and equal penalty, no interest and prosecution
Imposition of personal liability on the Manager (including MD) of a company if any amount due
under UFIA Act is not recoverable from the company
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Applicability of the UFIA Act
Applicable to all persons resident in India. In case of Individuals, it applies to ordinary resident under
ITA
Who is an RNOR?
To understand who an RNOR is, we first need to understand the definitions of resident and non-
resident Indian.
A person is a resident Indian in a particular year if he fulfills either of these two conditions: -
He/she has been in India in that year for 182 days or more or -He/she has been in India for 60
days or more in that year and 365 days or more in the 4 years preceding that year
A person who does not fulfill the above conditions is considered to be a non-resident.
Now, if you have recently moved back to India after spending many years overseas, you must check
for the status of RNOR.
A person is an RNOR if he meets either of these two conditions: -He/she has been non-resident in
India, that is, an NRI, in nine out of the ten previous years preceding that year, or
-He/she has, during the seven previous years preceding that year, been in India for a period of 729
days or less
Now depending on the date of return, a person can take the benefit of the RNOR status for up to 3
tax years in India. (Note than a tax year in India is a fiscal year, that is, from April to March)
Illustration: Rakesh Verma returns to India on 15th January 2011 after spending more than 20
years abroad. The first tax year for him in India would be 2010-2011. Does he qualify as RNOR in
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2010-2011? Yes, because: -He has been an NRI for all the years preceding 2010-2011.
Will he qualify as RNOR in 2011-2012? Yes, because -He will have been an NRI for nine out of the
ten previous years. That is, except for 2010-2011, he will have been NRI in all other years
Will he qualify as RNOR in 2012-2013? -He will not have been NRI for nine out of the ten previous
years because he would have been RNOR for 2010-2011 and 2011-2012. -During the seven
previous years, that is for the seven tax years from 2005-2006 to 2011-2012, he would have been
in India for the entire 2011-2012 (366 days) and for 75 days in 2010-2011. That's 441 days in total
which is less than 729 days. Because he will fulfill this second condition, he will qualify as an
RNOR in 2012-2013 as well.
Will he qualify for RNOR in 2013-2014? -He will not have been NRI for nine out of the ten previous
years because he would have been RNOR from 2010-11 to 2012-13 -During the seven previous tax
years, that is from 2006-2007 to 2012-2013, he would have been in India for 365 days in 2012-
2013, 366 days in 2011-2012 and 75 days in 2010-2011. That's 806 days in total. Since he will not
fulfill either condition, he will be considered as Resident Indian in 2013-2014.
Accordingly UFIA applicable only to those person who are ROR, not to RNOR & NRI.
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Undisclosed foreign income and assets
Undisclosed Foreign Income and Asset (UFIA) [Section 2(12)]
• Total amount of undisclosed income from source located outside India [as referred
in Section 4(1)], and
• Value of UFA located outside India
• UFIA shall be
– Income from a source located outside India which has not been disclosed in the
Return of Income filed under the ITA
– Income from sources, in respect of which return is not filed under the ITA and
– Value of undisclosed foreign asset (UFA) located outside India
(fair market value in the previous year in which AO notices UFA- method of valuation
to be prescribed)
• Computation of UFIA laid down under section 5 of the Bill
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Undisclosed Asset located outside India (UFA) [Section 2(11)]
• An asset (including financial interest in any entity) located outside India
• Asset can be held by the assessee in his name or in respect of which he is a
beneficial owner, and
• Assessee has no explanation about the source of investment in such asset or the
explanation given by him is the opinion of the Assessing Officer is unsatisfactory
Test of undisclosed foreign asset is to explain the source of investment
Asset not taxable as UFA if its source is explained (even though it is not declared in
the return of income)
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UFA is not defined under the Bill. It will include all assets either movable or immovable (including
financial interest in an entity)
• A cue can be taken from the Instructions to the Income Tax Returns:
“Financial interest would include, but would not be limited to, any of the following:-
(1) if the resident assessee is the owner of record or holder of legal title of any financial account,
irrespective of whether he is the beneficiary or not.
(2) if the owner of record or holder of title is one of the following:-
(i) an agent, nominee, attorney or a person acting in some other capacity on behalf of the resident
assessee with respect to the entity.
(ii) a corporation in which the resident owns, directly or indirectly, any share or voting power.
(iii) a partnership in which the resident assessee owns, directly or indirectly, an interest in partnership
profits or an interest in partnership capital.
(iv) a trust of which the resident has beneficial or ownership interest.
(v) any other entity in which the resident owns, directly or indirectly, any voting power or equity
interest or assets or interest in profits.”
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Computation of tax on UFIA
• UFIA will be taxed @ 30% - no surcharge and cess
• Tax will be charged on its value in the previous year in which UFIA same is noted by AO
• Value of UFA means fair market value of an asset ‘including financial interest in any entity) in
the previous year in which it comes to AO’s notice– method of valuation to be prescribed
• Computation of total UFIA (Section 4)
Computation of total UFIA
Income from source located outside India (foreign income ‘ FI’ ) which has not
been disclosed in IT Return
XX
FI in respect of which no IT return has been filed XX
FMV of UFA (no explanation or unsatisfactory explanation about the source of
income has been provided – Section 4(3))
XX
• If UIFA is taxed under this new legislation, it will not be taxed under ITA
• Any variation made to the foreign sourced income as per section 29 to 43C or section 57 to 59 or
section 92C of the ITA will not be included in total undisclosed foreign income
• Hardship to the assessee as tax and penalties proposed to be calculated at current value of assets
instead of original purchase price
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Computation of tax on UFIA
• As per Section 5,
- No expenditure, allowance, set off of any loss shall be allowed as deduction from total UFIA – no
mention about liabilities incurred against undisclosed foreign assets
- If any income is assessed prior to AY 2016-17 under ITA or any income is assessed /
assessable under UFIA Act shall be reduced from the value of UFA outside India – subject to
producing evidence that the UFA was acquired from such income
- Proportionate income which was been assessed to tax under ITA or UFIA Act shall be reduced
from FMV of UFA being immovable property
Reduction Formula:
Value of UFA as on first day of FY (in which AO notices such asset) X
Assessed / assessable foreign income / Total cost of the asset
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Computation of tax on UFIA
Computation of total UFIA
Income from source located outside India (foreign income or ‘ FI’ ) which has not been
disclosed in IT Return
XX
FI in respect of which no IT return has been filed XX
FMV of UFA (no explanation or unsatisfactory explanation about the source of income has
been provided ) – manner of valuation to be provided
XX
Less:
Income which has been assessed to tax for any assessment year under the ITA prior to
relevant AY in which UFIA applies
(XX)
Income which is assessable or has been assessed to tax for any assessment year
under UFIA
(XX)
In case of immovable properties, the deduction will be:
Value of UFA as on first day of FY in the same proportion as assessed / assessable foreign
income bears total cost
(XX)
Total value of UFIA XX
Tax @ 30% XX
The quantum of penalty may vary between 100% to 300% of the tax amount, depending on whether
voluntarily disclosures are made under one time disclosure window or UFIA is detected by AO
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Computation of tax on UFIA
Illustration 1:
• Mr. Y acquired foreign asset (immovable property) in the assessment year 2010-11 for Rs.120 lacs.
Out of the total investment, Rs.80 lacs was assessed to tax in an earlier year.
• In AY 2007-08, the AO identified the undisclosed asset having value of Rs.4 crore for which no
explanation was provided
Computation of total UFIA – Shares Rs. (in crores)
FMV of UFA (no explanation provided or explanation not
satisfactory)
4
Less
Income which has been assessed to tax for any assessment year under
the ITA prior to relevant AY in which UFIA applies
(Rs.4crore X 0.80 lacs / 1.20 lacs)
(2.67)
Amount chargeable to tax under UFIA Act 1.33
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Computation of tax on UFIA
Illustration 2:
• Mr. X acquired share of foreign company, in the assessment year 2011-12 for 40 lacs.
• AO identified the undisclosed asset in the assessment year 2018-19, the FMV of such asset is
determined at Rs.60 lacs
• Shares were acquired from the income assessed to tax of Rs.16 lacs
Computation of total UFIA – Shares Rs. (in crores)
FMV of UFA in respect of which no explanation or unsatisfactory
explanation about the source of income has been given
60
Less:
Income which has been assessed to tax for any assessment year under
the ITA prior to relevant AY in which UFIA applies
(16)
Amount chargeable to tax under UFIA Act 44
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Assessment procedure Chapter III – Tax Management
• No requirement to file a separate return under UFIA Act.
• Assessment / reassessment by AO in respect of undisclosed foreign income or asset on the basis
of information received
• Issue of notice for assessment / reassessment (no timeline provided), opportunity of being heard
and furnishing of evidences / documents will be given – principles of natural justice to be followed
• Inquiry or investigation by Tax Authorities into matters of the assesse even though there are no
proceedings pending before it
• Time limit for completion of assessment and reassessment shall be 2 years from the end of the
financial year in which notice was issued
• It is expected that two assessment orders will be passed in respect of period covered by a single
return of income: under section 143(3) of ITA and 10(3) of UFIA Act
• Remedial measures provided - appeal to CIT(A) / ITAT / High Court and Supreme Court (for
substantial question of law), rectification of mistakes, revision of orders, recovery of arrears
• Under UFIA, the AO will be able to re-open the assessments beyond 16 years.
Treaty protection
Section 73
No provision granting relief against double taxation of income under UFIA Act and corresponding law in
foreign jurisdiction
FEMA and UFIA – Issues
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Foreign assets held in accordance with FEMA – examples
Any resident individual (under FEMA or ITA or both) who is holding assets abroad acquired from
LRS
Any Indian resident company holding assets abroad under Overseas Direct Investments (ODI)
Guidelines
A resident person who continues to hold assets abroad which were acquired when non-resident as
permitted under section 6(4) of FEMA
Inheritance of foreign asset by Indian resident from non-resident relative and continues to hold the
same as permitted under section 6(4) of FEMA
However, Finance Bill 2015 proposes that the Enforcement Director under FEMA can directly seize
equivalent value of Indian assets (without asking any questions) and merely on the reason to
believe or suspicion – similar amendments are also proposed under Prevention of Money-
laundering Act, 2002 (PMLA) vide Finance Bill 2015
Black Money is different from criminal money – Harsh implications and arbitrary penalties under
UFIA read with proposed PMLA amendment not justified
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Mandatory filing of IT Return & disclosure requirement of foreign assets in ITR
- Currently, ROR is mandatorily required to file the IT return even if total income does not exceed
the maximum amount not chargeable to tax if he has any asset (including any financial interest
in any entity) located outside India or signing authority in an account outside India
- Finance Act 2015 has proposed that ROR, is mandatorily required to file the tax return if he:
- holds, as a beneficial owner or otherwise, any asset (including any financial interest in any
entity) located outside India or has signing authority in any account located outside India; or
- is a beneficiary of any asset (including any financial interest in any entity) located outside
India
- Filing of return will not be mandatory for a beneficiary of any asset (including any financial
interest in any entity) located outside India, if income arising from such an asset is includible in the
income of the beneficial owner of such an asset
Disclosure of Foreign Assets (Schedule FA) as per IT Return w.e.f. AY 2012-13 ITR Form contain Schedule
FA that required for every assesse to disclose following details:-
- Details of foreign bank accounts
- Details of foreign immovable property
- Details of any other asset or assets in the nature of investment
- Details of account(s) in which there is signing authority and which has not been included above
- Details of trusts, created under the laws of a country outside India, in which you are a trustee