OBJECTIVE
The Direct Tax Vivad se Vishwas Bill, 2020 was introduced in the Parliament on 5th February, 2020 and subsequently amended. The webinar shall deal with the frequently asked questions relating to the scheme. It shall discuss the issues faced by the taxpayers in the dispute resolution scheme.
Guided by “Sabka Saath, Sabka Vikas, Sabka Vishwas”, the Finance Minister Smt. Nirmala Sitharaman had introduced a new No Dispute but Trust Scheme – ‘Vivad Se Vishwas’ in the Budget 2020 in the Lok Sabha on 5th February, 2020. Expectations are that the new scheme will work better than erstwhile similar scheme “The Direct Tax Dispute Resolution Scheme, 2016”, given the kind of cases that are in appeal.
To know more:https://itatorders.in/blog/eligible-person-under-vivad-se-vishwas-scheme-2020/
Get consultation under the VSV scheme and calculate your taxes : https://www.itatorders.in/vsvcalculator
OBJECTIVE
Goods and Services Tax (GST) is an Indirect Tax levied in India introduced in July, 2017 which was one of the most important reforms in the Indian Economy. Unlike erstwhile indirect tax regime, GST promises seamless credit on goods and services across the entire supply chain with some exceptions. In this webinar, we shall understand and analyse the provisions related to Input Tax Credit under the GST law
OBJECTIVE
Under GST, the supplier of goods or services is liable to pay the tax to the Government. However, under the reverse charge mechanism (RCM), the liability to pay GST is cast on the recipient of the goods or services. Reverse charge means the liability to pay tax is on the recipient of supply of goods or services instead of the supplier of such goods or services in respect of notified categories of supply. In this webinar, we shall understand the applicability and provisions of RCM under GST.
OBJECTIVE
Customs duty is an indirect tax, which is a tax on the goods and not a tax on the person having or owning the goods.In this webinar, we shall know when an assessment can be made and when shall an appeal be made before a commissioner, High Court and Supreme Court.
OBJECTIVE
Job work sector constitutes a significant industry in Indian economy. The concept of job work already exists in Central Excise, wherein a principal manufacturer can send inputs or semi finished goods to a job worker for further processing. After the introduction of the Goods and Services Act (GST), it made special provisions in this regard, giving some leniency for the job workers in complying with the discrete provisions with a motive to make the principal responsible for the same. In this webinar we will be learning the provisions of the GST Act relating to goods sent on job work, rates applicable for services by way of job work and transitional provisions.
Guided by “Sabka Saath, Sabka Vikas, Sabka Vishwas”, the Finance Minister Smt. Nirmala Sitharaman had introduced a new No Dispute but Trust Scheme – ‘Vivad Se Vishwas’ in the Budget 2020 in the Lok Sabha on 5th February, 2020. Expectations are that the new scheme will work better than erstwhile similar scheme “The Direct Tax Dispute Resolution Scheme, 2016”, given the kind of cases that are in appeal.
To know more:https://itatorders.in/blog/eligible-person-under-vivad-se-vishwas-scheme-2020/
Get consultation under the VSV scheme and calculate your taxes : https://www.itatorders.in/vsvcalculator
OBJECTIVE
Goods and Services Tax (GST) is an Indirect Tax levied in India introduced in July, 2017 which was one of the most important reforms in the Indian Economy. Unlike erstwhile indirect tax regime, GST promises seamless credit on goods and services across the entire supply chain with some exceptions. In this webinar, we shall understand and analyse the provisions related to Input Tax Credit under the GST law
OBJECTIVE
Under GST, the supplier of goods or services is liable to pay the tax to the Government. However, under the reverse charge mechanism (RCM), the liability to pay GST is cast on the recipient of the goods or services. Reverse charge means the liability to pay tax is on the recipient of supply of goods or services instead of the supplier of such goods or services in respect of notified categories of supply. In this webinar, we shall understand the applicability and provisions of RCM under GST.
OBJECTIVE
Customs duty is an indirect tax, which is a tax on the goods and not a tax on the person having or owning the goods.In this webinar, we shall know when an assessment can be made and when shall an appeal be made before a commissioner, High Court and Supreme Court.
OBJECTIVE
Job work sector constitutes a significant industry in Indian economy. The concept of job work already exists in Central Excise, wherein a principal manufacturer can send inputs or semi finished goods to a job worker for further processing. After the introduction of the Goods and Services Act (GST), it made special provisions in this regard, giving some leniency for the job workers in complying with the discrete provisions with a motive to make the principal responsible for the same. In this webinar we will be learning the provisions of the GST Act relating to goods sent on job work, rates applicable for services by way of job work and transitional provisions.
OBJECTIVE
Goods and Services Tax (GST) is an Indirect Tax levied in India introduced in July, 2017 which was one of the most important reforms in the Indian Economy. GST is payable on the supply of goods or services. In this webinar, we will be able to understand and analyse the provisions related to time and value of supply under GST.
Key Takeaways:
- Rationale for Introducing Penalty Provisions
- Consequences of Fake Invoicing under Income Tax Act and GST
- Legal Proceedings and Compounding of Offences
- Judicial Precedents
Article is about when to apply GST Refund when goods or services are exported out of India. Legal provisions for process of GST refund scheme. GST is a destination based consumption tax where in the levy of tax moves along with goods and /or services.where a goods exporter is not in position to utilize the GST paid in inputs such as raw material , inputs etc. which are used for export of goods shall apply for refund of GST paid by goods exporter. By taking GST Refund Exporter of Goods can increase its business working capital.
Procedures to claim refund, rebate and duty drawback under customsDVSResearchFoundatio
OBJECTIVE
Import of all kinds of goods and on the export of goods on certain situations attracts customs duty. The Customs Act,1962 contains provisions which govern the levy of customs duty. In this webinar, we shall understand the procedures to be followed while claiming refunds, rebate and duty drawback under customs law.
concept of input tax and input service distributorGST Law India
This presentation provides a detailed information on input tax credit, when and in which manner ITC could be taken, restrictions in taking ITC, reversal, transfer, utilization of ITC and about input service distributor under GST.
OBJECTIVE
Honourable Finance Minister Nirmala Sitharaman, in the Speech of Budget 2020-21, proposed to introduce The Direct Tax Vivad se Vishwas Act, 2020 for
dispute resolution related to direct taxes. Similar scheme known as the 'Sabka Vishwas' was introduced in 2019 for dispute resolution under Legacy Indirect Taxes. The Direct Tax Vivad se Vishwas Bill, 2020 was introduced in the parliament on 5th February, 2020. In this webinar, we shall under the provisions of the Bill and the Rationale for its Introduction.
GST AUDIT and its Impact on Statutory Audit/Tax AuditGST Law India
The following presentation enumerates the Auditor’s Comments on the correctness of Valuations including transaction value, Section 15 provisions, Valuation Rules, Value of supply of services in case of pure agent, Reimbursement of expenses and Margin scheme and other special valuations.
The Direct Tax Vivad se Vishwas Rules, 2020 ('the Rules') have been notified. The Rules inter alia laid down the procedure and the forms, which need to be filled in. Further, along with detailed instructions for taxpayers to file the declaration and the undertaking; e-filing utility has also been enabled.
OBJECTIVE
Honourable Finance Minister Nirmala Sitharaman, in the Speech of Budget 2020-21, proposed to introduce The Direct Tax Vivad se Vishwas Act, 2020 for dispute resolution related to direct taxes. Similar scheme known as the 'Sabka Vishwas' was introduced in 2019 for dispute resolution under Legacy Indirect Taxes. The Direct Tax Vivad se Vishwas Bill, 2020 was introduced in the parliament on 5th February, 2020. In this webinar, we shall under the provisions of the Bill and the Rationale for its Introduction.
OBJECTIVE
Goods and Services Tax (GST) is an Indirect Tax levied in India introduced in July, 2017 which was one of the most important reforms in the Indian Economy. GST is payable on the supply of goods or services. In this webinar, we will be able to understand and analyse the provisions related to time and value of supply under GST.
Key Takeaways:
- Rationale for Introducing Penalty Provisions
- Consequences of Fake Invoicing under Income Tax Act and GST
- Legal Proceedings and Compounding of Offences
- Judicial Precedents
Article is about when to apply GST Refund when goods or services are exported out of India. Legal provisions for process of GST refund scheme. GST is a destination based consumption tax where in the levy of tax moves along with goods and /or services.where a goods exporter is not in position to utilize the GST paid in inputs such as raw material , inputs etc. which are used for export of goods shall apply for refund of GST paid by goods exporter. By taking GST Refund Exporter of Goods can increase its business working capital.
Procedures to claim refund, rebate and duty drawback under customsDVSResearchFoundatio
OBJECTIVE
Import of all kinds of goods and on the export of goods on certain situations attracts customs duty. The Customs Act,1962 contains provisions which govern the levy of customs duty. In this webinar, we shall understand the procedures to be followed while claiming refunds, rebate and duty drawback under customs law.
concept of input tax and input service distributorGST Law India
This presentation provides a detailed information on input tax credit, when and in which manner ITC could be taken, restrictions in taking ITC, reversal, transfer, utilization of ITC and about input service distributor under GST.
OBJECTIVE
Honourable Finance Minister Nirmala Sitharaman, in the Speech of Budget 2020-21, proposed to introduce The Direct Tax Vivad se Vishwas Act, 2020 for
dispute resolution related to direct taxes. Similar scheme known as the 'Sabka Vishwas' was introduced in 2019 for dispute resolution under Legacy Indirect Taxes. The Direct Tax Vivad se Vishwas Bill, 2020 was introduced in the parliament on 5th February, 2020. In this webinar, we shall under the provisions of the Bill and the Rationale for its Introduction.
GST AUDIT and its Impact on Statutory Audit/Tax AuditGST Law India
The following presentation enumerates the Auditor’s Comments on the correctness of Valuations including transaction value, Section 15 provisions, Valuation Rules, Value of supply of services in case of pure agent, Reimbursement of expenses and Margin scheme and other special valuations.
The Direct Tax Vivad se Vishwas Rules, 2020 ('the Rules') have been notified. The Rules inter alia laid down the procedure and the forms, which need to be filled in. Further, along with detailed instructions for taxpayers to file the declaration and the undertaking; e-filing utility has also been enabled.
OBJECTIVE
Honourable Finance Minister Nirmala Sitharaman, in the Speech of Budget 2020-21, proposed to introduce The Direct Tax Vivad se Vishwas Act, 2020 for dispute resolution related to direct taxes. Similar scheme known as the 'Sabka Vishwas' was introduced in 2019 for dispute resolution under Legacy Indirect Taxes. The Direct Tax Vivad se Vishwas Bill, 2020 was introduced in the parliament on 5th February, 2020. In this webinar, we shall under the provisions of the Bill and the Rationale for its Introduction.
Vivaad Se vishwas scheme has been introduced by Government of India to provide one time opportunity for settlement of pending litigation by paying the basic tax amount and complete waiver of interest and penalty.
According to the in-depth analysis, the VsV Bill results in a win-win situation for both the government and the Taxpayer. While the VsV Bill will help in reducing the overall litigations as of date, it is equally important for the government to also chalk out a plan to reduce future litigations. See More :https://www2.deloitte.com/in/en/services/tax.html
The subject matter experts of VsV Bill 2020 gives presentation about the thorough analysis of the bill, the amendments made and how its going to affect taxpayers (directly or indirectly) in the long run. See More :https://www2.deloitte.com/in/en/services/tax.html
OBJECTIVE
Goods and Services Tax (GST) is an Indirect Tax levied in India introduced in July, 2017 which was one of the most important reforms in the Indian Economy. Timely refund mechanism is essential in tax administration, as it facilitates trade through the release of blocked funds for working capital, expansion and modernisation of existing business. In this webinar, we shall understand and analyse the provisions related to Refund under the GST law.
A voluntary dispute resolution scheme called as Sabka Vishwas (Legacy Dispute Resolution) Scheme 2019 has been introduced by the Government for resolution of the Legacy disputes under Central Excise, Service Tax etc. (Incorporating clarification and procedure vide Circular 1071/4/2019-CX8. dated 27/08/2019)
The Federal Tax authority (FTA) operates using the Tax Procedures law that permits the FTA to assess payable taxes, tax audits, determine tax evasion and issue administrative penalties. These tax assessments as stated can result in a decision to make the taxpayer pay penalties pertaining to a particular transaction or tax period.
SCRAPPING OF RETRO TAX PROVISIONS : A REVIVAL OF OVERSEAS INTEREST IN INDIADVSResearchFoundatio
Key Takeaways:
- Scrapping of Restrospective effect of Taxation
- Indirect transfer of assets not taxable before 28th May 2012
- Vodafone case analysis
- Draft notification to implement the amendment
Key Takeaways: - Analysis of section 45(4), section 9B of the Income Tax Act...DVSResearchFoundatio
Key Takeaways:
- Analysis of section 45(4), section 9B of the Income Tax Act and Rule 8AA and Rule 8AB of Income Tax Rules
- Illustrations to understand the relevant impact
- Critical Issues concerned with the provisions
Key Takeaways:
- Facts of the case
- Issues and Orders of the case
- Contention of the parties
- Observations by Honourable Supreme Court
- Conclusions
Key Takeaways:
- Facts of the case
- Issues and Orders of the case
- Contention of the parties
- Observations by Honourable Supreme Court
- Conclusions
FALLACIOUS DISREGARDING OF TRANSACTIONS THAT RESULT IN A TAX BENEFIT TO THE A...DVSResearchFoundatio
Key Takeaways:
- Facts of the case
- AO's contention
- Ruling of CIT(A) and issues for consideration of the ITAT
- Observations of ITAT
- Final Ruling
- Way Forward
ALLOWABILITY OF OUTSTANDING INTEREST CONVERTED INTO DEBENTURES AS AN EXPENSE ...DVSResearchFoundatio
Key Takeaways:
- Facts and issues of the case
- Rationale behind the section
- Ruling of lower jurisdiction authorities
- Rival submissions before the Honourable Supreme Court
- Observations and final rulings of Honourable Supreme Court
- Way Forward
Key Takeaways:
- Facts of the case
- Issues and Orders
- Contention of the parties
- Observations of Honourable Supreme Court
- Conclusion and way forward
Key Takeaways:
- Background and Overview of Legal Provision
- Facts of the Case
- Contentions of the Assessee and Revenue
- Supreme Court’s Verdict
- Key Learnings and Way Forward
Key Takeaways:
- Background and Overview of Legal Provision
- Facts of the Case
- Contentions of the Assessee and Revenue
- Supreme Court’s Verdict
- Key Learnings and Way Forward
AUTOMATIC VACATION OF STAY GRANTED BY TRIBUNALDCIT v. PEPSI FOODS LTD. [2021]...DVSResearchFoundatio
Key Takeaways:
- Background and Overview of Legal Provision
- Facts of the Case
- Contentions of the Assessee and Revenue
- Supreme Court’s Verdict
- Key Learnings and Way Forward
Putting the SPARK into Virtual Training.pptxCynthia Clay
This 60-minute webinar, sponsored by Adobe, was delivered for the Training Mag Network. It explored the five elements of SPARK: Storytelling, Purpose, Action, Relationships, and Kudos. Knowing how to tell a well-structured story is key to building long-term memory. Stating a clear purpose that doesn't take away from the discovery learning process is critical. Ensuring that people move from theory to practical application is imperative. Creating strong social learning is the key to commitment and engagement. Validating and affirming participants' comments is the way to create a positive learning environment.
[Note: This is a partial preview. To download this presentation, visit:
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Sustainability has become an increasingly critical topic as the world recognizes the need to protect our planet and its resources for future generations. Sustainability means meeting our current needs without compromising the ability of future generations to meet theirs. It involves long-term planning and consideration of the consequences of our actions. The goal is to create strategies that ensure the long-term viability of People, Planet, and Profit.
Leading companies such as Nike, Toyota, and Siemens are prioritizing sustainable innovation in their business models, setting an example for others to follow. In this Sustainability training presentation, you will learn key concepts, principles, and practices of sustainability applicable across industries. This training aims to create awareness and educate employees, senior executives, consultants, and other key stakeholders, including investors, policymakers, and supply chain partners, on the importance and implementation of sustainability.
LEARNING OBJECTIVES
1. Develop a comprehensive understanding of the fundamental principles and concepts that form the foundation of sustainability within corporate environments.
2. Explore the sustainability implementation model, focusing on effective measures and reporting strategies to track and communicate sustainability efforts.
3. Identify and define best practices and critical success factors essential for achieving sustainability goals within organizations.
CONTENTS
1. Introduction and Key Concepts of Sustainability
2. Principles and Practices of Sustainability
3. Measures and Reporting in Sustainability
4. Sustainability Implementation & Best Practices
To download the complete presentation, visit: https://www.oeconsulting.com.sg/training-presentations
Attending a job Interview for B1 and B2 Englsih learnersErika906060
It is a sample of an interview for a business english class for pre-intermediate and intermediate english students with emphasis on the speking ability.
3.0 Project 2_ Developing My Brand Identity Kit.pptxtanyjahb
A personal brand exploration presentation summarizes an individual's unique qualities and goals, covering strengths, values, passions, and target audience. It helps individuals understand what makes them stand out, their desired image, and how they aim to achieve it.
Discover the innovative and creative projects that highlight my journey throu...dylandmeas
Discover the innovative and creative projects that highlight my journey through Full Sail University. Below, you’ll find a collection of my work showcasing my skills and expertise in digital marketing, event planning, and media production.
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Looking for professional printing services in Jaipur? Navpack n Print offers high-quality and affordable stationery printing for all your business needs. Stand out with custom stationery designs and fast turnaround times. Contact us today for a quote!
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𝐓𝐉 𝐂𝐨𝐦𝐬 (𝐓𝐉 𝐂𝐨𝐦𝐦𝐮𝐧𝐢𝐜𝐚𝐭𝐢𝐨𝐧𝐬) is a professional event agency that includes experts in the event-organizing market in Vietnam, Korea, and ASEAN countries. We provide unlimited types of events from Music concerts, Fan meetings, and Culture festivals to Corporate events, Internal company events, Golf tournaments, MICE events, and Exhibitions.
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As a business owner in Delaware, staying on top of your tax obligations is paramount, especially with the annual deadline for Delaware Franchise Tax looming on March 1. One such obligation is the annual Delaware Franchise Tax, which serves as a crucial requirement for maintaining your company’s legal standing within the state. While the prospect of handling tax matters may seem daunting, rest assured that the process can be straightforward with the right guidance. In this comprehensive guide, we’ll walk you through the steps of filing your Delaware Franchise Tax and provide insights to help you navigate the process effectively.
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As an Army veteran dedicated to lifelong learning, I bring a disciplined, strategic mindset to my pursuits. I am constantly expanding my knowledge to innovate and lead effectively. My journey is driven by a commitment to excellence, and to make a meaningful impact in the world.
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The world of search engine optimization (SEO) is buzzing with discussions after Google confirmed that around 2,500 leaked internal documents related to its Search feature are indeed authentic. The revelation has sparked significant concerns within the SEO community. The leaked documents were initially reported by SEO experts Rand Fishkin and Mike King, igniting widespread analysis and discourse. For More Info:- https://news.arihantwebtech.com/search-disrupted-googles-leaked-documents-rock-the-seo-world/
3. Legends Used
AMT Alternate Minimum Tax
AY Assessment Year
CBDT Central Board of Direct Taxes
CIT(A) Commissioner of Income-tax (Appeals)
DRP Dispute Resolution Panel
ITAT Income-tax Appellate Tribunal
MAT Minimum Alternate Tax
the Act - Income Tax Act, 1961
5. Introduction
Tax disputes consume time, energy and resources both on the part of the
Government as well as taxpayers. Moreover, they also deprive the Government of
the timely collection of revenue
Honourable Finance Minister Smt. Nirmala Sitharaman, in her budget speech,
has proposed to bring a scheme to reduce the litigation in the direct taxes
The Direct Tax Vivad se Vishwas Bill, 2020 (“the Bill”) was introduced in
the Lok Sabha on 05-02-2020 for dispute resolution related to direct taxes
There were concerns raised by the tax-payers in relation to coverage of the Bill,
clarifications of specific terminologies, etc.
Revised ‘Direct Tax Vivad se Vishwas Bill, 2020’ was introduced on 14.02.2020
addressing the concerns raised and providing numerous clarifications on its
applicability and viability
7. Definition of Disputed Tax
Nature of case Disputed Tax
Appeal or petition is pending before the
appellate forum on or before 31-01-2020
Amount of tax payable if such appeal was to be decided
against taxpayer
Order has been passed on or before 31-01-
2020 and time limit for filing appeal or
petition against such order has not expired
Amount of tax payable after giving effect to such order
Objections are pending before the DRP on or
before 31-01-2020
Amount of tax payable if DRP was to confirm variation
proposed in the draft order
DRP issued directions but the Assessing Officer
didn't pass an order on or before 31-01-2020
Amount of tax would have been payable had the order
been passed by the Assessing Officer
An application for revision under section 264
filed, is pending
Amount of tax payable by the taxpayer if the application
was to be rejected
CIT(A) has issued an enhancement notice in
disposing of appeal
Amount of disputed tax + Amount of tax in relation to
issues for which notice of has been issued
In cases where disputed is related to reduction of MAT/AMT credit or loss or depreciation computed
thereunder, the taxpayer shall have an option either to include amount of tax related to such tax credit
or loss or depreciation in amount of disputed tax or carry forward the reduced MAT/AMT credit or loss or
depreciation.
The above amounts of tax are including surcharge and cess but excluding interest
8. Definition of Appellant
a) A person in whose case writ/special leave petition is pending before the High Court or the
Supreme Court
b) A person in whose case, an order has been passed by the Assessing Officer or appellate forum
and time limit for filing an appeal or petition against such order has not expired on or before 31-
01-2020
c) A person who has filed an objection with the DRP and no direction has been issued by DRP on
or before 31-01-2020
d) A person against whom directions have been issued by DRP but the Assessing Officer has not
yet passed an assessment order in pursuance of such directions on or before 31-01-2020
e) A person who has filed an application for revision under section 264 and such application is
pending on or before 31-01-2020
Definition of ‘disputed tax’ was amended to remove ambiguities in the erstwhile definition and the
coverage for ‘appellant’ was expanded to include cases of search and seizure and those pending
before DRP
9. Amount Payable
The quantum of amount payable if the appeal is filed by the taxpayer
Type of case
Amount payable up to
31-03-2020
Amount payable on or
after 01-04-2020
I. Cases relating to disputed tax and interest/ penalty on such disputed tax
Includes assessment for search and seizure
operations or power to requisition books of
accounts and the disputed tax does not exceed
Rs. 5 crores
Amount of disputed tax
plus 25% of disputed tax
Amount of disputed tax
plus 35% of disputed tax
Residual Cases Amount of disputed tax
Amount of disputed tax
plus 10% of disputed tax
Note: Where 25% or 35% or 10% of disputed tax, exceeds the total of interest and penalty on disputed tax,
such excess amount shall be ignored
II. Cases relating to disputed interest, disputed
penalty and disputed fee
25% of disputed interest,
penalty or fee
30% of disputed interest,
penalty or fee
However, if appeal is filed for any issues on which the decision has been already favoured for the
taxpayer in earlier years from the higher forums (without further reversal), the amount payable
shall be 50% of the amount mentioned above
10. Contd..
The quantum of amount payable if the appeal is filed by the department
Type of case
Amount payable up to
31-03-2020
Amount payable on or
after 01-04-2020
I. Cases relating to disputed tax and interest/ penalty on such disputed tax
Includes assessment for search and seizure
operations or power to requisition books of
accounts and the disputed tax does not exceed
Rs. 5 crores
50% of disputed tax
plus 12.5% of disputed tax
50% of disputed tax
plus 17.5% of disputed tax
Residual Cases 50% of disputed tax
50% of disputed tax
plus 5% of disputed tax
Note: Where 12.5% or 17.5% or 5% of disputed tax, exceeds the total of interest and penalty on disputed
tax, such excess amount shall be ignored
II. Cases relating to disputed interest,
penalty and disputed fee
12.5% of disputed interest,
penalty or fee
15% of disputed interest,
penalty or fee
11. Withdrawal of Appeals and Claims
The withdrawal of appeals or petitions or claims in any
proceedings or notices by the tax-payer needs to be done after
issuance of certificate stating the amount of payment to be made
as against the erstwhile provision of withdrawal along with filing
of declaration
Proof of Withdrawal (from High Court and Supreme Court)
needs to be submitted along with the intimation of payment by
tax-payer as against the erstwhile provision of submitting at the
time of filing declaration
It shall not be presumed that the parties to the Bill have agreed
on the decision in relation to disputed issue by settling under
this Bill. Thus, if disputed matters arise in future, appeal can be
filed by the tax-payer or department and normal appellate
proceedings shall apply.
12. Refund of Amount
In case amount paid by taxpayer, in respect of its tax arrear (aggregate of disputed tax (including
interest or penalty or fee) + disputed interest + disputed penalty + disputed fee), before filing the
declaration, is more than the amount determined under the Bill, refund shall be granted
No interest shall be granted on such refund
No refund of amount paid by virtue of the Bill, under any circumstances
Illustration
Amount paid towards tax arrears
(Amount in Rs.)
Amount determined under the Bill
(Amount in Rs.)
Further payment to be made or
refund to be granted (Amount in Rs.)
100 110 Payment of 10
100 90 Refund of 10
100 100 No payment
100 300 Payment of 200
Payment of Rs. 10 or Rs. 200 done under the Bill, shall not be refunded under any circumstances
Earlier, the provisions of the Bill read as “no refund shall be granted under any circumstances”. The above
amendment has removed the ambiguity and justified the position of tax-payer.
13. Non-Applicability
Erstwhile Position Amended Position
Relating to an AY in respect of which an
assessment has been done for search and
seizure operations or requisition of books of
accounts
Relating to an AY in respect of which an
assessment has been made on the basis of
search and seizure operations or requisition of
books of accounts, where disputed tax exceeds
Rs. 5 crores
Any person in respect of whom prosecution for any
offence punishable under the provisions of the
Indian Penal Code or for the purpose of
enforcement of any civil liability has been instituted
Any person in respect of whom prosecution has
been initiated by an Income-tax authority for any
offence punishable under the provisions of the
Indian Penal Code or for the purpose of
enforcement of any civil liability under any law
for the time being in force, or such person has
been convicted of any such offence consequent
to the prosecution initiated by an Income-tax
authority
14. Rules to be Prescribed
• Determination of disputed tax including the manner of set-off in respect of brought forward or carry
forward of MAT/AMT credit or set-off in respect of brought forward or carry forward of loss or
allowance of depreciation under the provisions of the Act
• Manner of calculating the amount payable under the Bill
16. Issuance of Certificate after 31.03.2020 however, declaration
filed on or before 31.03.2020
When the
declaration has
been filed by
appellant on or
before 31st March
2020
but the final
certificate has been
issued on or after
1st April 2020,
then declarant may
not be liable to
pay additional tax
17. Rectification filed u/s 154 but no order has been received on or
before 31.01.2020
If order is issued u/s
143 (1) and assessee
has filed a rectification
u/s 154
No rectification order
has been passed on
or before 31.01.2020
Even though assessee
intends to reduce the
litigation, he cannot
opt for the Scheme as
order has not been
passed and no appeal
is pending
18. Condonation of delay in filing appeals
An assessment order either asks for payment of demand
amount or assessee can prefer an appeal, within 30 days
If the assessee could not prefer an appeal within 30 days for
genuine reasons, after 30 days, it can file an appeal along
with condonation of delay
If the appeal as well as the condonation of delay is filed
before the cut-off date of 31.01.2020, whether that would be
eligible for the purpose of the Scheme
The above needs to be accepted and addressed
appropriately in Frequently Asked Questions (FAQs)
19. Computation of the limit of disputed tax in search cases
The limit of disputed
amount of Rs. 5
crores in search
cases shall be
computed year
wise
i.e. for each year of
block assessment
years
For instance, in a
search case where
the aggregate
disputed tax for 2 or
more years exceeds
Rs.5 crores,
a person can file
declaration for
those years in
which the disputed
tax amount does
not exceed Rs.5
crores
20. Appeal filed has the effect of reducing returned losses
Two options are provided to the tax-payer under the Bill in this regard:-
• Tax-payer can make the payment of notional tax pursuant under the Bill and carry forward
the actual returned loss or
• Pay nothing under the Bill and carry forward the reduced losses
21. Practical difficulty in acquiring the proof of withdrawal
After submission of declaration, the authorities has to grant
certificate, determining the amount, within 15 days
Tax-payer needs to pay the determined amount within 15
days
Proof of withdrawal of appeals and claims needs to be
submitted by tax-payer along with intimation of payment
It may be practically difficult to get proof of withdrawal is
appeal or petition is filed with higher authorities like High
Court or Supreme Court, considering the inherent limitation
22. Effect on other appeals on similar issues for other assessment
years
Declaration
has to be made
for all AYs if
appellant
seeks benefits
for all AYs
and does not
extend any
other AYs,
even though
similar
grounds of
appeal
will be in
connection with
the appeals
pending for a
particular AY
It is significant
to notice that
the
declaration
filed by the
taxpayer
under the Bill
23. Proof of Withdrawal
When appellant has to
submit proof of withdrawal
of appeal from High Court or
Supreme Court
Whether only application for
withdrawal shall suffice or
The appeal needs to be
actually withdrawn in
process?
The issue needs to be
addressed in FAQs
24. Refund of penalty amount
Before declaration,
full amount of tax
and specified
percentage of
penalty paid
If the said person
opts for the
Scheme in the Bill
The penalty
amount, in relation
to the disputed tax,
can be refunded as
per the amended
provision
25. Multiple issues in relation to a single appeal
There may be instances where multiple issues are part of
a single appeal
On some issues, the assessee may expect a favourable
outcome and on some others, there may be adverse
outcome anticipated
In such a scenario the assessee is not allowed to sever a
part of appeal for the Scheme proposed under the Bill
and the balance under normal appellate proceedings
26. Discretionary power for rejecting declaration
if the applicant
is ineligible
as per
Section 9
(Non-
applicability)
However, the
Authorities
may reject an
application
has no
discretionary
power to
reject anyone
from opting
under the Bill
The
Designated
Authority who
are bound by
the Bill,
27. Payment of determined amount in parts
There is no clarity as to whether declarant can pay amount determined under the Bill in
multiple parts,
even though within the given time period of 15 days
28. Cases for Protective Assessment
In case of tax-payer,
protective
assessment is
being done
Subsequently
substantive
assessment has
been completed
Whether tax-payer
needs to opt for
scheme for both
type of
assessments
The issue needs to
be addressed in
FAQs
29. Reduction in demand amount from the original amount as on
31.01.2020
The final
certificate shall
consider the
reduced amount
of ‘X-1’ and not
the amount of
‘X’ as on
31.01.2020
Before the issue
of final
certificate
The demand
amount reduces
to ’X-1’ for any
reason from the
intimation
received from
department’s
end
If the assessee
opts for the
Scheme with
the demand
amount of ‘X’ as
on 31.01.2020
30. Conclusion
The Bill is expected to be laid down in the Parliament around 1st week of March,
where it will receive assent of both the Houses, subject to modifications if any
It is expected that the department shall additionally issue FAQs to address
the concerns related to the Bill
The success of the Scheme proposed in the Bill depends on how the issues
faced by the stakeholders are addressed