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C O R P O R A T E T A X P A Y E R S
Key Amendments to Income Tax Return (ITR) Forms
The purpose of this presentation is to highlight the significant
changes in the Income Tax Return forms and their impact, so
that companies can prepare well in advance of due dates of
filing ITRs and avoid last-minute rush/confusions.
H E L L O
The Central Board of Direct Taxes (‘CBDT’) has issued a notification dated
1st April 2019, wherein the amendments have been introduced to the
Income Tax Return forms applicable for Assessment Year (‘AY’) 2019-20​
As per the aforesaid notification, CBDT has brought additional disclosure
requirements in the Income Tax Return forms for the AY 2019-20​
This presentation covers the recently introduced changes in the Income
Tax Return forms (Form ITR- 6) as applicable and the impact of these
changes on the taxpayers at the time of filing the said forms as part of
their tax return procedures.​
B A C K G R O U N D
1 7 / 0 4 / 2 0 1 9 | P A G E 0 3
A P P L I C A B I L I T Y
All companies required
under their annual
corporate tax returns
under the Indian Income
Tax Act, 1961.
Does not apply to companies
engaged in charitable activities
and eligible for claiming tax
exemption
T O W H O M
To annual tax filings
for reporting tax
liabilities for the tax
period ended March
31, 2019 i.e. AY 2019-
20
F R O M W H E N
Form 6 is prescribed for
corporate taxpayers
P R E S C R I B E D
F O R M
1 7 / 0 4 / 2 0 1 9 | P A G E 0 4
Expenses prior to
commencement date are
allowed as deductible
expense in 5 years.
Hence, determination of
date of commencement of
business – Important;
This shall facilitate
automated verification
later
C O M M E N T
C O M M E N C E M E N T O F
B U S I N E S S
A P P L I C A B I L I T Y A C T I O N P O I N T
N E W
B U S I N E S S
S E T- U P
Disclosure of date of
commencement of
business added in
the ITR
Tax payer should
maintain a record of the
expenses incurred prior
to incorporation, post
incorporation but before
commencement and
post-commencement
expenses in order to
determine the
deductibility, which can
be a time-consuming
process
1 7 / 0 4 / 2 0 1 9 | P A G E 0 5
Eligible start-ups are
allowed tax benefits –
exemption from angel
tax and tax exemption
on corporate income
under certain conditions
Such disclosure should
facilitate smoother grant
of tax benefits to eligible
start-ups
C O M M E N T
E L I G I B L E S T A R T - U P S
A P P L I C A B I L I T Y A C T I O N P O I N T
S TAR T- U P S
R E G I S T E R E D
W I T H D P I I T
( E L I G I B L E
S TAR T- U P S )
Such start-ups are now
required to report the
following:
• Recognition number
allotted by DPIIT
• Certificate number
issued by IMB
• Date of filing Form 2
The collation of the
necessary information
pertaining to eligibility
certificate shall not be a
time-consuming process
as all the relevant
information must be
available with tax payer
1 7 / 0 4 / 2 0 1 9 | P A G E 0 6
This disclosure is in
line with CBCR
reporting
requirements and
significant beneficial
ownership
requirement under
the Companies Act,
2013;
This could also be
used as a tool to
track indirect
transfers of interest
or shares outside
India
C O M M E N T
F O R E I G N C O M P A N I E S
A P P L I C A B I L I T Y A C T I O N P O I N T
F O R E I G N
C O M PAN I E S F I L I N G
TAX R E T U R N S I N
I N D I A
Need to disclose the details
of immediate and ultimate
parent company such as:
• Name
• Address
• Country of residence
• PAN (if allotted)
• Tax identification number
allotted in country of
residence
This could be an
onerous requirement,
especially in case
complex holding
structures have been
used for making the
investment in India;
Companies will also
need to keep track of
movements in
shareholding outside
India.
1 7 / 0 4 / 2 0 1 9 | P A G E 0 7
This disclosure has been
introduced in line with
Section 28(via) of the
Act wherein fair market
value of the inventory on
the date of conversion
shall be treated as profit
from business.
C O M M E N T
C O N V E R S I O N O F
I N V E N T O R Y T O C A P I T A L
A P P L I C A B I L I T Y A C T I O N P O I N T
C O M PAN I E S
H AV I N G
C O N V E R T E D
I N V E N TO RY
H E L D TO
C AP I TAL
Need to disclose the
profit on conversion
of inventory into
capital
Collation of the
information pertaining to
fair market value of
inventory shall not be a
time-consuming exercise
for the tax payer as FMV
would, in any case be
required to be computed
for determining the
asset’s value for the
purposes of Act
1 7 / 0 4 / 2 0 1 9 | P A G E 0 8
Onerous disclosure
requirement; This
would essentially
warrant change in
accounting practices
in a way that system
allows capturing of
appropriate data at
the source itself.
C O M M E N T
A S S E T S & L I A B I L I T I E S D I S C L O S U R E
A P P L I C A B I L I T Y A C T I O N P O I N T
UNLISTED AND
START-UP COMPANIES
Need to disclose specific details of
assets/liabilities such as:
▪ Details of land and building
▪ Details of listed, unlisted or other
equity
▪ Details of capital contribution to
any other entity
▪ Details of loans and advances to
any other concern
▪ Details of motor vehicles, aircraft,
yacht or any other mode of
transport
▪ Details of jewellery, etc.
▪ Details of loans, deposit and
advances taken from a person
other than financial institution
Details of each asset
and liability needs to
be prepared
separately. Time-
consuming exercise on
part of tax payer,
hence requisite details
to be collected well in
advance.
1 7 / 0 4 / 2 0 1 9 | P A G E 0 9
Disclosure
requirement in order
to let the Income Tax
Department know
about the income
claimed to be exempt
out of the income
earned from
investment fund or
business trust;
C O M M E N T
P A S S T H R O U G H I N C O M E S
A P P L I C A B I L I T Y A C T I O N P O I N T
C O M PAN I E S
R E C E I V I N G I N C O M E
F R O M I N V E S T M E N T
F U N D S / B U S I N E S S
T R U S T S
Need to disclose the following
details:
▪ Name of the Business
Trust/Investment Fund;
▪ PAN;
▪ Income earned under the
head House Property,
Capital Gains, etc.
▪ Details pertaining to income
claimed to be exempt
Details should usually
be readily available
.
1 7 / 0 4 / 2 0 1 9 | P A G E 1 0
Disallowance of
expenses pertaining to
earning of exempt
income has been a
matter of litigation
Taxpayer and tax officer
invest significant time in
going through this issue
at the time of tax audits;
Earlier, no specific line
item existed for
disallowance u/s 14A.
The addition brings more
transparency through
specific disclosures.​
C O M M E N T
D I S A L L O W A N C E O F E X P E N S E S
A P P L I C A B I L I T Y A C T I O N P O I N T
C O M PAN I E S
N E E D I N G TO
D I S AL L O W
E X P E N S E S
I N C U R R E D TO
E AR N
E X E M P T
I N C O M E S
Need to disclose
amount disallowed as
expenses incurred
towards earning of
exempt income
This disclosure shall
require tax payer earning
exempt income to
calculate the expenses
directly attributable to
exempt income at the
time of filing the income
tax return​
1 7 / 0 4 / 2 0 1 9 | P A G E 1 1
Offering income on presumptive basis, need
to disclose
▪ Registration No. of Carriage;
▪ Ownership Status, i.e., Leased or Owned;
▪ Tonnage Capacity of Carriage;
▪ Number of Months for which goods carriage
was owned/leased/hired;
▪ Presumptive income computed as per
Section 44AE
G O O D S C A R R I A G E
B U S I N E S S
P R E S U M P T I V E I N C O M E S
▪ Allows benefit of presumptive income taxation
to the genuine taxpayers;
▪ Additional details required to be maintained by
the taxpayer
C O M M E N T
Having income from shipping, aircraft,
exploration of oil and gas businesses and
turnkey power projects​businesses
F O R E I G N
C O M P A N I E S
In order to provide convenience to foreign
companies opting presumptive taxation scheme,
disclosure has been simplified and only gross
receipt along with net profit needs to be disclosed
in line with the provisions of the Act
C O M M E N T
Need to disclose gross receipts/turnover and
net profit
1 7 / 0 4 / 2 0 1 9 | P A G E 1 2
M A N U F A C T U R I N G
B U S I N E S S
D I S C L O S U R E F O R
T R A D I N G A N D M F G . B U S I N E S S
▪ Need to maintain separate account with respect to their trading business, manufacturing
business and any other business.
C O M M E N T
T R A D I N G
B U S I N E S S
▪ Collation of information/details pertaining to separate business may be a time-consuming
process as they will now need to bifurcate their income and expenses corresponding to
each line of activity
▪ This would essentially warrant change in accounting practices in a way that the system
allows capturing of appropriate data at the source itself; hence, it is suggested that
companies engaged in combined businesses evaluate internal systems in line
with the said requirement;
A C T I O N
P O I N T S
Details of inventory, manufacturing
expenses and other direct expenses
pertaining to the manufacturing business
need to mentioned separately
Need to disclose
Details of trading expenses as well as
receipt from business and profession
needs to mentioned separately
Need to disclose
1 7 / 0 4 / 2 0 1 9 | P A G E 1 3
▪ Registration No of Carriage;
▪ Ownership Status i.e. Leased or Owned;
▪ Tonnage Capacity of Carriage;
▪ Number of Months for which goods carriage
was owned/leased/hired;
▪ Presumptive income computed as per
Section 44AE
G O O D S C A R R I A G E
B U S I N E S S
I F S C D I S C L O S U R E S
I N T E R N A T I O N A L
F I N A N C I A L
S E R V I C E S
C E N T R E ( I F S C )
▪ Disclosure requirement specifically to
allow benefits to companies located in IFSC
▪ Automation of benefits in the tax return itself
C O M M E N T
Companies to specify, in case they have
presence in IFSC and earn income solely in
convertible foreign exchange
1 7 / 0 4 / 2 0 1 9 | P A G E 1 4
O V E R A L L C O M M E N T S
TRANSPARENCY CBDT has released the tax return forms with an intention to bring more
transparency through specific disclosures.
AUTOMATION Revenue authorities may not call for additional information as they would
now have access to verifiable detailed information.
Greater automated scrutiny with detailed information in the ITRs is
expected. This shall eliminate the need of face-to-face interactions between
the tax officers and tax payers.
BETTER
COMPLIANCE
Better disclosures shall enable the revenue authorities to extend the tax
benefits in a more efficient manner.
TAXPAYERS Taxpayers will need to work on systems to ensure timely and correct data
collation to avoid confusion and last-minute stress.
1 7 / 0 4 / 2 0 1 9 | P A G E 1 5
Disclaimer
This publication does not constitute as professional advice. The information in this publication has been obtained or derived from sources believed by Coinmen Consultants LLP
(Coinmen) to be reliable but Coinmen does not represent that this information is accurate or complete. Any opinions or estimates contained in this publication represent the judgment of
Coinmen at this time and are subject to change without notice. Readers of this publication are advised to seek their own professional advice before taking any course of action or decision,
for which they are entirely responsible, based on the contents of this publication. Coinmen neither accepts or assumes any responsibility or liability to any reader of this publication in
respect of the information contained within it or for any decisions readers may take or decide not to or fail to take. The presentation containsamendments as proposed in the Income tax
Return Forms by Central Board of Direct Taxes (‘CBDT’) through notification amending Income tax Rules, 1962 dated 1st April 2019.
Understanding tax implications
on the income can be confusing as it is.
But, it gets further complicated
when things change every year.
At Coinmen, our aim is to provide
financial expertise and help your business grow.
This presentation is put together
by our team to ensure that you’re prepared
well in advance and can work towards
getting higher returns in the
current financial year.
1 7 / 0 4 / 2 0 1 9 | P A G E 1 6

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Key Changes In 2019 In ITR Forms For Corporate Tax Payers

  • 1. C O R P O R A T E T A X P A Y E R S Key Amendments to Income Tax Return (ITR) Forms
  • 2. The purpose of this presentation is to highlight the significant changes in the Income Tax Return forms and their impact, so that companies can prepare well in advance of due dates of filing ITRs and avoid last-minute rush/confusions. H E L L O
  • 3. The Central Board of Direct Taxes (‘CBDT’) has issued a notification dated 1st April 2019, wherein the amendments have been introduced to the Income Tax Return forms applicable for Assessment Year (‘AY’) 2019-20​ As per the aforesaid notification, CBDT has brought additional disclosure requirements in the Income Tax Return forms for the AY 2019-20​ This presentation covers the recently introduced changes in the Income Tax Return forms (Form ITR- 6) as applicable and the impact of these changes on the taxpayers at the time of filing the said forms as part of their tax return procedures.​ B A C K G R O U N D 1 7 / 0 4 / 2 0 1 9 | P A G E 0 3
  • 4. A P P L I C A B I L I T Y All companies required under their annual corporate tax returns under the Indian Income Tax Act, 1961. Does not apply to companies engaged in charitable activities and eligible for claiming tax exemption T O W H O M To annual tax filings for reporting tax liabilities for the tax period ended March 31, 2019 i.e. AY 2019- 20 F R O M W H E N Form 6 is prescribed for corporate taxpayers P R E S C R I B E D F O R M 1 7 / 0 4 / 2 0 1 9 | P A G E 0 4
  • 5. Expenses prior to commencement date are allowed as deductible expense in 5 years. Hence, determination of date of commencement of business – Important; This shall facilitate automated verification later C O M M E N T C O M M E N C E M E N T O F B U S I N E S S A P P L I C A B I L I T Y A C T I O N P O I N T N E W B U S I N E S S S E T- U P Disclosure of date of commencement of business added in the ITR Tax payer should maintain a record of the expenses incurred prior to incorporation, post incorporation but before commencement and post-commencement expenses in order to determine the deductibility, which can be a time-consuming process 1 7 / 0 4 / 2 0 1 9 | P A G E 0 5
  • 6. Eligible start-ups are allowed tax benefits – exemption from angel tax and tax exemption on corporate income under certain conditions Such disclosure should facilitate smoother grant of tax benefits to eligible start-ups C O M M E N T E L I G I B L E S T A R T - U P S A P P L I C A B I L I T Y A C T I O N P O I N T S TAR T- U P S R E G I S T E R E D W I T H D P I I T ( E L I G I B L E S TAR T- U P S ) Such start-ups are now required to report the following: • Recognition number allotted by DPIIT • Certificate number issued by IMB • Date of filing Form 2 The collation of the necessary information pertaining to eligibility certificate shall not be a time-consuming process as all the relevant information must be available with tax payer 1 7 / 0 4 / 2 0 1 9 | P A G E 0 6
  • 7. This disclosure is in line with CBCR reporting requirements and significant beneficial ownership requirement under the Companies Act, 2013; This could also be used as a tool to track indirect transfers of interest or shares outside India C O M M E N T F O R E I G N C O M P A N I E S A P P L I C A B I L I T Y A C T I O N P O I N T F O R E I G N C O M PAN I E S F I L I N G TAX R E T U R N S I N I N D I A Need to disclose the details of immediate and ultimate parent company such as: • Name • Address • Country of residence • PAN (if allotted) • Tax identification number allotted in country of residence This could be an onerous requirement, especially in case complex holding structures have been used for making the investment in India; Companies will also need to keep track of movements in shareholding outside India. 1 7 / 0 4 / 2 0 1 9 | P A G E 0 7
  • 8. This disclosure has been introduced in line with Section 28(via) of the Act wherein fair market value of the inventory on the date of conversion shall be treated as profit from business. C O M M E N T C O N V E R S I O N O F I N V E N T O R Y T O C A P I T A L A P P L I C A B I L I T Y A C T I O N P O I N T C O M PAN I E S H AV I N G C O N V E R T E D I N V E N TO RY H E L D TO C AP I TAL Need to disclose the profit on conversion of inventory into capital Collation of the information pertaining to fair market value of inventory shall not be a time-consuming exercise for the tax payer as FMV would, in any case be required to be computed for determining the asset’s value for the purposes of Act 1 7 / 0 4 / 2 0 1 9 | P A G E 0 8
  • 9. Onerous disclosure requirement; This would essentially warrant change in accounting practices in a way that system allows capturing of appropriate data at the source itself. C O M M E N T A S S E T S & L I A B I L I T I E S D I S C L O S U R E A P P L I C A B I L I T Y A C T I O N P O I N T UNLISTED AND START-UP COMPANIES Need to disclose specific details of assets/liabilities such as: ▪ Details of land and building ▪ Details of listed, unlisted or other equity ▪ Details of capital contribution to any other entity ▪ Details of loans and advances to any other concern ▪ Details of motor vehicles, aircraft, yacht or any other mode of transport ▪ Details of jewellery, etc. ▪ Details of loans, deposit and advances taken from a person other than financial institution Details of each asset and liability needs to be prepared separately. Time- consuming exercise on part of tax payer, hence requisite details to be collected well in advance. 1 7 / 0 4 / 2 0 1 9 | P A G E 0 9
  • 10. Disclosure requirement in order to let the Income Tax Department know about the income claimed to be exempt out of the income earned from investment fund or business trust; C O M M E N T P A S S T H R O U G H I N C O M E S A P P L I C A B I L I T Y A C T I O N P O I N T C O M PAN I E S R E C E I V I N G I N C O M E F R O M I N V E S T M E N T F U N D S / B U S I N E S S T R U S T S Need to disclose the following details: ▪ Name of the Business Trust/Investment Fund; ▪ PAN; ▪ Income earned under the head House Property, Capital Gains, etc. ▪ Details pertaining to income claimed to be exempt Details should usually be readily available . 1 7 / 0 4 / 2 0 1 9 | P A G E 1 0
  • 11. Disallowance of expenses pertaining to earning of exempt income has been a matter of litigation Taxpayer and tax officer invest significant time in going through this issue at the time of tax audits; Earlier, no specific line item existed for disallowance u/s 14A. The addition brings more transparency through specific disclosures.​ C O M M E N T D I S A L L O W A N C E O F E X P E N S E S A P P L I C A B I L I T Y A C T I O N P O I N T C O M PAN I E S N E E D I N G TO D I S AL L O W E X P E N S E S I N C U R R E D TO E AR N E X E M P T I N C O M E S Need to disclose amount disallowed as expenses incurred towards earning of exempt income This disclosure shall require tax payer earning exempt income to calculate the expenses directly attributable to exempt income at the time of filing the income tax return​ 1 7 / 0 4 / 2 0 1 9 | P A G E 1 1
  • 12. Offering income on presumptive basis, need to disclose ▪ Registration No. of Carriage; ▪ Ownership Status, i.e., Leased or Owned; ▪ Tonnage Capacity of Carriage; ▪ Number of Months for which goods carriage was owned/leased/hired; ▪ Presumptive income computed as per Section 44AE G O O D S C A R R I A G E B U S I N E S S P R E S U M P T I V E I N C O M E S ▪ Allows benefit of presumptive income taxation to the genuine taxpayers; ▪ Additional details required to be maintained by the taxpayer C O M M E N T Having income from shipping, aircraft, exploration of oil and gas businesses and turnkey power projects​businesses F O R E I G N C O M P A N I E S In order to provide convenience to foreign companies opting presumptive taxation scheme, disclosure has been simplified and only gross receipt along with net profit needs to be disclosed in line with the provisions of the Act C O M M E N T Need to disclose gross receipts/turnover and net profit 1 7 / 0 4 / 2 0 1 9 | P A G E 1 2
  • 13. M A N U F A C T U R I N G B U S I N E S S D I S C L O S U R E F O R T R A D I N G A N D M F G . B U S I N E S S ▪ Need to maintain separate account with respect to their trading business, manufacturing business and any other business. C O M M E N T T R A D I N G B U S I N E S S ▪ Collation of information/details pertaining to separate business may be a time-consuming process as they will now need to bifurcate their income and expenses corresponding to each line of activity ▪ This would essentially warrant change in accounting practices in a way that the system allows capturing of appropriate data at the source itself; hence, it is suggested that companies engaged in combined businesses evaluate internal systems in line with the said requirement; A C T I O N P O I N T S Details of inventory, manufacturing expenses and other direct expenses pertaining to the manufacturing business need to mentioned separately Need to disclose Details of trading expenses as well as receipt from business and profession needs to mentioned separately Need to disclose 1 7 / 0 4 / 2 0 1 9 | P A G E 1 3
  • 14. ▪ Registration No of Carriage; ▪ Ownership Status i.e. Leased or Owned; ▪ Tonnage Capacity of Carriage; ▪ Number of Months for which goods carriage was owned/leased/hired; ▪ Presumptive income computed as per Section 44AE G O O D S C A R R I A G E B U S I N E S S I F S C D I S C L O S U R E S I N T E R N A T I O N A L F I N A N C I A L S E R V I C E S C E N T R E ( I F S C ) ▪ Disclosure requirement specifically to allow benefits to companies located in IFSC ▪ Automation of benefits in the tax return itself C O M M E N T Companies to specify, in case they have presence in IFSC and earn income solely in convertible foreign exchange 1 7 / 0 4 / 2 0 1 9 | P A G E 1 4
  • 15. O V E R A L L C O M M E N T S TRANSPARENCY CBDT has released the tax return forms with an intention to bring more transparency through specific disclosures. AUTOMATION Revenue authorities may not call for additional information as they would now have access to verifiable detailed information. Greater automated scrutiny with detailed information in the ITRs is expected. This shall eliminate the need of face-to-face interactions between the tax officers and tax payers. BETTER COMPLIANCE Better disclosures shall enable the revenue authorities to extend the tax benefits in a more efficient manner. TAXPAYERS Taxpayers will need to work on systems to ensure timely and correct data collation to avoid confusion and last-minute stress. 1 7 / 0 4 / 2 0 1 9 | P A G E 1 5
  • 16. Disclaimer This publication does not constitute as professional advice. The information in this publication has been obtained or derived from sources believed by Coinmen Consultants LLP (Coinmen) to be reliable but Coinmen does not represent that this information is accurate or complete. Any opinions or estimates contained in this publication represent the judgment of Coinmen at this time and are subject to change without notice. Readers of this publication are advised to seek their own professional advice before taking any course of action or decision, for which they are entirely responsible, based on the contents of this publication. Coinmen neither accepts or assumes any responsibility or liability to any reader of this publication in respect of the information contained within it or for any decisions readers may take or decide not to or fail to take. The presentation containsamendments as proposed in the Income tax Return Forms by Central Board of Direct Taxes (‘CBDT’) through notification amending Income tax Rules, 1962 dated 1st April 2019. Understanding tax implications on the income can be confusing as it is. But, it gets further complicated when things change every year. At Coinmen, our aim is to provide financial expertise and help your business grow. This presentation is put together by our team to ensure that you’re prepared well in advance and can work towards getting higher returns in the current financial year. 1 7 / 0 4 / 2 0 1 9 | P A G E 1 6