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T A X P A Y E R S O T H E R T H A N
I N D I V I D U A L S , H U F ( S ) A N D
C O M P A N I E 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 tax payers 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 (Forms ITR-5 and ITR-7) as applicable and the impact
of these changes on the tax payers 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 - I T R 5
All persons other than
Individuals, HUFs
and Companies;
Such as Partnership
firms, Limited Liability
Partnerships,
Unincorporated Joint
Ventures
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
Partnership firms opting for
presumptive basis of
taxation and whose total
income does not exceed
INR 50 Lakh
Persons including
companies involved in
charitable, political,
research activities and
education institutions​
D O E S N O T
A P P L Y T O
In such cases, ITR 7 applies.
Read here for changes in
ITR-7
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
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
Purpose of obtaining this
detail could be to obtain
data concerning ‘angel
tax’ or to seek further
details regarding source
of funds in share
investment transactions.
Significant for curbing
black money conversion
practices using share
capital investment route.
Availability of information
could lead
to deeper investigation on
such matters in future.
C O M M E N T
S H A R E H O L D I N G I N U N L I S T E D C O M P A N Y
A P P L I C A B I L I T Y A C T I O N P O I N T
TAX PAY E R S
H O L D I N G S H AR E S
I N AN U N L I S T E D
C O M PAN Y D U R I N G
T H E P R E V I O U S
Y E AR
Need to disclose following
details such as:
▪ Name of the company
▪ PAN
▪ Shares transacted during
the year and other similar
details
Extensive details on the
part of tax payers
required for this
disclosure
Documents concerning
the investment such as
investment proof,
source of funds, credit-
worthiness of
individuals, etc. can be
maintained while
investing, just
in case there are
questions raised in
future
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
TAX PAY E R
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
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
TAX PAY E R
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
Needs 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 0 9
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
TAX PAY E R
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
Needs 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 0
Change introduced in
line with the
provisions of Section
194IB/194I of the Act
wherein the payer
is liable to deduct tax
from the rent income
as the case may be
Mandatory on the
part of tax payer to
disclose PAN/TAN of
the payer in order to
claim the credit of
TDS
C O M M E N T
T D S O N R E N T A L I N C O M 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
TAXPAYER
CLAIMING CREDIT
OF TDS DEDUCTED
BY TENANT
Tax payer needs to disclose the
PAN/ TAN of the tenant (as the
case may be)
The requisite details
should be readily
available.
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 tax payers;
▪ Additional details required to be maintained by
the taxpayer
C O M M E N T
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 C E N T R E
( I F S C )
▪ Disclosure requirement specifically to
allow benefits to tax payer located in IFSC
▪ Automation of benefits in the tax return itself
C O M M E N T
Tax payer to specify, in case he has
presence in IFSC and earns income solely in
convertible foreign exchange
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 manufacturing business need
to mentioned separately
Needs to disclose
Details of trading expenses as well as
receipt from business and profession
needs to mentioned separately
Needs to disclose
1 7 / 0 4 / 2 0 1 9 | P A G E 1 3
I T R - 7
REGISTRATIONS Additional disclosure of registration or approval other than Income Tax
Act
DISCLOSURE FOR
INVESTMENTS
Specific disclosure in respect of value applied towards the objective which
has not been converted into investment as per Section 11(5) of the Act
REVENUE
EXPENDITURE
Detailed disclosure about the establishment & administrative expense and
expenditure on the object of the trust/ institution;
CAPITAL
EXPENDITURE
Specific disclosure in respect to cost of new asset for claim of exemption u/s
11(1A) and sources of funds to meet capital expenditure
SHAREHOLDING
DETAILS
Requires the unlisted companies to disclose the shareholding details, share
application money pending allotment, details of a shareholder who is not a
shareholder at the end of the year but was a director during the year
1 7 / 0 4 / 2 0 1 9 | P A G E 1 4
Go Back To ITR-5
I T R - 7
INCOME AND
EXPENDITURE
Four schedules have been added in respect to income and
expenditure statement claiming exemption under a different section
prescribed under the Income Tax Act
DATE OF
CONVERSION OF
ACCRETED
INCOME
Disclosure for specified date u/s 115TD has been added wherein the
date of conversion of trust into a firm is not eligible for registration as
charitable trust has to be reported
1 7 / 0 4 / 2 0 1 9 | P A G E 1 5
Go Back To ITR-5
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 taxpayers
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 6
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 7

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Key Changes In 2019 In ITR Forms For Non-Corporate Tax Payers Including LLPs

  • 1. T A X P A Y E R S O T H E R T H A N I N D I V I D U A L S , H U F ( S ) A N D C O M P A N I E 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 tax payers 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 (Forms ITR-5 and ITR-7) as applicable and the impact of these changes on the tax payers 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 - I T R 5 All persons other than Individuals, HUFs and Companies; Such as Partnership firms, Limited Liability Partnerships, Unincorporated Joint Ventures 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 Partnership firms opting for presumptive basis of taxation and whose total income does not exceed INR 50 Lakh Persons including companies involved in charitable, political, research activities and education institutions​ D O E S N O T A P P L Y T O In such cases, ITR 7 applies. Read here for changes in ITR-7 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 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. Purpose of obtaining this detail could be to obtain data concerning ‘angel tax’ or to seek further details regarding source of funds in share investment transactions. Significant for curbing black money conversion practices using share capital investment route. Availability of information could lead to deeper investigation on such matters in future. C O M M E N T S H A R E H O L D I N G I N U N L I S T E D C O M P A N Y A P P L I C A B I L I T Y A C T I O N P O I N T TAX PAY E R S H O L D I N G S H AR E S I N AN U N L I S T E D C O M PAN Y D U R I N G T H E P R E V I O U S Y E AR Need to disclose following details such as: ▪ Name of the company ▪ PAN ▪ Shares transacted during the year and other similar details Extensive details on the part of tax payers required for this disclosure Documents concerning the investment such as investment proof, source of funds, credit- worthiness of individuals, etc. can be maintained while investing, just in case there are questions raised in future 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 TAX PAY E R 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. 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 TAX PAY E R 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 Needs 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 0 9
  • 10. 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 TAX PAY E R 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 Needs 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 0
  • 11. Change introduced in line with the provisions of Section 194IB/194I of the Act wherein the payer is liable to deduct tax from the rent income as the case may be Mandatory on the part of tax payer to disclose PAN/TAN of the payer in order to claim the credit of TDS C O M M E N T T D S O N R E N T A L I N C O M 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 TAXPAYER CLAIMING CREDIT OF TDS DEDUCTED BY TENANT Tax payer needs to disclose the PAN/ TAN of the tenant (as the case may be) The requisite details should be readily available. 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 tax payers; ▪ Additional details required to be maintained by the taxpayer C O M M E N T 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 C E N T R E ( I F S C ) ▪ Disclosure requirement specifically to allow benefits to tax payer located in IFSC ▪ Automation of benefits in the tax return itself C O M M E N T Tax payer to specify, in case he has presence in IFSC and earns income solely in convertible foreign exchange 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 manufacturing business need to mentioned separately Needs to disclose Details of trading expenses as well as receipt from business and profession needs to mentioned separately Needs to disclose 1 7 / 0 4 / 2 0 1 9 | P A G E 1 3
  • 14. I T R - 7 REGISTRATIONS Additional disclosure of registration or approval other than Income Tax Act DISCLOSURE FOR INVESTMENTS Specific disclosure in respect of value applied towards the objective which has not been converted into investment as per Section 11(5) of the Act REVENUE EXPENDITURE Detailed disclosure about the establishment & administrative expense and expenditure on the object of the trust/ institution; CAPITAL EXPENDITURE Specific disclosure in respect to cost of new asset for claim of exemption u/s 11(1A) and sources of funds to meet capital expenditure SHAREHOLDING DETAILS Requires the unlisted companies to disclose the shareholding details, share application money pending allotment, details of a shareholder who is not a shareholder at the end of the year but was a director during the year 1 7 / 0 4 / 2 0 1 9 | P A G E 1 4 Go Back To ITR-5
  • 15. I T R - 7 INCOME AND EXPENDITURE Four schedules have been added in respect to income and expenditure statement claiming exemption under a different section prescribed under the Income Tax Act DATE OF CONVERSION OF ACCRETED INCOME Disclosure for specified date u/s 115TD has been added wherein the date of conversion of trust into a firm is not eligible for registration as charitable trust has to be reported 1 7 / 0 4 / 2 0 1 9 | P A G E 1 5 Go Back To ITR-5
  • 16. 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 taxpayers 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 6
  • 17. 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 7