Income Computation & Disclosure Standards (‘ICDS’) 2_7_8_Delhi Chapter of CTC... · June 2017...

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June 2017 Income Computation & Disclosure Standards (‘ICDS’) – Second half : Chamber of Tax Consultants – June, 2017 – Noopur Agashe and Amit Agarwal

Transcript of Income Computation & Disclosure Standards (‘ICDS’) 2_7_8_Delhi Chapter of CTC... · June 2017...

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June 2017

Income Computation & Disclosure Standards (‘ICDS’) – Second half : Chamber of Tax Consultants – June, 2017 – Noopur

Agashe and Amit Agarwal

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Contents

Case Study on securities4

ICDS – VII: Government Grants1

Case Study on government grants2

ICDS – VIII: Securities3

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ICDS – II: Valuation of Inventories5

Case Study on Inventories6

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1ICDS – VII:

Government Grants

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ICDS – VII: Government grants

• Government,

• Government agencies and

• Similar bodies whether local, national or international.

Government

Assistance by government in cash or kind to an enterprise for past or future compliance.

Government Grants

Exclusions from the scope of ICDS:

• Assistance other than in the form of Government grants.

• Government participation in the ownership of the enterprise.

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ICDS - VII: Government Grants – Accounting of government grants under ICDS

Recognition criteria

Assurance of compliance of terms and conditions

Reasonable assurance that grant shall be received

No postponement beyond actual date of receipt

Broadly, Government grant can be of following categories:

Grant relatable to fixed asset

Grant relatable to other than fixed asset

Reasonable assurance means that the entity will comply with the conditions attached to the grant and that the grant will be received

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ICDS – VII: Government grants - Impact

To clear the anomaly, definition of income under section 2(24) of the Act was been amended with effect from April 1, 2015 to provide that:

• Assistance in form of subsidy or grant or cash incentive or drawback or reimbursement by Government in cash or kind shall be income of the assesse

ICDS requires recognition of any subsidy as income

which is conflicting with the Act.

“assistance in the form of a subsidy or grant or cash incentive or duty drawback or waiver or concession or reimbursement (by whatever name called) by the Central Government or a State Government or any authority or body or agency in cash or kind to the assessee 17[other than the subsidy or grant or reimbursement which is taken into account for determination of the actual cost of the asset in accordance with the provisions of Explanation 10 to clause (1) of section 43]”

Extract of Section 2(24)(xviii)

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ICDS – VII: Government grants - Impact

Explanation 10 of Section 43(1) of the Act

Where a portion of the cost of an asset acquired by the assessee has been met directly or indirectly by Central Government or a State Government or any authority established under any law or by any other person, in the form of a subsidy or grant or reimbursement (by whatever name called), then, so much of the cost as is relatable to such subsidy or grant or reimbursement shall not be included in the actual cost of the asset to the assessee:

Provided that where such subsidy or grant or reimbursement is of such nature that it cannot be directly relatable to the asset acquired, so much of the amount which bears to the total subsidy or reimbursement or grant the same proportion as such asset bears to all the assets in respect of or with reference to which the subsidy or grant or reimbursement is so received, shall not be included in the actual cost of the asset to the assessee.

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ICDS - VII: Government Grants – Treatment of government grants under ICDS

Grant relatable to fixed asset.

Attributable to specific asset

• Reduce cost or block WDV

Not attributable to specific asset but to the block of assets

• Reduce cost or WDV in proportion.

Grant at Concessional rate

• Account on basis of acquisition cost

Refund to Government on non-fulfillment of obligations

• To be added to the cost of the asset

• Depreciation allowance to be claimed prospectively.

Disclosure

• The nature and amount reduced from cost in the Previous Year (‘PY’)

• Nature and amount not reduced from costs in the PY with reasons.

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ICDS - VII: Government Grants – Treatment of government grants – Contd.

Grant other than fixed assets

Non- depreciable assets

Income in the period over which cost of

meeting such obligation is charged

to incomeIncome in the period of their costs.

All other grants other than impacting cost of asset

Income in the period of receivable.

Grant received as compensation for expenses or losses or as financial support

RefundsAdjusted against any

unamortised deferred creditBalance to be debited to

Profit & loss Account

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ICDS - VII: Government Grants – Disclosure requirement under ICDS

DisclosureNature and amount recognized

as Income for the PY

Nature and amount not recognized as income for the

PY with reasons

Concluding Thoughts

With effect from April 1, 2015 - ICDS guidelines are in line with the provisions of the Income-tax Act, 1961

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Topic ICDS – 7 AS –12 Ind-AS

Recognition Recognition of grants not to be postponed beyond the date of actual receipt or fulfilment of conditions which ever is earlier

AS-12 provide for postponement of government grant beyond the date of actual receipt where condition attached to the grant are not fulfilled.

Similar to AS

Recognition -Depreciable asset

Grant relating to a depreciable asset to be deducted from the cost/WDV of the asset and cannot be treated as deferred income.

Grants for fixed assets are presented either by deducting from gross value of the asset or as deferred income.

Grants related to assets including non-monetary grants at fair value, should be presented in balance sheet as deferred income.

Recognition -Non-depreciable asset

Grant relating to a non-depreciable asset to be recognised as income over the same period of the cost being charged.

Grant relating to a non-depreciable asset to be credited to capital reserve.

Recognition –Promoter contribution

To be recognised as income over the same period of the cost being charged.

Capital grants in nature of promoter’s contribution are treated as capital reserve.

Government grants are not directlycredited to shareholders’ interests.

Compensation for losses

Compensation for losses –disclosed

Not required to be disclosed Similar to AS

ICDS - VII: Government Grants – ICDS vs AS – Quick snapshot

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ICDS - VII: Government Grants – Points to ponder

• ICDS provisions in line with the provisions of the Act

• Subsidy, grant, etc., (other than reduced from actual cost) to be treated as income

• Relevance of “Purpose” test ignored (i.e. capital v revenue in nature)

Thoughts on the amendment

• Carbon credits from other agencies

• Prepayment of sales tax under deferral scheme

• Promoter contribution by Government

• Whether recognition of government grant can be postponed beyond the date of actual receipt?

How the below should be treated for tax?

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ICDS - VII: Government Grants – Judicial precedents overruled

Subsidy granted for setting up new unit/expansion of existing business is a capital receipt. (Sahney steel & press works Ltd. (228 ITR 253 (SC)), PonniSugars & Chemicals Ltd. (306 ITR 392) (SC))

Subsidy to setup a new unit in a backward area – Capital receipt. (Reliance Industries Ltd. (339 ITR 632) (Bom))

Subsidy for construction of multiplex theatre complexes – Capital receipt(Chaphalkar Brothers (351 ITR 309) (Bom))

Incentive by way of additional quota for free sale of sugar for setting up a new sugar factory/expansion –Capital receipt (Kisan Sahkari Chini Mills Ltd. (2 taxmann.com 274) (Allahabad))

Grant given for research in the field of telecommunications, which in turn would benefit the Nation and public at large, has been held as capital receipt. (India Telephone (215 Taxman 82) (Karnataka))

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2ICDS: VII –

Government grants – Case

study

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Case Study 1 – On timing of recognition of grant…

Export of goods

Export customers

Import supplier

Local suppliers

Importer

ICo Sells duty credit

Purchase of inputs

Timing of recognition of Export incentives

Facts

• I Co manufactures goods from locally sourced materials and exports them

• I Co is entitled to duty credit on exports which it can either itself use to import goods without payment of duty or sell the credit to other importers

• I Co recognized duty credit in Year 1 of Rs.1 Cr. on export made during Year 1

• The duty credit was actually used in Year 2 partly by importing goods and partly by sale to other importers

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Case Study 1 – On timing of recognition of grant

Book Treatment as per

ICAI AS

• AS-12 permits I Co to recognise duty credit of Rs.1 Cr in Year 1 since there is reasonable assurance of compliance of attached conditions and reasonable certainty of ultimate collection

1 (358 ITR 295) (SC)

Tax Treatment post ICDS

• ICDS requires recognition in Year 1 inlinewith AS-12

• ICDS further provides recognition cannot be postponed beyond date of actual receipt

Tax Treatment pre ICDS

• SC ruling in Excel Industries1 permits I Co to recognise duty credit of Rs.1 Cr in year 2 when there is actual import or sale of duty credit

• But, tax recognition in Year 2 may create MAT mismatch in Year 1

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Case study 2 – Stamp duty concession for land…

I CoStamp duty

exemption forland

Buys land in backward area for

setting upunit

Land

State Govt

Facts

• I Co buys land at cost of Rs.20 Cr. in Year 1 in backward area pursuant to package scheme of incentives offered by State Government

• I Co has obligation to set up industrial unit & provide certain level of employment

• I Co is exempted from paying stamp duty of Rs. 1 Cr

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Case study 2 – Stamp duty concession for land

Book Treatment asper ICAI AS-12

• As per Expert advisory committee of ICAI, exemption from statutory levies not covered within scope of AS- 12 (Position may change under Ind-AS)

• I Co. can recognize land cost at Rs. 20 Cr

Tax Treatment post ICDS

• ICDS requires subsidy related to assets and/or subsidies other than assets to be recognized as income (over a period matching with incurrence of related costs). Accordingly, the stamp duty concession of INR 1 Crore would be taxedas per ICDS – 7.

Tax Treatment pre ICDS

• Arguably, subsidy in given facts, is non-chargeable capital receipt if primary object of subsidy can be substantiated to be for promoting industrialization and employment in backward area

• Land cost is arguably Rs. 20 Cr

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Case study 3 – Grant related to depreciable fixed asset

• Co. A has received grant of Rs. 10 crore from Rajasthan Government to procure a plant worth Rs. 25 Crores to be used in manufacturing unit based in Alwar .

• How this plant should be recognized as per ICDS.

Balance sheet

Asset 25 Crore

Grant -10 Crore

Net Amount to be shown as per ICDS 15 Crore

No difference in Pre and Post ICDS implication – subsidy will be reduced from the cost of asset

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Case study 4 – Grant related to non depreciable fixed asset(with condition)

Balance sheet

Asset

Land 25 Crore

Liabilities 10 Crore

Grant (deferred revenue)

Grant of 10 crore will be recognized as income in P&L

over the period of 5 years.

• Co. A has received grant of Rs. 10 crore from Rajasthan Government to procure land worth Rs. 25 Crores on which A will construct the plant.

• As condition, Company needs to keep 1000 local work force for next 5 years, else government will ask for refund of the grant on pro-rata basis.

• How this plan should be recognized as per ICDS.

Pre ICDS – grant would be regarded as capital receipt under capital reserve

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Case study 5 – Grants related to non depreciable assets(without obligation)…

I Co. GOI

Land

Subsidy for meeting cost of land

Buys land in backward area for setting up of unit

• I Co buys land at cost of Rs. 10 cr. in year 1 in backward area pursuant to package scheme of incentives offered by Government

• I Co has obligation to set up Industrial unit

• I Co receives subsidy of Rs. 2 Cr. FromGovernment for meeting cost of land in year 3 after setting up of unit

Facts

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Case study 5 – Grants related to non depreciable assets(without condition)

Book treatment as perICAI AS

• I Co. can recognize subsidyof Rs. 2 cr:

• In capital reserve in balance sheet

Tax treatment pre ICDS

• Pre amendment to income definition. arguably subsidy in given facts is non chargeable capital receipt

• Finance Act 2015 amended definition of income to includes government subsidy which is not adjustable in the “cost of asset”

Tax treatment post ICDS

• Income includes government subsidy which is not adjustable in the “cost of asset”

• ICDS recognition of grant as income over a period matching with incurrence of related cost i.e. purchase of land in year 1.

• Hence, subsidy income to be offered to income in year 1.

PRE Amendment

POST Amendment

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Case study 6 – Non Monetary grants

Balance sheet

Asset 50 lac

Grant -20 Lac

Net Amount to be shown as per ICDS 30 Lac

Accounted for on the basis of their acquisition cost

• Company A has received the land worth Rs. 50 lakhs from the Government by just payingRs. 30 Lakhs only. This will be used for the construction of new plant which will ultimately generate jobs in the society.

• How this grant will be recognized as per ICDS

No difference in Pre and Post ICDS implication

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Case study 7 - Refund – Depreciable asset

Pre ICDS

Since there was no certainty that the conditions would be fulfilled, grant should not be recognized in year 1 as it can be argued that there was no reasonable assurance that the A will comply with the conditions attached.

Pre ICDS

2015

Grant will be recognized as it can not be postponed beyond receipt.

• On April 01, 2015 Co. A has received conditional grant of Rs. 10 crore from Rajasthan Government to procure a plant worth Rs. 25 Crores to be used in manufacturing unit based in Alwar. Life of the plant is 10 years.

• There was no certainty of the conditions being fulfilled and in the 2nd year Co. A failed to satisfy the condition. 9 crore out 10 crore has been refunded to the Government

• How this plan should be recognized as per ICDS.

2016

WDV 13.5 Crore

Grant Refund 9 Crore

Asset after refund 22.5 Crore

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3ICDS: VIII –

Securities

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ICDS – VIII: Securities

Covers only those securities held as stock-in-trade.

• Stock brokers• Traders• NBFC’s

Businesses to whom ICDS – 8 is applicable – Indicative list

• Recognition of interest and dividend on securities.• Securities in the business of insurance.• Securities of Mutual fund, Venture capital funds, Banks and Public financial institutions.

Specifically excludes

• Amount for which an asset could be exchanged between a knowledgeable, willing buyer and a knowledgeable, willing seller in an arm’s length transaction.

Fair Value means

• Securities as defined in section 2(h) of the Securities Contract (Regulation) Act, 1956, and excludes derivatives.

Securities means

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ICDS – VIII: Securities – Initial recognition

• Purchase price/ actual cost.

• Directly attributable cost.

• Adjust pre-acquisition interest and dividend.

Recognition at cost of acquisition

Recognition and initial measurement

• Fair value of security so acquiredCost in case of

“exchange”

• Fair value of securities acquiredExchanged for

securities or for another asset

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ICDS – VIII: Securities – Subsequent measurement

Listed –Actual cost

vs. NRV whichever

is lower

Unlisted/listed but

not quoted – Actual

cost

Measurement for the following:

Shares

Debt Securities

Convertible Securities

Any other securities

At the end of previous year

If cost cannot be specifically attributed to the listed securities –could be measured on FIFO basis

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ICDS – VIII: Securities – ICDS vs AS

Criteria ICDS – 8 AS –13 Ind-AS

Securities –Scope

Only securities held as stock in trade fall within the scope of ICDS 8 and long term investments do not fall under this standard.

AS 13 deals with accounting for investments. Stock-in-trade is outside the scope.

Requirements for recognising and measuring financial assets, financial liabilities and some contracts to buy or sell non-financial items by all entities.

Securities –Measurement

If Cost cannot be determined under specific identification method, it should be determined either on basis of FIFO / weighted average method.

In respect of shares, debentures and other securities held as stock-in-trade, the cost of stocks disposed of is determined by applying an appropriate cost formula.

All financial assets are classified as measured at amortised cost or measured at fair value.

Securities –Valuation

Treated as one group each and the total gain / loss of the category is considered: SharesDebtConvertible Any other

Valuation done scrip wise – cost or NRV whichever is less

Assets measured at fair values, gains and losses are recognised entirely in profit and loss (FVTPL), or recognised in other comprehensive income (FVTOCI)

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4ICDS: VIII –Securities –Case study

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Case Study on ICDS – VIII: Securities

Shares Cost NRV

Valuation as per AS 13 Valuation as per ICDS

Lower of cost or NRV -

Individual scrip wise

Lower of cost or NRV -

Category wise

ABC Ltd. 50 40 40

XYZ Ltd. 70 60 60

PQR Ltd. 30 10 10

EFG Ltd. 60 90 60

LMN Ltd. 100 500 100

Total 310 700 270 310

Impact: Category wise valuation results into accelerated taxation since appreciation in the value of

certain securities will be set off against diminution in the value of other securities.

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ICDS – VIII: Securities - Development

AS- 13 ICDS VIII

Pre-acquisition Interest

• AS 13 and ICDS on securities both require that receipt of interest to be deducted from the actual costto the extent attributable to pre-acquisition period.

• Apex court in the case Vijaya Bank (187 ITR 541), the assessee purchased securities. It was contended that the price paid for the securities was determined with reference to their actual value as well as the interest which had accrued on them till the date of purchase.

• It was held that the amounts claimed by the assessee as deduction were not shown to havebeen expended for the purpose of realising the interest and, were, therefore, not allowable as deductible expenditure.

• However, as per the Bombay High Court decision in the case of American Express International Banking Corpn. v. CIT [2002] 125 Taxman 488 (Bom.), it was held that if income from securities is taxed under PGBP, department ought to have taxed interest received from broken period and allow deduction of interest paid for broken period.

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ICDS – VIII: Securities - Convertible debentures

Convertible securities has been recognised as a separate category under ICDS

So long as convertible debentures are not converted into shares, valuation will be under separate category of convertible securities

When convertible debentures are converted into shares, the valuation of shares will move into separate category i.e. of shares

Issue will arise on how conversion should be treated for tax purposes and how cost should be computed for shares acquired on conversion of debentures

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ICDS – VIII: Securities - Convertible debentures - Cont.

In case of capital gains, in view of specific provisions u/s 47(x) and 49(2A), the conversion is exempt from capital gains and cost of debentures is substituted as cost of shares

In case of business income, two views are possible:

• View - 1: The conversion may be regarded as ‘exchange’ and the fair value of shares acquired may be regarded as cost.

• View - 2: Conversion is not equivalent to ‘exchange’ since there is an extinguishment of debentures. Since ICDS is silent, it may be treated as tax neutral event and actual cost of debentures may be substituted as actual cost of shares.

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5ICDS: II –

Valuation of Inventories

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ICDS II - Valuation of Inventories

Scope

• Deals with the valuation of inventories

• Not applicable to valuation of inventories in the following cases:

- Work-in-Progress arising under construction contracts or dealt with by other ICDS

- Shares, debentures and other financial instruments held as stock-in-trade which are covered in ICDS 8

- Inventories of livestock, agriculture and forest products, mineral oils and gases

- Machinery spares used in connection with fixed assets and having irregular use

Ind-AS 2 – Specific exclusion is provided to commodity brokers/traders who are measuring their inventory at fair value less cost to sell.

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ICDS II - Valuation of Inventories

Held for sale* in the ordinary course of business

In the process of production for such sale

In the form of materials or supplies to be consumed in the production process or in the rendering of services

Scope

• Inventories are assets:

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ICDS II - Valuation of Inventories

Cost of purchase

Cost of service

Cost of conversion

Other cost incurred

Cost of inventory

• Borrowing costs attributable to inventories that require >=12 months to bring them to saleable condition as provided under ICDS 9 will have to be inventorized.

• Exclusions from cost

- Abnormal amount of material/labor cost

- storage costs, unless necessary in production process prior to a further production stage

- indirect administration overheads, and

- selling costs and distribution costs

Cost of Inventories

• Cost – ICDS specifies following as components of Cost of inventories

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ICDS II - Valuation of Inventories

Particulars Amount

Purchase price xx

Duties and Taxes

(no exclusion of CENVAT)

xx

Freight inward and other expenses directly attributable

to acquisition

xx

Less: Trade discounts, rebates and similar items xx

Cost of purchase xx

Cost of purchase

Other costCost of conversion

Cost of services (in the case of a service provider shall)

Particulars Amount

Labour cost xx

Supervisory personnel cost xx

Attributable overheads xx

Other cost of personnel directly engaged in providing

the service

xx

Cost of services xx

Particulars Amount

Cost directly related to units of production xx

Systematic allocation of: xx

Fixed production overheads xx

Variable production overheads xx

Cost of conversion xx

Particulars Amount

Costs incurred in bringing the inventory to their present

location and condition

xx

Other cost xx

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ICDS II - Valuation of Inventories

Particulars As prescribed in ICDS

Measurement Cost or Net Realizable Value (‘NRV), whichever is less

Cost of inventories Cost of purchase + Costs of services + Costs of conversion + Other costs incurred to bring inventories to their present location and condition

Borrowing costs attributable to inventories that require >=12 months to bring them to saleable condition will have to be inventorised

Cost of purchase Purchase price + duties & taxes + freight inward + attributable expenditure – rebates,trade discounts.

ICDS prescribes that duties and taxes (even those subsequently recoverable) included in cost of purchase, which is in line with section 145 A for Accounting for Duties and Taxes

Cost of conversion Cost Directly related to units of production + Systematic allocation of Variable production overheads and Fixed production overheads

Amount of Fixed production overheads allocated to each unit cannot decrease on account of fall in production. In such case, excess fixed production overheads to be charged off as expense in that period.

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ICDS II - Valuation of Inventories

Particulars As prescribed in ICDS

Cost of services Labour and other personnel directly engaged in providing service including supervisory and attributable overheads

Cost exclusions Abnormal wastages + Storage costs, unless necessary for further production + Administrative overheads + Selling costs and distribution cost

Cost Formulae Specific Identification Method (applicable for non interchangeable items goods produced & segregated for specific project )

First in First Out Method (‘FIFO’) /Weighted Average Cost (‘WAC’) Method/ Standard Costing/Retail method

Disclosure requirements

• The accounting policy adopted in measuring inventories including cost formulae used;

• Total carrying amount of inventories and its appropriate classification; and

• Where Standard Costing has been used as a measurement of cost, details of such inventories and a confirmationof the fact that standard cost approximates the actual cost.

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ICDS II - Valuation of Inventories

Value of Opening Inventory

• New Business - Cost of inventory available on the day of commencement of business

• Continuing Business - Value of ‘closing inventory’ at the end of the immediatelypreceding previous year

Change of Method of Valuation of Inventory

• Method of valuation once adopted shall not be changed without reasonable cause

• In case of dissolution of a partnership firm or AOP or BOI, notwithstanding whether business is discontinued or not, the inventory on the date of dissolution shall be valued at NRV

Transitional Provisions

• Interest and other borrowing costs, which do not qualify to be a part of inventory valuationas per the standard but is a part of the opening value of inventory, shall be taken into account for determining cost of closing inventory of period beginning on or after April 1, 2016 if it continues to remain part of inventory

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ICDS II - Valuation of Inventories

Particulars As per ICDS 2 As per AS-2 As per Ind AS 2

Cost of services Included in cost of inventories No specific mentionin AS-2

No Specific mention inInd AS 2

Exclusive vs inclusive method of accounting

Value of inventories to include all taxes and duties, whether recoverable in future or not

Value of inventories to exclude duties and taxes recoverable in the future

-

Observations:

• Duties/taxes recoverable by from the tax authorities to be included in valuation of inventory

• In line with section 145A (refer Explanation to section 145A)

Other costs includible in the value of inventories

ICDS 2 does not specifically exclude distribution cost in the value of inventories

AS-2 excludesdistribution costs in the value of inventories

Ind AS similar in this respect to ICDS 2

Observations:

• Distribution costs, if any, be included in cost of inventory

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ICDS II - Valuation of Inventories

Particulars As per ICDS 2 As per AS-2 As per Ind AS 2

Value of Inventory at the beginning of the previous year

New business - Cost at the day of commencement of business

Continuing business – value of closing inventory at the end of preceding previous year

There is no such specific provision

-

Valuation of Inventory –Interest and other borrowing costs

Interest and other borrowing charges shall be inventorised as per ICDS – 9

Usually, not covered in AS-2 Usually, not covered inInd AS-2

Observations:

• Such costs shall be included in the cost of inventory

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ICDS II - Valuation of Inventories

Particulars As per ICDS 2 As per AS-2 As per Ind AS 2

Valuation of inventories in certain case of dissolution

Notwithstanding whether business is discontinued or not, the inventory on the date of dissolution shall be valued at the net realisable value#

No such provision Notwithstanding whether business is discontinued or not, the inventory on the date of dissolution shall be valued at the net realisable value#

Observations:

As per SC in Sakthi Trading Co and other judicial precedents:

• dissolution + discontinuation = market value

• dissolution + continuation = lower of cost or market value

• Whether the above law still prevails? No?

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ICDS II - Valuation of Inventories

Particulars As per ICDS 2 As per AS-2 As per Ind AS 2

Scope – Exclusion of Shares, Debentures and other Financial Instruments held as Stock-in-trade

Excluded only if covered under ICDS – 8

Unconditional exclusion -

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6ICDS: II –

Valuation of Inventories –

Case study

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Case study I– Valuation of Opening Inventory

ABC Ltd. Closing Stock

Opening stock valued as per FIFO method

Valuation-Weighted

Average Method

• ABC Ltd. changed its valuation method to weighted average method

• ABC Ltd. valued its stock at FIFO method since so many years

• AO asked the tax payer to follow the weighted average method for opening stock as well

• AO is not correct in asking the tax payer tochange the method of valuation for opening stock as per ICDS 2

Treatment under ICDS

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Noopur AgasheDirector– Corporate and International TaxationOffice : + 91 (124) 3306689Mobile: : +91 9810064294Email : [email protected]

Noopur Agashe is a Director in PwC’s Tax and Regulatory Services team and has over 13 years of extensive professionalexperience in advising large Indian and multi national clients in income tax matters, assisting in tax compliances andproviding litigation support services.

Noopur has worked with companies in the technology, mining, retail and automotive industries.

Her core expertise includes providing direct tax compliance and litigation support and advising on domestic and internationaltax matters

Noopur holds a graduate degree in Commerce and is a member of the Institute of Chartered Accountants of India.

Noopur Agashe: A Brief Profile

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Amit AgarwalAssociate Director – Corporate & International Tax, PwC India

Office : + 91 (124) 3306681Mobile: : +91 9999772202Email : [email protected]

Amit Agarwal is an Associate Director in PwC’s Corporate & International Tax Services team and has around 7 yearsextensive professional experience in advising large Indian and foreign clients in income tax matters , assisting in taxcompliances and providing litigation support services.

Amit’s domain of expertise are:

• Direct Tax Compliance and Advisory

• International Tax and advising on cross border transactions (both inbound and outbound)

• Direct Tax litigation support

• Tax Due Diligence

• India entry and exit strategy

Amit is a commerce graduate from University of Delhi and is a member of the Institute of Chartered Accountants of India.

Amit Agarwal: A Brief Profile

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Thank you

All views expressed in the presentation are personal in nature