UNION BUDGET - SKP Group€¦ · UNION BUDGET 2014–15. Contents BUDGET 2014 – A Pragmatic...

UNION BUDGET 2014–15

Contents

BUDGET 2014 – A Pragmatic People Policy (PPP) Budget .............................................................. 3

1. DIRECT TAXATION ................................................................................................................ 5

1.1 Rates of Tax ................................................................................................................................................ 5

1.1.1 Effective Tax Rates ............................................................................................................................................. 5

1.2 Personal Taxation ...................................................................................................................................... 5

1.3 Retrospective Taxation .............................................................................................................................. 6

1.4 Direct Tax Code .......................................................................................................................................... 6

1.5 Capital Gains .............................................................................................................................................. 6

1.5.1 Characterisation of income of Foreign Institutional Investors ...................................................................... 6

1.5.2 Short-term capital assets ................................................................................................................................... 6

1.5.3 Forfeiture of advance received for transfer of capital assets ......................................................................... 6

1.5.4 Deduction from capital gains on investments in specified bonds .................................................................. 7

1.5.5 Investments in residential house property ...................................................................................................... 7

1.5.6 Capital gains on sale of mutual fund units ....................................................................................................... 7

1.6 Tax Incentives ............................................................................................................................................ 7

1.6.1 Accelerated deduction for capital expenditure relating to specified business ............................................. 7

1.6.2 Accelerated deduction under section 35AD vs profit-linked deduction for units in a Special Economic Zone .................................................................................................................................................................... 8

1.6.3 Incentive for investment in plant and machinery .......................................................................................... 8

1.6.4 Tax holiday for power sector ............................................................................................................................ 8

1.7 Corporate Social Responsibility ................................................................................................................ 9

1.8 Withholding Tax (TDS) .............................................................................................................................. 9

1.8.1 Time limit for depositing withholding tax for payments to non-residents ................................................... 9

1.8.2 Disallowance of expenditure ............................................................................................................................ 9

1.8.3 Coverage of withholding tax defaults resulting in disallowance of expenditure ......................................... 9

1.9 Concessional rate of tax on dividends from foreign companies ........................................................... 9

1.10 Dividend Distribution Tax ...................................................................................................................... 10

1.11 Special provisions relating to Business Trusts ...................................................................................... 10

1.12 Mode of acceptance or repayment of loans or deposits ....................................................................... 11

1.13 Provisional attachment ........................................................................................................................... 11

1.14 Power of Survey ....................................................................................................................................... 11

1.15 Additional powers to call for information or documents .................................................................... 12

1.16 Filling of Return of Income of Mutual Fund, Securitisation Trust, Venture Capital Company or Venture Capital Fund .......................................................................................................................................... 12

1.17 Estimation of the value of asset/investment/property by the Valuation Officer ................................ 12

1.18 Income computation and disclosure standards .................................................................................... 12

1.19 Withholding tax on payment in respect of Life Insurance policy ....................................................... 13

1.20 Withholding tax on income by way of interest to non-residents from an Indian Company/Business Trust 13

1


1.21 Withholding tax procedural matters ..................................................................................................... 13

1.22 Failure to produce accounts and documents ........................................................................................ 13

1.23 Scope of Advance Ruling ......................................................................................................................... 14

1.24 Scope of Settlement Commission ............................................................................................................ 14

1.25 Speculation Business ............................................................................................................................... 14

2. TRANSFER PRICING ............................................................................................................. 15

2.1 Roll-back mechanism introduced in the Advance Pricing Agreement (APA) Scheme ....................... 15

2.2 Amendment to the definition of international transaction ................................................................. 15

2.3 Clarifications for comparability analysis carried out for an international transaction .................... 15

2.4 Enhancement of the power of Transfer Pricing Officer ....................................................................... 16

3. INDIRECT TAXATION .......................................................................................................... 17

3.1 Customs Duty ........................................................................................................................................... 17

3.1.1 Key changes in the rates of duty for certain products .................................................................................. 17

3.1.2 Procedural/administrative changes................................................................................................................ 17

3.1.3 Other amendments .......................................................................................................................................... 18

3.2 Central Excise Duty.................................................................................................................................. 18

3.2.1 Key changes in rates of duty for certain products ......................................................................................... 18

3.2.2 Procedural/administrative changes................................................................................................................ 19

3.2.3 Other amendments .......................................................................................................................................... 19

3.3 Service Tax ............................................................................................................................................... 20

3.3.1 Ambit of Negative List narrowed.................................................................................................................... 20

3.3.2 Key changes in Mega Exemption List ............................................................................................................. 20

3.3.3 Rationalisation of abatement .......................................................................................................................... 21

3.3.4 Advance Ruling ................................................................................................................................................ 21

3.3.5 Amendments in Chapter V of the Finance Act, 1994 ..................................................................................... 22

3.3.6 Compliances enhancement ............................................................................................................................. 22

3.3.7 Procedural simplification ................................................................................................................................ 23

3.3.8 Changes in Reverse Charge Mechanism ......................................................................................................... 23

3.3.9 Payment of Service Tax ................................................................................................................................... 23

3.3.10 Rationalisation of Service Tax on the Service Portion in a Works Contract ................................................ 23

3.3.11 Changes in Point of Taxation Rules ................................................................................................................ 23

3.3.12 Changes in Place of Provision of Services Rules (POPS) ................................................................................ 23

3.3.13 Changes in CENVAT Credit Rules .................................................................................................................... 24

3.3.14 Clarification on availment by Input Service Distributor .............................................................................. 24

3.4 Goods and Services Tax (GST) ................................................................................................................. 24

2


BUDGET 2014 – A Pragmatic People Policy (PPP) Budget

Before we go on to analyse the first budget of India’s new government, it is important to understand the backdrop in which this budget was presented. The Bharatiya Janata Party (BJP) was voted to power following a high-pitched election campaign by its Prime Ministerial nominee, Narendra Modi, who promised to take India out of its economic paralysis, assuring “Acche din” (good days) for everyone. The results were astonishing – India saw a single-party majority after three decades and the principal party (Congress) that had ruled India for the most part of the last 60 years did not win even 10% of the total legislative seats. It was evident that the Indian electorate wanted change. In such an environment, expectations from this budget were extremely high and the new Finance Minister (FM), Arun Jaitley, had the herculean task of converting pre-poll promises into reality.

Presenting the maiden budget of this 45-day-old government, the FM has tried to please everyone, while prioritising fiscal prudence over mere populism. Aiming to fulfil the government’s promise of development, the FM announced steps to achieve sustained growth of 7–8% in the next 3-4 years, along with macroeconomic stabilisation that includes lower inflation, lesser fiscal deficit and a manageable current account deficit.

Given the challenges of the current economic situation, it was commendable that the FM retained the daunting fiscal deficit target of 4.1% of GDP for FY 2014-15 set by his predecessor. With the slowdown in growth in recent years, it would have been easy to go on a spending spree in order to fulfil pre-poll promises. His road map for fiscal deficit reduction is also impressive with a target of 3.6% for FY 2015-16 and 3% for FY 2016-17. To put these figures into perspective, a 0.1% change in fiscal deficit would result in the government saving or spending approximately USD 1 billion (around INR 60 billion). The fiscal deficit target seems to be very ambitious since it is based on 19.7% growth in tax revenue. This may be one of the greatest challenges given the current situation where average corporate earnings are up by around 10% and the dark clouds of an unpredictable monsoon linger.

One of the ways he proposes to achieve the targeted growth rate is by fuelling investments in infrastructure and manufacturing. This would help boost job creation as well. The budget aims at creating an environment conducive to start-ups, mainly in the private sector, and has announced an innovative INR-100-billion fund to spur India’s entrepreneurial spirit. Similarly, there were several small but structurally significant policy changes based on which the FM hopes to revitalise the India growth story.

With respect to foreign direct investment (FDI), the limits for FDI in the insurance and defence sectors have been increased from 26% to 49%, clearly reflecting the government’s approach and its commitment to rely on foreign investments to stimulate the Indian economy.

The budget gives a significant thrust to the infrastructure and real estate sectors. Typically, banks and financial institutions avoided funding these sectors. The FM has attempted to correct this with his out-of-the-box thinking and relaxed the cash reserve ratio (CRR) and statutory lending norms (SLR) for long-term money from banks for infrastructure financing. There are more specific plans for roads, ports, airlines and the power sector. Allowing the creation of Real Estate Investment Trusts (REITs) is also a good idea and should increase the depth of the real estate market. In consonance with the sop to people who avail home loans, this is a significant positive development for a sector that has not seen much good news in the past few years.

On the taxation front, the FM said the government would avoid retrospective taxation, being committed to providing a stable and certain tax regime. However, there was no respite for the existing disputes which would take their own course. (This means the Vodafone issue on the matter of indirect transfer remains unresolved and lingers). Nevertheless, all fresh cases arising out of retrospective amendments of 2012 with respect to indirect transfers will be scrutinised by a High Level Committee to be constituted by the Central Board of Direct Taxes (CBDT) before any action is initiated. The other amendments proposed on transfer pricing signal the government’s readiness to align the existing provisions with global best practices. However, the fine print on a

3


few aspects of transfer pricing is missing even in the Finance Bill, and will be announced separately in the future.

The government reaffirmed its commitment to the Goods and Services Tax (GST) and the Direct Taxes Code (DTC), although it would have been good to have a timeframe for their implementation. On the indirect taxation front, in order to boost domestic manufacturing and address the issue of inverted duties, basic customs duty (BCD) has been reduced on certain items. The FM has proposed to broaden the tax base by bringing certain transactions under the purview of Service Tax. In order to facilitate trade, the ‘Indian Customs Single Window Project’ would be implemented. Conducive steps are also being taken to expedite the process of disposal of appeals.

Overall, with this eagerly awaited budget, the government has made all the right noises and has taken some baby steps to revive the economy. We hope these potentially transformative steps will make the Indian economy sprint in the coming years!

Source: Union Budget 2014-15, Government of India 4

http://indiabudget.nic.in/budget.asp


1. DIRECT TAXATION

All the proposals discussed below are proposed to be applicable from 1 April 2014, unless otherwise stated.

1.1 Rates of Tax

No changes proposed in the tax rates for any taxpayer (corporate and non-corporate)

Basic exemption limit for non-corporate taxpayers proposed to be increased from INR 200,000 to INR 250,000.

Basic exemption limit for resident individuals between 60 and 80 years of age (senior citizens) proposed to be increased from INR 250,000 to INR 300,000.

Surcharge and education cess continue to be levied at the same rates.

1.1.1 Effective Tax Rates

Category of Taxpayer Effective Tax Rate

Individuals earning more than INR 10 million 33.99%

Corporate Tax – Domestic Company

Income less than INR 10 million 30.90%

Income from INR 10 million to INR 100 million 32.445%

Income more than INR 100 million 33.99%

Corporate Tax – Foreign Company


Income from INR 10 million to INR 100 million 42.024%

Income more than INR 100 million 43.26%

Firm/Limited Liability Partnership (LLP)


Income of INR 10 million or more 33.99%

1.2 Personal Taxation

Deduction for interest on housing loan with respect to self-occupied house property proposed to be increased from INR 150,000 to INR 200,000.

Deduction under section 80C proposed to be increased from INR 100,000 to INR 150,000.

For taxpayers engaged in the business of plying, hiring or leasing goods carriages and owning not more than 10 goods carriages:

• The taxable income of such taxpayers would be presumed to be INR 7,500 per month or part thereof per goods carriage or actual income earned, whichever is higher;

• The distinction between Heavy Goods Vehicle (HGV) and vehicle other than HGV is proposed to be done away with.

5


1.3 Retrospective Taxation

The previous Finance Bill had introduced certain tax provisions with retrospective effect. The provisions were aimed at charging to tax, transactions taking place outside India where the underlying assets being transferred were situated in India or the asset transferred derived substantial part of its value from the underlying Indian asset.

These provisions severely affected investor sentiment and created doubts about the fairness and transparency of the Indian tax regime.

The Finance Bill has not proposed to remove the retrospective tax provisions. However, the Finance Minister has clarified as follows:

• Retrospective tax would be avoided, unless absolutely necessary.

• For cases that are presently under litigation due to the retrospective tax provisions, the legal procedure would be followed.

• For new cases sought to be covered under retrospective tax provisions, no action will be taken against the taxpayer unless the same is reviewed by a High Level Committee of the Central Board of Direct Taxes (CBDT).

Since the above is more of a ‘statement of intent’ on the part of the government, these provisions do not find way as legal provisions in the Finance Bill 2014.

1.4 Direct Tax Code

In his budget speech, the Finance Minister mentioned that the new government will consider the comments received from stakeholders, will review the Direct Tax Code in its present shape and take a view on the whole matter.

No comments on the same where incorporated in the Finance Bill.

1.5 Capital Gains

1.5.1 Characterisation of income of Foreign Institutional Investors

Foreign Institutional Investors (FIIs) faced uncertainty as to whether their income will be considered as business income or as capital gains. It is now proposed to amend the definition of ‘capital asset’ to treat securities held by FIIs as capital assets and the income arising from transfer of the securities as capital gains.

This clarification will be applicable from 1 April 2014.

1.5.2 Short-term capital assets

Presently, unlisted shares and units of Debt Funds are considered as short-term capital assets if the taxpayer holds them for up to 12 months. It is now proposed to increase the time period for these assets from 12 months to 36 months. Short-term capital assets attract a higher rate of tax as compared to long-term assets.

1.5.3 Forfeiture of advance received for transfer of capital assets

If a taxpayer receives any advance payment for transfer of capital assets and if for any reason, the advance is forfeited by him, presently the amount forfeited is reduced from the cost of the capital asset. Thus, the advance forfeited becomes taxable in the year of actual transfer of capital asset by way of increased amount of capital gains (since cost is reduced by the amount forfeited).

6


To overcome such deferment of tax, it is now proposed to consider the forfeited sums of money, received as advance or otherwise, as ‘Income from Other Sources’ in the year of forfeiture. As a natural corollary, when the advance forfeited is taxed as Income from Other Sources, it is proposed that the amount so forfeited will not be reduced from the cost of the asset for calculation of capital gains.

1.5.4 Deduction from capital gains on investments in specified bonds

Presently, exemption for capital gains can be availed by making investments in specified bonds within six months from the date of transfer of capital asset. The law also provides that the amount invested in the specified bonds cannot exceed INR 5 million during any financial year.

The wordings ‘any financial year’ created a possibility that a taxpayer who transferred his capital assets towards the end of the financial year could invest INR 100 million in specified bonds by spreading the investment over two financial years, but within the window of six months from date of transfer of capital asset.

This created a favourable position for taxpayers transferring capital assets towards the end of the financial year as against taxpayers who transferred capital assets at the beginning of the financial year.

To bring parity, it is proposed that for capital gains arising in one financial year, the investment in specified bonds made in that year as well as subsequent years would be restricted to INR 5 million.

1.5.5 Investments in residential house property

The Income Tax Act provides exemption from capital gains arising from transfer of residential house property or other long-term capital assets if the capital gains are reinvested in ‘a’ residential house property, subject to certain conditions.

Doubts had arisen as to whether the term ‘a residential house property’ means ‘one residential house property’. Certain Courts had taken a view that ‘a residential house property’ does not mean ‘one residential house property’. Further, since the law did not expressly so provide, investments made outside India were also being considered for exemption.

It is now proposed to be clarified that the exemption from capital gains will be restricted to investment in ‘one’ residential house property located in India.

1.5.6 Capital gains on sale of mutual fund units

Under the existing law, capital gains arising on transfer of units of Mutual Funds, other than units of equity-oriented funds, held for more than a year are taxed at a concessional rate of 10% without any indexation benefit, or at a rate of 20% with indexation.

It is now proposed to do away with the concessional rate of tax of 10% for such units. These units will now be taxed at normal rate of tax of 20% applicable to long-term capital gains.

1.6 Tax Incentives

1.6.1 Accelerated deduction for capital expenditure relating to specified business

Section 35AD provides for 100% deduction for capital expenditure incurred in relation to specified infrastructure development businesses.

It is proposed to include two new businesses in the definition of a ‘specified business’, namely:

• Laying and operating a slurry pipeline for the transportation of iron ore;

7


• Setting up and operating a semiconductor wafer fabrication manufacturing unit, if such unit is notified by the CBDT in accordance with the prescribed guidelines.

Thus, the taxpayer will be eligible to claim capital expenditure incurred in relation to the above businesses in entirety, in the year of incurrence of the expenditure. This benefit will be available where the date of commencement of operations of the specified business is on or after 1 April 2014.

The asset for which accelerated deduction is claimed should be used for the specified business for a minimum of eight years from the year of acquisition of the asset.

If the asset is used for a purpose other than the specified business, the benefit obtained under section 35AD will be considered as business income and taxed accordingly. The amount chargeable to tax will be the deduction claimed under section 35AD reduced by the amount of depreciation that would be allowable on the asset, if deduction under section 35AD was not claimed. This provision will not apply to a sick industrial company.

1.6.2 Accelerated deduction under section 35AD vs profit-linked deduction for units in a Special Economic Zone

Presently, where the taxpayer operates in a Special Economic Zone (SEZ), he is eligible to claim a tax incentive of 100% or 50% of export profits under section 10AA of the Income Tax Act.

It is now proposed that where the taxpayer carries out a business specified under section 35AD and operates in an SEZ, the taxpayer will be eligible to obtain either:

• The tax incentive based on export profits under section 10AA, or

• Accelerated deduction for capital expenditure under section 35AD.

That is, both benefits cannot be simultaneously claimed.

1.6.3 Incentive for investment in plant and machinery

In order to encourage additional investment in the manufacturing sector, it is proposed to provide an additional deduction of 15% of the total investment in new plant and machinery to companies engaged in manufacturing activities.

This benefit is available where the cost of new plant and machinery acquired and installed during the tax year exceeds INR 250 million.

This benefit is available for the period from 1 April 2014 to 31 March 2017. The limit of INR 250 million will separately apply for each year.

The deduction of 15% of cost of plant and machinery is over and above the depreciation allowed on the cost of plant and machinery.

Under the present law, companies are eligible to claim additional deduction for 15% of cost of plant and machinery if the investment in plant and machinery made during the period 1 April 2013 to 31 March 2015 is INR 1 billion or more. The proposed incentive is separate from this incentive. However, the existing incentive and the proposed incentive cannot be simultaneously claimed.

1.6.4 Tax holiday for power sector

The Income Tax Act provides tax holiday of 10 years for undertakings engaged in generation, transmission and distribution of power.

The tax holiday was set to expire on 31 March 2014.

8


It is now proposed to extend the tax holiday to provide that taxpayers who would commence business of generation, transmission and distribution of power by 31 March 2017 will also be eligible for the tax holiday.

1.7 Corporate Social Responsibility

Under the new Companies Act, 2013, companies satisfying certain criteria are mandatorily required to spend a certain percentage of their profit on Corporate Social Responsibility (CSR) activities.

It is proposed to be clarified that the CSR expenditure of these companies will not be tax deductible.

1.8 Withholding Tax (TDS)

1.8.1 Time limit for depositing withholding tax for payments to non-residents

Presently, a delay in depositing withholding tax results in the underlying expenditure being disallowed. Payments to non-residents are not tax-deductible if the withholding tax is deposited on or before the due date of payment of withholding tax deducted at source (TDS).

However, for payments to residents, the deduction for expenditure is allowed if the withholding tax is deposited on or before the due date of filing the tax return.

It is now proposed that for payments made to non-residents, the underlying expenditure will be tax deductible if the withholding tax is deposited within the due date of filing the tax return. Thus, there will be a uniform time limit for depositing the withholding tax, both for residents as well as non-residents.

1.8.2 Disallowance of expenditure

Presently, failure to withhold taxes results in the underlying expenditure being considered as not tax deductible.

It is now proposed that in case of failure to withhold taxes on payments to residents, the disallowance of expenditure would be restricted to 30% of the expenditure. This relaxation is applicable only for payments to residents.

1.8.3 Coverage of withholding tax defaults resulting in disallowance of expenditure

Currently, the disallowance of expenditure for withholding tax defaults is restricted to certain expenses like interest, commission, brokerage, rent, royalty fee for technical services, and payments to contractors.

It is proposed that the disallowance for non-deduction or non-payment be extended to all expenses on which tax is deductible.

The proposed amendment will mean that expenses such as salaries, director’s fees, etc., will not be tax deductible if taxes are not properly withheld on the same.

1.9 Concessional rate of tax on dividends from foreign companies

The Income Tax Act provides for a concessional rate of tax of 15% on dividends received by an Indian company from foreign companies where the Indian company holds 26% or more voting

9


power in the foreign company. This provision was applicable for dividends received until 31 March 2014.

It is now proposed to extend the benefit of the concessional rate of tax perpetually by removing the sunset clause of 31 March 2014.

1.10 Dividend Distribution Tax

Distribution of dividend by companies to its shareholders and by mutual funds to unit holders attracts Dividend Distribution Tax (DDT) at the rate of 16.995%.

Presently, there was some ambiguity about the amount on which the DDT was to be calculated. That is, whether DDT should be calculated on the amount eventually distributed to the shareholders/unit holders or whether the amount distributed should be grossed up.

It is proposed to be clarified that DDT should be calculated by grossing up the amount of dividend distributed to the shareholders/unit holders.

1.11 Special provisions relating to Business Trusts

It is proposed that in order to promote socio-economic growth, two new categories of investment vehicles in the form of business trusts be created namely:

• Real Estate Investment Trust (REIT)

• Infrastructure Investment Trust (InvIT)

The units of these business trusts are required to be listed on a recognised stock exchange.

For this purpose, a special tax regime for providing the way the income in the hands of such trusts is to be taxed, and the taxability of the income distributed by the business trusts in the hands of the unit holders, is proposed.

Interest income earned by the business trusts from an Indian company in which the trust holds controlling interest (SPV) is not liable to tax in the hands of the business trust.

When the trust makes payment of interest to unit holders, it is subject to withholding tax:

• If interest is distributed to a resident @ 10%; and

• If distributed to a non-resident @ 5%.

In case of interest on External Commercial Borrowings by business trust, withholding tax of 5% would apply.

Capital gains tax in the hands of the unit holder on transfer of units of business trust, if Securities Transaction Tax (STT) is paid is as under:

• Long-term capital gains will be exempt.

• Short-term capital gains will be taxable at the concessional rate of 15%.

SPVs are required to pay distribution tax on income distributed by way of dividend to business units. However, this would be exempt in the hands of the trust as well as the unit holder.

Business trust will not pay distribution tax on income that it received from SPVs, distributed by way of dividend to unit holders.

10


Capital gains on disposal of assets by the business trust will be taxable in its hands at the applicable rate. The distribution of the capital gains income will be exempted in the hands of the unit holders.

Income other than that mentioned above will be taxable in the hands of the business trust at the maximum marginal rate.

When the sponsor transfers the shares in the SPVs in lieu of the units of the business trust, the same will not be considered as transfer. However, when the sponsor transfers the units of the business trust, taxabity would trigger in the hands of the sponsor. The sponsor would not be able to take the preferential capital gains regime consequential to levy of STT. The cost of the units at the time of sale will be the cost of shares and the period of holding will include the period of holding of the shares.

It is proposed that a return is required to be filed by the business trusts.

1.12 Mode of acceptance or repayment of loans or deposits

At present, acceptance or repayment of loan or deposits in excess of INR 20,000 other than by an account payee cheque or account payee bank draft is prohibited.

It is now proposed to amend the provisions so as to include an electronic clearing system as an acceptable mode since a number of banking transactions take place by way of internet banking facilities or by use of payment gateways.

1.13 Provisional attachment

In order to protect the interest of revenue, the Assessing Officer can provisionally attach the property of an assessee during the pendency of proceedings of assessment or reassessment with the prior approval of the Commissioner or Chief Commissioner and by passing an order in writing, The provisional attachment is valid for a period of six months which may be extended by the Commissioner or Chief Commissioner to a total period of two years.

It is proposed to amend the provision to provide that the specified authority can extend the period of provisional attachment to two years or up to 60 days after the date of assessment or reassessment, whichever is later.

1.14 Power of Survey

Currently, for the purposes of Survey, an Income Tax authority is allowed to enter the premises in which business is carried on by the assessee. Also, he can impound and retain in his custody, any books and documents inspected by him during the survey for a period not exceeding 10 days (exclusive of holidays).

It is now proposed to increase the 10 days to 15 days with the permission of the specified authorities. Further it is proposed that the tax authority may enter the office or place where business is carried on within the limits of the area assigned to him or where the books of accounts are kept to verify that the TDS (Tax Deducted at Source) or TCS (Tax Collected at Source) has been deducted/collected as per the provisions of the Act. For this purpose, the tax authority may enter the office after sunrise and before sunset.

The amendment is proposed to be effective from 1 October 2014.

11


1.15 Additional powers to call for information or documents

Powers have been proposed to be conferred on the Income Tax authorities in order to enable them to verify the information in their possession relating to any person, by issuing notices to such persons and asking to furnish any information or documents, which the authority may think are useful to him in course of any enquiry or proceedings under the Income Tax Act.

The same is proposed to be effective from 1 October 2014.

1.16 Filling of Return of Income of Mutual Fund, Securitisation Trust, Venture Capital Company or Venture Capital Fund

The Finance Bill 2014 now proposes that Mutual Funds, Securitisation Trusts, Venture Capital Companies/Funds (as defined under the Act) shall be required to file a Return of Income if their Total Income before claiming any deduction under the Act exceeds the maximum limit that is not chargeable to tax. Furthermore, due to this amendment, the requirement of filling a statement giving details of income before any Income Tax authority is dispensed off. The same shall be with effect from 1 April 2015.

1.17 Estimation of the value of asset/investment/property by the Valuation

Officer

Currently the Assessing Officer (AO) may refer to the Valuation Officer (VO) to make an estimate of the value of any investment, bullion, jewellery or fair market value of property. There is no time limit for furnishing a report by the VO.

It is now proposed that the AO may refer the case to the VO irrespective of whether the AO is satisfied or not with the correctness or completeness of the accounts of the assessee.

It is further proposed that if the assessee does not cooperate or comply with the directions of the VO, he can estimate the value to the best of his judgement.

Also the VO is required to send a copy of the report to the AO and assessee within six months from the end of the month in which the reference is made.

The time for completion of assessments and reassessments would exclude the period beginning with the date on which the reference is made and ending with the date on which the report is received.

The amendment is proposed to be effective from 1 October 2014.

1.18 Income computation and disclosure standards

Currently, the method of accounting for computation of income has been provided. Furthermore, the Central Government is empowered to notify Accounting Standards for any class of income or any class of assessee.

It is proposed to now empower the Central Government to notify the Income Computation and Disclosure Standards to be followed by any class of assessee for any class of income.

12


1.19 Withholding tax on payment in respect of Life Insurance policy

It is proposed to provide for withholding tax at the rate of 2% on sums paid by a life insurance policy including the sum allocated by way of bonus, which is not exempted under the Act.

The requirement of withholding tax would apply if the sum paid exceeds INR 100,000.

This amendment will take effect from 1 October 2014.

1.20 Withholding tax on income by way of interest to non-residents from an Indian Company/Business Trust

A concessional rate of withholding tax of 5% is proposed to be extended to external commercial borrowings by business trusts subject to certain conditions.

The period of the borrowings is proposed to be extended to be before 1 July 2017.

It is further proposed to provide that the benefit of section 194LC would be available to long-term bonds, including long-term infrastructure bonds.

It is also proposed that the concessional rate of withholding tax would apply even in case a PAN is not available.

These amendments are proposed to be effective from 1 October 2014.

1.21 Withholding tax procedural matters

Under the existing provisions, TDS returns can be revised pursuant to a notification from the CBDT. However, there is no express provision under the Act to revise the TDS returns. In order to bring clarity in the matter relating to filing correction/revision statements, it is proposed to bring in the amendment.

Furthermore, similar to the processing of the original TDS statements, the revised statements can also be processed.

Also, currently no order treating an assessee to be an assessee in default can be passed after the expiry of two years from the end of the financial year in which the statement is filed or six years from the end of the financial year in which the payment is made or credit is given. It is now proposed to do away with the period of two years from the end of the financial year in which the statement is filed and extend the six years by another year and make it seven years from the end of the financial year in which the payment is made or credit is given.

Currently there is a penalty for failure to furnish the TDS/TCS statements however the authority competent to levy the penalty is not specified. It is now proposed to amend the same and provide that the penalty can be levied by the Assessing Officer.

This amendment is proposed to be effective from 1 October 2014.

1.22 Failure to produce accounts and documents

As per the existing law, in case a person fails to produce accounts and documents called by the Assessing Officer or wilfully fails to comply with the direction of Audit given by the specified authority, then he is punishable with:

• rigorous imprisonment for a term which may extend to one year; or

• with a fine ranging between INR 4 to INR 10 per day of default; or

13


• with both of the above.

The proposed section aims at punishing the assessee with imprisonment as well as a fine. Moreover, the quantum of the fine is not specified

1.23 Scope of Advance Ruling

Under the existing provisions, a resident could have recourse under advance rulings only in respect of the following:

• The transaction is between a resident and a non-resident; or

• Where the question under consideration is whether an arrangement proposed to be undertaken is an impermissible avoidance agreement or not (inserted by the Finance Act, 2013 with effect from 1 April 2015)

As an administrative initiative, the proposed budget seeks to cover transactions carried out by residents provided they are above a defined threshold limit. In addition, it is proposed to set up additional benches.

The Finance Minister, in his budget speech, mentioned about the amendment to the section; however, this clause does not find place in the Finance Bill.

1.24 Scope of Settlement Commission

During the speech, the Finance Minister mentioned that the scope of the Settlement Commission shall be expanded. However, there is no mention in the Finance Bill in this regard.

1.25 Speculation Business

The Income Tax Act allows carry forward of losses arising from a speculation business to be set-off only against profits arising from the speculation business.

There exists an ambiguity as to whether the losses arising from the business of dealing in shares is to be considered as speculation.

It is now proposed that a company, the principal business of which is the business of trading in shares, shall not be considered to be carrying on a speculation business. The losses arising from share trading activity for such companies will be considered as normal business losses.

It is also proposed to provide that an eligible transaction in respect of trading in commodity derivatives, carried out in a recognised association and chargeable to commodities transaction tax, shall not be considered to be a speculative transaction.

14


2. TRANSFER PRICING

2.1 Roll-back mechanism introduced in the Advance Pricing Agreement (APA)

Scheme

APA negotiated for succeeding five years can be applicable to the previous four years also from the first year to which the APA relates.

Detailed rules, specified circumstances and conditions are expected to be prescribed separately.

The proposed amendment will take effect from 1 October 2014.

The roll-back will save litigation costs, reduce the pendency of appeals and also encourage taxpayers to apply for the APA scheme.

The administrative mechanisms for APA would also be strengthened in order to expedite disposals of applications.

2.2 Amendment to the definition of international transaction

The definition of deemed international transaction is widened. The transaction between a taxpayer and an unrelated party was deemed to be international transaction where the unrelated party has entered into a prior agreement or arrangement with the taxpayer’s associated enterprise (AE).

It was not clear whether the aforesaid provisions would apply if the unrelated party was a resident of India, since it was a transaction between two domestic (Indian) entities.

The proposed amendment provides that the transaction between a taxpayer and an unrelated party would be a deemed international transaction, irrespective of whether the unrelated party is a non-resident or not.

The proposed amendment has an effect of overruling Tribunal judgments that had provided relief to taxpayers.

This amendment is proposed to be effective from 1 April 2014.

2.3 Clarifications for comparability analysis carried out for an international transaction

Introduction of range concept for determination of arm’s length price of an international transaction. The existing concept of arithmetic mean will continue where the number of comparables is inadequate. Use of range will shield the arm’s length price from variations on account of extreme values.

Further, use of multiple-year data would be allowed in comparability analysis. This would iron out differences on account of different product and industry lifecycles and yearly fluctuations.

These provisions are not reflected in the Finance Bill. It is expected that these changes will be given effect soon by amending the Income Tax Rules.

The above provisions of use of range and multiple-year data will align Indian transfer pricing regulations with global best practices. It would also reduce tax disputes and litigation going forward. These changes were on the wish list since the introduction of transfer pricing regulations in India, and are welcome proposals providing much needed relief to taxpayers.

15


2.4 Enhancement of the power of Transfer Pricing Officer

Transfer Pricing Officers, in addition to the Assessing Officer and Commission (Appeals), are given powers to levy a penalty for failure to furnish the documentation with respect to international transactions.

This amendment is proposed to be effective from 1 October 2014.

16


3. INDIRECT TAXATION

3.1 Customs Duty

Peak rate of Basic Customs Duty (BCD) remains unchanged at 10%.

3.1.1 Key changes in the rates of duty for certain products

(Effective 11 July 2014)

3.1.2 Procedural/administrative changes

(Effective from the enactment of the Finance Bill, 2014 unless otherwise stated)

Mandatory fixed pre-deposit of 7.5% of the duty demanded or penalty imposed or both for filing the appeal with the Commissioner (Appeals) or the Tribunal at the first stage and 10% of the duty demanded or penalty imposed or both for filing the second stage appeal before the Tribunal. The amount of pre-deposit payable would be subject to a ceiling of INR 100 million.

Safeguard duty has been imposed on inputs and raw materials imported by 100% Export Oriented Units (EOUs) and Special Economic Zones (SEZs) when such goods are cleared as such in a Domestic Tariff Area (DTA) or used in the manufacture of goods cleared in a DTA. This amendment shall become operative immediately.

A ‘Resident Private Limited Company’ has been made eligible for filing applications before the Authority for Advance Rulings.

The Appellate Tribunal’s discretionary power to refuse to admit an appeal of up to INR 50,000 has been raised to INR 200,000.

Baggage Rules amended as follows:

• Increase in free baggage allowance for passengers of and above 10 years of age and returning from stay abroad of greater than 3 days from INR 35,000 to INR 45,000; and

S. No. Tariff Description Old Rate New Rate Impact

1 Crude glycerine 12.5% 7.5%

2 Specified raw materials such as EVA resin, polyvinyl fluoride, etc. used in the manufacture of solar back sheets and EVA

10% 0%

3 Flat copper wire used in the manufacture of photovoltaic (PV) ribbons for solar PV cells/modules

5% 0%

4 Coal tar pitch, battery waste and battery scrap 10% 5%

5 LCD, LED TV panels and colour picture tubes of cathode ray TVs

10% 0%

6 eBook readers 7.5% 0%

7 Stainless steel flat products 5% 7.5%

8 Telecommunication products not covered under the Information Technology Agreement

0% 10%

17


• Increase in free baggage allowance for passengers of and above 10 years of age and returning from stay abroad of less than 3 days from INR 15,000 to INR 17,500.

3.1.3 Other amendments

(Effective 11 July 2014 unless otherwise stated)

Clarification issued that road construction machinery imported duty free can be sold within 5 years of importation subject to payment of customs duty on the depreciated value and that individual constituents of the consortium whose names appear in the contract can import goods without payment of duty.

The requirement of certification by the Ministry of Road Transport (or National Highways Authority of India) for availing customs duty exemption on specified goods required for the construction of roads has now been removed.

Education cess and secondary and higher education cess on the countervailing duty (CVD) portion of customs duty would be levied on specified imported IT products.

CVD exemption on portable X-ray machines/systems withdrawn.

BCD on machinery, equipment, components, appliances and auxiliary instruments required for the initial set-up of solar energy production projects is being reduced to 5%.

Exemption from Special Additional Duty (SAD) on inputs/components used in the manufacture of personal computers (laptops/desktops) and tablet computers.

Exemption from SAD on specified inputs (PVC sheets and ribbons) used in the manufacture of smart cards.

Full exemption on HIV/AIDS drugs and diagnostic kits imported under the National AIDS Control Programme (NACP).

Plant & equipment imported prior to 2008 for use in projects financed by the United Nations or an international organisation, which hitherto could not be transferred/sold/re-exported out of the project site, have been allowed to be transferred/sold/re-exported from the project site.

It has been clarified that aircraft engines and parts thereof are eligible for duty exemption when imported for servicing, repair or maintenance of aircrafts used for scheduled operations.

3.2 Central Excise Duty

Peak rate of Excise Duty remains unchanged at 12.36% (including education cess).

3.2.1 Key changes in rates of duty for certain products



1 Pan masala 12% 16%

2 Winding wires of copper 10% 12%

3 Waste and scrap of primary cells, primary batteries and electric accumulators

10% 12%

18



4 Machinery for the preparation of meat, poultry, fruits, nuts or vegetables; and on presses, crushers and similar machinery used in the manufacture of wine, cider, fruit juices or similar beverages; and on packaging machinery

10% 6%

5 Recorded smart cards (with or without CENVAT credit) 2% or 6% 12%

6 Reverse osmosis membrane elements used in household water filters

12% or 10%

6%

7 Metal core printed circuit board (PCB) and LED driver for use in the manufacture of LED lights and fixtures and LED lamps

12% or 10%

6%

8 Footwear of retail price exceeding INR 500 per pair but not exceeding INR 1,000 per pair (Footwear of retail price up to INR 500 per pair will continue to remain exempted)

12% 6%

3.2.2 Procedural/administrative changes

(Effective from the enactment of the Finance Bill 2014 unless otherwise stated)

Specified persons/assessees shall be required to furnish an information return stating required details within the prescribed time. On failure of submitting such return/rectified return, if any, within the prescribed time, as the case may be, shall make them liable to pay a penalty of INR 100 for each day during which the failure continues.

The monetary limit in case of discretionary powers of the Tribunal to refuse admission of appeals is increased from INR 50,000 to INR 200,000.

Mandatory fixed pre-deposit of 7.5% of the duty demanded or penalty imposed or both for filing an appeal with the Commissioner (Appeals) or the Tribunal at the first stage and 10% of the duty demanded or penalty imposed or both for filing the second stage appeal before the Tribunal. The amount of pre-deposit payable would be subject to a ceiling of INR 100 million.

Determination of disputes relating to taxability or excisability of goods is covered under the term ‘determination of any question having a relation to rate of duty’ and hence, the appeal against Tribunal orders in such matters would lie before the Supreme Court.

Settlement Commission can allow filing of application in cases where the applicant has not filed the returns after recording reasons thereof.

An additional duty of excise is being levied at the rate of 5% ad valorem on aerated waters containing added sugar.

3.2.3 Other amendments

(Effective 11 July 2014 unless otherwise stated)

In case if price is not the sole consideration for sale of excisable goods and they are sold by the assessee at a price less than the manufacturing cost and profit, and no additional consideration is flowing directly or indirectly from the buyers to such assessee, the value of such goods shall be deemed to be the transaction value.

19


In case of failure to pay duty as per return within one month from the due date of payment, the assessee would be liable to pay a penalty of 1% on the amount of duty not paid for the month, or part thereof during which such default continues.

Excise duty is being exempted on parts of tractors removed from one or more factories of a tractor manufacturer to another factory of the same manufacturer for manufacturing tractors.

Full exemption from excise duty provided for HIV/AIDS drugs and diagnostic kits supplied under the National AIDS Control Programme (NACP) funded by the Global Fund to fight AIDS, TB and Malaria (GFATM).

Full exemption from excise duty provided on machinery, equipment, etc. required for setting up of compressed biogas plants (Bio-CNG).

Full exemption from excise duty provided to goods supplied to the National Technical Research Organisation (NTRO).

Full exemption from excise duty is being provided for solar tempered glass used in the manufacture of solar photovoltaic cells/modules, solar power generating equipment/system and flat plate solar collectors.

Optional excise duty of 2% (without CENVAT) or 6% (with CENVAT) on writing and printing paper for printing of educational text books is being withdrawn and instead a uniform excise duty of 6% with CENVAT is being levied

Education cess and secondary & higher education cess (customs component) is being exempted on goods cleared by an EOU into a DTA.

Intermediate goods manufactured and consumed captively for further manufacture of matches is being fully exempted.


E-payment of excise duty is being made mandatory for all assessees from 1 October 2014.

3.3 Service Tax

Rate of Service Tax remains unchanged at 12.36% (including education cess).

3.3.1 Ambit of Negative List narrowed

(Effective from the date to be notified after the President’s assent)

Sale of space or time for advertisements such as online and mobile advertisement except through print media.

Service of transportation of passengers, with or without accompanied belongings by radio taxis.

3.3.2 Key changes in Mega Exemption List


Exemption widened to include the following:

Services provided by Common Bio-medical Waste Treatment Facility operators by way of treatment, disposal of bio-medical waste or processes incidental to such treatment or disposal.

Services by way of transportation of organic manure, cotton, ginned or baled by rail or a vessel from one place in India to another or by a goods transport agency (GTA) by way of transport in a goods carriage.

20


Services by way of loading, unloading, packing, storage or warehousing of cotton (ginned or baled).

Services received by the Reserve Bank of India, from outside India in relation to management of foreign exchange reserves.

Services provided by a tour operator to a foreign tourist in relation to a tour conducted wholly outside India.

Life micro-insurance product as approved by the Insurance Regulatory and Development Authority, having a maximum cover of INR 50,000.

Accommodation services provided by dharamshalas and ashrams where room rent per day is less than INR 1,000.

Exemption withdrawn for the following:

Services by way of technical testing or analysis of newly developed drugs, including vaccines and herbal remedies, on human participants by a clinical research organisation approved to conduct clinical trials by the Drug Controller General of India.

Services provided to educational institutions by way of renting of immovable property and auxiliary educational services except certain services such as:

• transportation of students, faculty and staff;

• catering, including any mid-day meals scheme sponsored by the government;

• security or cleaning or house-keeping services performed in such educational institutions;

• services relating to admission to, or conduct of examination by, such institution.

Transport of passengers, with or without accompanied belongings, by air-conditioned contract carriages, excluding tourism, conducted tour, charter or hire.

3.3.3 Rationalisation of abatement


The condition for availing abatement in case of GTA service is being amended with immediate effect. A GTA service receiver can avail abatement without obtaining certificate of non-availment of CENVAT credit.

(Effective 1 October 2014)

For rent-a-cab and tour operator services, credit of service tax paid to sub-contractor would be available to the main service provider.

Abatement of 60% has been granted on transport of passengers, with or without accompanied belongings, by a contract carriage other than motor cab, subject to conditions specified therein.

The above abatement shall be extended to radio taxis also from the date to be notified after the President’s assent.

Taxable portion with respect to transport of goods by vessel to be reduced from 50% to 40%. Effective rate of service tax would reduce from 6.18% to 4.944%.

3.3.4 Advance Ruling



21


3.3.5 Amendments in Chapter V of the Finance Act, 1994

(Effective from the date notified after the President’s assent)

Print media has been defined so as to exclude business directories, yellow pages and trade catalogues, which are primarily meant for commercial purposes.

Rate of exchange shall be determined as per the rules prescribed, to ascertain the value of services in case of export/import transactions.

Time limit prescribed for completion of adjudications

Power to waive 50% penalty for offences specified in Section 78(1) of the Finance Act, 1994 removed

Powers granted to the Joint Commissioner or Additional Commissioner or any other officer notified by the Board to authorise any Central Excise Officer to search and seize.

The following provisions of the Central Excise Act, 1994 shall be applicable to service tax:

• Any explanation inserted in a notification or special order at any time within one year of issue of notification or order, for clarifying the scope or applicability thereof, shall have effect from the date of issue of such notification or order.

• Third-party sources shall furnish periodic information, as specified, in the manner as may be prescribed.

• Specified persons/assessees shall be required to furnish an information return stating required details within the prescribed time. On failure of submitting such return/rectified return, if any, within the prescribed time, as the case may be, shall make them liable to pay a penalty of INR 100 for each day during which the failure continues.

• Mandatory fixed pre-deposit of 7.5% of the duty demanded or penalty imposed or both for filing an appeal with the Commissioner (Appeals) or the Tribunal at the first stage and 10% of the duty demanded or penalty imposed or both for filing the second stage appeal before the Tribunal. The amount of pre-deposit payable would be subject to a ceiling of INR 100 million.

No fee shall be payable for filing a stay application with the Appellate Tribunal.

Service provided by the Employees’ State Insurance Corporation (ESIC) during the period prior to 1 July 2012 to be exempted from service tax.

3.3.6 Compliances enhancement


Interest rates now linked to the extent of delay in service tax payment as under:

Extent of Delay Rate (per annum)

Up to six months 18%

From six months up to one year 24%

More than one year 30%

22


3.3.7 Procedural simplification


Changes are proposed in the service tax provisions to simplify the procedural compliance in relation to SEZ.

3.3.8 Changes in Reverse Charge Mechanism


Scope of reverse charge mechanism expanded to include:

Service provided by Director to body corporate.

Services provided by Recovery Agent to Banks, Financial Institutions and Non-Banking Financial Company.


Simplification of partial reverse charge mechanism:

The portion of service tax payable by the service provider and service receiver will be 50% for both in case of renting of motor vehicle, where the service provider does not claim any abatement.

3.3.9 Payment of Service Tax


E-payment of service tax is being made mandatory for all assessees from 1 October 2014. Relaxation from e-payment may be allowed by the Deputy Commissioner or Assistant Commissioner on a case-to-case basis.

3.3.10 Rationalisation of Service Tax on the Service Portion in a Works Contract


In case of a works contract such as maintenance, repairs, completion and finishing service (other than original works), the value of the service portion is amended from 60% to 70% of the total contract value.

3.3.11 Changes in Point of Taxation Rules


Determination of point of taxation in case of reverse-charge transactions have been changed and would be the earlier of following:

• Date of payment, or

• First day after three months from the date of invoice.

With respect to invoices issued prior to 1 October 2014, transitional rules are framed.

3.3.12 Changes in Place of Provision of Services Rules (POPS)


Place of performance of service would not be criteria for repairs service carried out on temporarily imported goods that are exported after repairs (without being put to use).

Meaning of intermediary amended to include intermediary of goods within its ambit.

23


Service consisting of hiring of vessels (excluding yachts) and aircraft is excluded from Rule 9(d) and would be covered under the general rule (i.e. Rule 3) irrespective of being hired for a short term or long term.

3.3.13 Changes in CENVAT Credit Rules


A manufacturer or a service provider shall take CENVAT credit on inputs and input services within a period of six months from the date of issue of invoice, bill or challan with effect from 1 September 2014.

In case of service tax paid under full reverse charge, the condition of payment of invoice value to the service provider for availing credit of input services is withdrawn. However, there is no change in respect of partial reverse charge.

Re-credit of CENVAT credit reversed on account of non-receipt of export proceeds within the specified period or extended period to be allowed if export proceeds are received within one year from the period so specified or extended period, subject to conditions.

Going forward, there will be a restriction on transfer of credit by a large taxpayer from one unit to another.

The term ‘place of removal’ is now defined under CENVAT Credit Rules, 2004.

3.3.14 Clarification on availment by Input Service Distributor


Interpretational issues were raised regarding the amendment such as: distribution of the credit would be restricted to only those units where the services are used, and the credit available for distribution would also get reduced by the proportion of the turnover of those units where the services are not used. In this regard, it is clarified that the amended Rule 7 allows distribution of input service credit to all units (that are operational in the current year) in the ratio of their turnover of the previous year/previous quarter, as the case may be.

3.4 Goods and Services Tax (GST)

In the Budget speech, the Finance Minister assured the House that the debate on GST should come to end and before the year ends, the government endeavours to approve the legislative scheme.

Further, based on the Economic Survey 2013-14 issued on 9 July 2014, it appears that the government would consider a step-by-step approach to introduce GST, by introducing Central GST (CenGST) as the first step at a Central level and then SGST would be introduced to replace the State-level indirect taxes. In particular, once the CenGST is implemented, it will be easier for the Centre and States to move to GST.

GST is expected to streamline the tax administration, avoid harassment of businesses, and may result in higher revenue collection for the Centre and States.

The Finance Minister assured that all States would be taken on board for a fair consensus on GST.

24


ABOUT THIS PUBLICATION This SKP publication contains general information existing at the time of its preparation only. It is intended as a news update and is not intended to be comprehensive nor to provide specific accounting, business, financial, investment, legal, tax or other professional advice or opinion or services. This publication is not a substitute for such professional advice or services, and it should not be acted on or relied upon or used as a basis for any decision or action that may affect you or your business. Before making any decision or taking any action that may affect you or your business, you should consult a qualified professional adviser and also refer to the source pronouncement/documents on which this publication is based. It is also expressly clarified that this publication is not a solicitation or an invitation of any sort whatsoever or a source of advertising from SKP Group or any of its entities to create any adviser-client relationship. Whilst every effort has been made to ensure the accuracy of the information contained in this publication, this cannot be guaranteed, and neither SKP Group nor any related entity shall have any liability to any person or entity that relies on the information contained in this publication. Any such reliance is solely at the user's risk.

© 2014 SKP Group. All rights reserved.

Mumbai

19 Adi Marzban Path

Ballard Estate

Mumbai 400 001

T: +91 22 6730 9000

Pune

VEN Business Centre

Baner-Pashan Link Road

Pune 411 021

T: +91 20 6720 3800

Hyderabad

6-3-249/3/1 SSK Building

Ranga Raju Lane

Road No. 1, Banjara Hills

Hyderabad 500 034

T : +91 40 2338 6912/13

[email protected]

New Delhi

B-376 Nirman Vihar

New Delhi 110 092

T: + 91 11 2242 8454/55

Chennai

Office No. 3, Crown Court

128 Cathedral Road

Chennai 600 086

T: +91 44 4208 0335

Bangalore

Office No. 312/313, Barton Centre

Mahatma Gandhi Road

Bangalore 560 001

T: +91 80 4140 0131/32/33

www.skpgroup.com

Twitter Facebook LinkedIn

25

mailto:[email protected]

http://www.skpgroup.com/

https://twitter.com/SKPGroup

https://www.facebook.com/SKPGroupIndia

https://www.linkedin.com/company/skp-group

UNION BUDGET - SKP Group€¦ · UNION BUDGET 2014–15. Contents BUDGET 2014 – A Pragmatic...

Documents

Transcript of UNION BUDGET - SKP Group€¦ · UNION BUDGET 2014–15. Contents BUDGET 2014 – A Pragmatic...