Thursday, July 10, 2014

Change in Budget in Direct Tax and Transfer price

                                                 Direct Taxes


1.      Increase personal income tax exemption limit by `50,000
i)                    From ` 2 lakh to ` 2.5 lakh in the case of individual taxpayers who are below the age of 60 years.
ii)                  Raise the exemption limit from ` 2.5 lakh to ` 3 lakh in the case of senior citizens.

2.      No change in the rate of surcharge for the corporates and the individuals, HUFs, firms etc.

3.       The education cess for all taxpayers shall continue at 3 percent.

4.      Increased the investment limit under section 80C of the Income-tax Act from ` 1 lakh to ` 1.5 lakh.

5.      Increased the deduction limit on account of interest on loan in respect of self occupied house property from ` 1.5 lakh to ` 2 lakh.


Manufacturing Sector

Provided investment allowance at the rate of 15 percent to a manufacturing company that invests more than ` 25 crore in any year in new plant and machinery.

This benefit will be available for three years i.e. for investments upto 31.03.2017. The Scheme announced last year will continue to operate in parallel till 31.03.2015.

Extended the 10 year tax holiday to the undertakings which begin generation, distribution and transmission of power by 31.03.2017.


Treating capital gains the income arising to Foreign Portfolio Investors (FPIs)
 from transaction in securities.

Continued the concessional rate of tax at 15 percent on dividend received by Indian companies from their foreign subsidiaries without any sunset date.

Extended the eligible date of borrowing in foreign currency from 30.06.2016 to 30.06.2017 for a concessional tax rate of 5 percent on interest payments.

Also extended this tax incentive to all types of bonds instead of only infrastructure bonds.


                                  Transfer Pricing

Made certain changes in Transfer Pricing regulations.

(1)   To be strengthened the administrative set up of APA to expedite disposal of applications. Introduced a "Roll Back" provision in the APA scheme so that an APA entered into for future transactions may also be applied to international transactions undertaken in previous four years in specified circumstances.

(2)   In order to align Transfer Pricing regulations in India with the best available practices, Introduced range concept for determination of arm's length price. However, the arithmetic mean concept will continue to apply where number of comparable is inadequate. The relevant data is under analysis and appropriate rules will be prescribed.

(3)   As per existing provisions of Transfer Pricing Regulations, only one year data is allowed to be used for comparable analysis with some exception. Proposed to amend the regulations to allow use of multiple year data.


(4)   Necessary legislative amendments to give effect to the above proposals including those relating to the Authority for Advance Rulings and Income-tax Settlement Commission will be moved in the current session of the Parliament.