Tax Insights
from India Tax & Regulatory Services
Amendments to the Finance Bill,
2016 as passed by the Lok Sabha
May 10, 2016
In brief
On 5 May, 2016, the Lok Sabha (Lower House) passed the Finance Bill, 2016 (Bill). For becoming law,
this Bill now has to get passed by the Rajya Sabha (Upper House) and thereafter obtain the Presidential
assent. While passing the Bill, however, 47 different amendments in respect of Direct Tax provisions in
the Bill as tabled originally were moved by the Finance Minister, Arun Jaitley, and all these
amendments were passed. In this News Alert, we have explained in tabular format the major changes
relating to Direct Taxes introduced just before the Lower House passed the Bill.
In detail
Clause
No in
Finance
Bill
Clause 3
Section
Amendment
Amendment as passed
in
as tabled in Lok Sabha
by Lok Sabha
Incomeon 29 Feb 2016
on 5 May, 2016
tax Act,
1961
Section 2
While the proposed
amendment was mentioned
in the Budget Speech of the
Finance Minister however
no corresponding change
was brought in the Finance
Bill
Third proviso to section
2(42A) inserted. In case of
unlisted shares, period of
holding for transfer to be
considered as a short-term
capital asset reduced from
36 months to 24 months.
Comments
Originally, the period of
holding of shares in a
company for
determination of the
nature of capital gains
vis-à-vis long-term or
short-term was 12
months. However this
period was extended to
36 months in the case of
unlisted companies by
Finance Act (no. 2) of
2014, which was
considered by many as a
retrograde step.
The current reduction in
period of holding for
unlisted companies from
36 months to 24 months
partly addresses this
perception and will help
corporates in business
restructuring.
www.pwc.in
Tax Insights
Clause No Section in
Amendment as tabled in
in
Income-tax Lok Sabha on 29 Feb 2016
Finance
Act, 1961
Bill
Clause 7
Clause 16
Section 10
clauses (12)
and (13)
w.e.f. 1 April
2017
Section 10 clause (12) amended Proposed amendment of
to provide that nothing in this
clauses (12) and (13) of section
clause would apply to any
10 rolled back.
accumulated balance
attributable to contributions
made on or after the 1st April,
2016 by employee other than
excluded employee, exceeding
40% of such accumulated
balance due and payable in
accordance with rule 8 of Part A
of the Fourth Schedule.
Section 10 clause (13) amended
to provide that payments in
commutation of annuity
purchased out of contributions
made on or after 1 April, 2016,
exceeding 40% of the annuity,
shall be chargeable to tax.
New section Expenditure for obtaining right
35ABA w.e.f to use spectrum for
1 April 2017 telecommunication services any capital expenditure incurred
and actually paid by a taxpayer
on acquisition of any right to use
spectrum for
telecommunication services
shall be allowed as a deduction
in equal instalments over period
starting from year in which such
payment has been made to year
in which useful life of spectrum
ends. Sub-sections (2) to (8) of
section 35ABB to apply as if for
the word “licence”, the word
“spectrum” had been
substituted
Explanation to define certain
expressions used for the
purposes of the said section.
This amendment will take effect
from 1 April, 2017 and will apply
in relation to assessment years
(AYs) 2017-2018 and onwards.
Clause 19
PwC
Section
35CCC from
AY 2017-18
to AY 202021
Amendment as passed by
Lok Sabha
on 5 May, 2016
Where taxpayer incurs any
expenditure on an agricultural
extension project notified by
CBDT in accordance with
guidelines prescribed, then
Sub-section (3) now introduced
to provide that if, in a previous
year, deduction under section
35ABA(1) has been granted and
after that, any provision of the
section has not been complied
with, the deduction would be
deemed to have been wrongly
allowed. The Tax Officer (TO)
is given the power to recompute the total income and
make the necessary
rectification. Limitation under
section 154(7) would be 4 years
counted from the date of noncompliance with provisions of
this section.
Words, “or payable in such
manner as may be prescribed”
added at end of Explanation
(iii) to new section 35ABA. This
qualifies the phrase, “payment
has actually been made”, which
means that even if the payment
has been made in a manner
prescribed, the payment would
be treated as actually been
made only when there was
actual payment of expenditure.
Proposed reduction of the
deduction from 150% to 100%
has been deferred. Thus, the
deduction available would
continue to be a weighted
deduction @150% of qualifying
Comments
It was proposed to tax
withdrawal from the
accumulated balance (in
excess of 40%) in the
provident fund account,
which is attributable to
employee’s contribution
made on or after 1 April,
2016.
After a lot of public pressure
the Finance Minister has
rolled back the amendment,
which will act as a major
relief for salaried taxpayers.
The proposed amendment
seeks to grant power to the
TO to rectify the total income
of the taxpayer where any of
the conditions specified
therein are not complied
with. Such rectification can
be done within 4 years from
the end of the previous year
in which the failure to
comply with the condition
happens.
The proposed sunset clause
has been extended to AY
2020-21 as against the initial
proposal of ending it by AY
2017-18.
Page 2
Tax Insights
Clause No Section in
Amendment as tabled in
Amendment as passed by
Comments
in
Income-tax Lok Sabha on 29 Feb 2016
Lok Sabha
Finance
Act, 1961
on 5 May, 2016
Bill
deduction of 150% of such
expenditure until AY 2020-21;
expenditure would be allowed. thereafter the same shall
reduce to 100%
It was proposed to reduce the
deduction to 100%. This
amendment was to take effect
from 1 April, 2018 and apply
from the AY 2018-2019 and
onwards.
New Clause Section 49
New sub-section (5) inserted in The FB 2016 introduced the
29A
w.e.f. 1 April,
section 49 w.e.f. 1 April, 2017 to Income Declaration Scheme,
2017
provide that if a capital gain
2016, where taxpayers can
arises from transfer of an asset declare their undisclosed
declared under the Income
income by paying tax @45%
Declaration Scheme 2016, and of the FMV of gross
tax, surcharge and penalty have undisclosed income/ assets.
been paid in accordance with
The amendment introduced
the Scheme on the Fair Market
clarifies that cost of the asset
Value (FMV) of the asset on the
considered for future capital
date of commencement of the
gain computation would be
Scheme, then such FMV would
the FMV used for declaration
be deemed to be cost of
of income under the Income
acquisition of the asset.
Declaration Scheme.
Clause 41
Clause 43
PwC
New Section Amended to provide deduction
80-IAC w.e.f of 100% of profits and gains
1 April 2017 derived by an eligible start-up
from business involving
innovation, development,
deployment or
commercialisation of new
products, processes or services
driven by technology or IP, for
three consecutive AYs out of
five, at option of taxpayer, if
incorporated before 1 April,
2019.
New Section Deductions in respect of profits
80-IBA w.e.f and gains from housing project:
1 April 2017 100% deduction of profits and
gains of taxpayer developing
and building housing projects, if
project approved by competent
authority on or before 31 March
2019, subject to conditions.
Taxpayer has to complete the
project within 3 years, failing
which deduction claimed in
previous years shall be deemed
to be the taxpayer’s income.
Explanation (ii) of the
proposed section amended to
include limited liability
partnerships (LLPs) in the
definition of “eligible startup”,
and LLPs are defined to as
partnerships referred to in
section 2(1)(n) of the Limited
Liability Partnership Act,
2008.
This amendment is a very
welcome step, as LLPs were
gaining traction as the
preferred legal structure for
doing business. Exclusion of
LLPs from the original
amendment would have
curtailed the benefit being
available to start-ups.
Words, ‘in accordance with
such guidelines as may be
prescribed” deleted from clause
(a) of section 80-IBA(2).
Mostly, the changes are
improvements to the draft of
the new section to head off
possible controversies or
block potential loopholes,
Words, “on which the project”
such as:
have been substituted by the
words, “on which the building  no specific guidelines for
plan of such housing project”
housing project need be
in Proviso (i) below clause (b)
notified
of section 80-IBA(2).
 distance from municipal
Clause (d) of section 80-IBA(2)
limits shall be measured
re-drafted, and for the words,
aerially
“within the area of twenty-five
kilometres from the municipal  ‘built-up area’ of the
residential unit shall be
limits of these cities”, the
relevant.
words, “within the distance,
measured aerially, of twentyfive kilometres from the
Page 3
Tax Insights
Clause No Section in
Amendment as tabled in
in
Income-tax Lok Sabha on 29 Feb 2016
Finance
Act, 1961
Bill
Amendment as passed by
Lok Sabha
on 5 May, 2016
Comments
municipal limits of these cities”
substituted. Similar change
also made in section 80-IBA(2)
Clause (g)(i).
Clause (da) has been
introduced in section 80IBA(2) to provide an additional
condition that the project
should be the only project on
the plot of land specified in
clause (d).
Clause (e) has been re-drafted
to clarify that the built-up area
of the residential units should
not exceed 30 sq mts for a
project in the four metro cities
or “within the distance,
measured aerially, of twentyfive kilometres from the
municipal limits of these cities”
In section 80-IBA(2)(g)(i), for
the words, “area other than the
areas”, the words, “place other
than the place” have been
substituted.
In section 80-IBA(3), the
words, “undertaking which”
have been substituted by
“taxpayer who”.
In section 80-IBA(5), the
words, “under any scheme for
the housing” have been
omitted.
In section 80-IBA(6)(b), the
words, “by the Central
Government” have been
substituted by the words, “to
approve the building plan by,
or under any law for the time
being in force”.
Clause 46
PwC
In section 80-IBA(6)(d), the
word, “dwelling” has been
substituted by the “word,
“residential” and the word,
“specify” substituted by the
word, “approve”.
Section
Proposed to amend sub-section Reference to “clause (viii)” has
92CA:
(3A) to provide that in certain
been changed to “clause (x)” in
Reference to circumstances as in clauses (ii) the proviso to new sub-section
Transfer
or (viii) of Explanation (1) to
(3A) of section 92CA.
Pricing
section 153, if period of
limitation available to transfer
The proposed change is
correction of a referencing
error with regard to
extension of time limit of
reference to the TPO,
wherein exchange of
Page 4
Tax Insights
Clause No Section in
Amendment as tabled in
Amendment as passed by
in
Income-tax Lok Sabha on 29 Feb 2016
Lok Sabha
Finance
Act, 1961
on 5 May, 2016
Bill
Officer: w.e.f. pricing officer (TPO) for making
1 June 2016 order is less than 60 days, such
remaining period shall be
extended to 60 days.
New Clause Section 111A:
With effect from 1 April, 2017,
47A
 In section 111A(1), a second
proviso has been inserted to
exempt transactions on any
recognised stock exchange
located in any IFSC in
foreign currency.
Clause 49
Clause 50
PwC
New section
115BA : tax
on income of
certain
domestic
companies
w.e.f. 1 April
2017
Sub-section (1) provides that the
income-tax payable in respect of
the total income of a domestic
company, for any previous year
relevant to the AY beginning on
or after the 1st day of April, 2017
shall, at the option of such
person, be computed at 25%, if
the conditions contained in subsection (2) are satisfied. Subsection (2) provides that the
conditions referred to in subsection (1) are the following,
viz:– (a) the company has been
set up and registered on or after
the 1st day of March, 2016; (b)
the company is engaged in the
business of manufacturing or
production of any article or
thing; and …
Sub-section (4) provides that
the option shall be exercised in
the prescribed manner on or
before the due date specified
under section 139(1).
New section Current provisions of the Act
115BBDA
provide that dividend income
w.e.f 1 April will be exempt if dividend
2017
Comments
information has been called
for under sections 90/ 90A.
While in the original Finance
Bill tabled by the Finance
Minister amendment to
section 10(38) relating to
long-term capital gains was
proposed so as to cover
financial instruments traded
on the IFSC platform within
 Explanation below section the tax exemption domain
without levy of STT,
111A(3) has been
however, no corresponding
substituted to define the
benefit under section 111A
terms, “equity oriented
fund” (as per Explanation to relating to short-term capital
gains was granted.
section 10 clause (38)),
“International Financial
The same has now been
Services Centre” (as per
corrected by this
section 2(q) of the SEZ Act, amendment.
2005) and “recognized
stock exchange” (as per
clause (ii) of Explanation 1
to section 43AA(5)).
Section 115BA(2)(b) has been Firstly the proposed
re-drafted thus:
amendment clarifies that
core incidental activities like
Words, “the company is
research on the goods
engaged in the business of
manufactured or their
manufacturing or production
distribution would be
of any article or thing” replaced
covered as part of eligible
by “the company is not
business activity to avail the
engaged in any business other
reduced tax rate of 25%.
than the business of
manufacturing or production Further the option to avail
of any article or thing, research the 25% tax rate while giving
in relation to, or distribution
up other tax incentives has
of, such article or thing
been made an irrevocable
manufactured by it;”.
choice.
Section 115BA(4) has been redrafted to provide that this
section won’t apply unless the
option is exercised on or before
due date specified under
section 139(1); and that once
exercised, the option cannot be
subsequently withdrawn.
Opening portion of sub-section The initial proposed section
(1) has been re-drafted.
had certain interpretational
issues as to whether the
Instead of words, “income
aggregate dividend received
exceeding INR 1 million”, the
by the individual needs to be
Page 5
Tax Insights
Clause No Section in
Amendment as tabled in
Amendment as passed by
in
Income-tax Lok Sabha on 29 Feb 2016
Lok Sabha
Finance
Act, 1961
on 5 May, 2016
Bill
distribution tax is paid on such words, “income in aggregate
income.
exceeding INR 1 million” are
inserted.
New section 115BBDA to
provide that any income by way Also, instead of “such
of dividend declared, distributed dividends, at the rate of”, the
or paid by a domestic company, words, “such dividends in
in excess of INR 1 million shall aggregate exceeding INR 1
be chargeable to tax at 10% in
million, at the rate of” are
case of an individual, HUF or a inserted.
firm resident in India.
No deduction in respect of any
expenditure or allowance or set
off of loss would be allowed in
computing the income by way of
dividend, and a defining the
term ‘dividends’.
Clause 52
Clause 53
PwC
New section
115BBF, with
effect from 1
April 2017
New section 115BBF introduced
to provide that where total
income of eligible taxpayer
includes income by way of
royalty in respect of a patent
developed and registered in
India, the income-tax payable
shall be tax calculated on the
royalty income at 10%, and the
tax which the taxpayer would
have had to pay had his total
income been reduced by the
10% tax on royalty income as
above.
Comments
considered for the additional
tax or it needs to be seen
singularly from each
company. Further there were
doubts as to whether the
additional tax applies on
dividend income exceeding
the INR 1 million limit or in
its entirety.
This amendment wards off
such possible disputes and
clarifies that the additional
tax has to be seen with
reference to the aggregate
dividend in excess of INR 1
million received from
multiple payers.
Sub-clauses (3) and (4) have
been added to proposed section
115BBF, which ushers in an
optional 10% presumptive tax
regime for royalty income for
income from patents developed
and registered in India.
Many developed economies
had a special tax regime to
incentive R&D activities. The
Bill introduced India’s very
own ‘Patent Box’ regime
wherein the royalties earned
from the patents developed
and registered in India were
An eligible taxpayer can
to be taxed on a gross basis
exercise this option within time
@10%.
allowed for filing return under
section 139(1). If the
The amendment done by the
presumptive tax option is not Finance Minister clarifies
opted for 5 years, then the
that for the purposes of the
option cannot be exercised for condition of the patents
Also, the taxpayer shall not be the next 5 years either.
being “developed in India”
eligible for deduction of any
75% of the expenditure
Developed in India means that
expenditure or allowance under
should be incurred in India.
at least 75% of expenditure
any provisions of the Act in
This will help bring certainty
incurred for any invention with
computing his income referred
and also addresses the
a granted patent is incurred in
to section 115BBF(1)(a).
practical difficulty expressed
India.
by many companies of
An Explanation in section
Condition that the unit set up ensuring all expenses being
115BBF is inserted to define
incurred in India.
in an IFSC now no longer
certain expressions used
needs to be set up on or after 1
therein.
April 2016.
One of the conditions to avail
Section
New section 115JB(7) provides The condition of being
115JB w.e.f. 1 that for a company, being a unit established on or after 1 April the reduced MAT rate of 9%
for units set up in the IFSC
April, 2017 in an IFSC established on or
2016 removed.
was that they need to be
after 1 April 2016 and deriving
established on or after 1
its income solely in convertible
April 2016. This condition
foreign exchange, tax rate would
has been relaxed and
be 9%.
therefore the reduced MAT
rate of 9% grandfathers units
already set up in the IFSC
before 1 April 2016.
Page 6
Tax Insights
Clause No Section in
Amendment as tabled in
in
Income-tax Lok Sabha on 29 Feb 2016
Finance
Act, 1961
Bill
Clause 60
Clause 66
New chapter
including
new sections
115TD,
115TE and
115TF: Tax
on certain
accreted
income of
certain
trusts and
institutions,
w.e.f. 1 June
2016
Amendment as passed by
Lok Sabha
on 5 May, 2016
Notwithstanding anything
Two additional provisos added
contained in any other provision to section 115TD(2)
of the Act, a trust or institution
i. to exclude accreted income
registered under section 12AA
attributable to asset
shall be liable to tax on accreted
acquired out of agricultural
income in case of certain
income; and to asset
eventualities, at maximum
acquired between trust/
marginal rate, in addition to tax
institution being established
chargeable in respect of total
and the date on which its
income. Other provisions
registration under section
include providing for asset
12AA became effective.
valuation, making exceptions to
certain assets, forms of
ii. If exemption given to trust
conversion making trust
for previous year before
ineligible for registration, how
registration under section
additional tax is calculated,
12AA became effective, due
when to pay tax, and provisions
to operation of first proviso
for interest for delayed payment
to section 12A(2),
and penalty for failure to pay the
registration deemed to be
additional tax.
effective from earlier
previous year.
Section 143: Proviso inserted after section
Assessment, 143(1D)
changes
w.e.f. 1 June,
2016
Comments
In order to ensure that the
intended purpose of
exemption availed by a
registered charitable trust is
not misused, a new ‘exit tax’
has been introduced on
accreted income of such
trust which was claimed
exempt from tax in earlier
years.
For the purpose of
computation of accreted
income, assets purchased out
of agricultural income, being
not chargeable to tax, or on
account of assets purchased
prior to availing any
exemption shall be excluded.
Further, the time limit for
payment of taxes on accreted
income has also been
relaxed.
Two more changes in date by
which additional tax has to be
paid in case of cancellation of
registration of trust/
institution, merger or rejection
of application.
Section 143: New sub-section Originally all tax returns
(1D), and proviso thereto,
were required to be
inserted.
processed under section
143(1) within a time frame of
Processing of return not
1 year from end of the
necessary before expiry of 1
relevant AY. Thereafter vide
year from end of FY in which
Finance Act 2012 an
return is made, where notice
amendment was brought in
has been issued under section
whereby processing of tax
143(2), but has to be completed
returns was not mandatory
before issue of order under
where the case of the tax
section 143(3).
payer has been selected for
scrutiny assessment.
Vide the current Finance Bill
processing of tax returns
even in cases of scrutiny
selection was made
mandatory before passing of
the final assessment order.
The Finance Bill as passed by
the Lok Sabha now provides
that the time limit of one
year shall not be applicable
for processing of tax returns,
though it is mandatory to
process the tax return before
PwC
Page 7
Tax Insights
Clause No Section in
Amendment as tabled in
in
Income-tax Lok Sabha on 29 Feb 2016
Finance
Act, 1961
Bill
Clause 81
Clause 86
Amendment as passed by
Lok Sabha
on 5 May, 2016
Comments
passing the final assessment
order under section 143(3).
Section
Proviso added - if payee is non- A proviso has been inserted
194LBB:
so as to provide that where
company non-resident or a
TDS on
income of the non-resident is
foreign company, no TDS is
income from
required under section 194LBB not chargeable to tax, no tax
units of
on income on which no tax is shall be deducted in such
investment
cases (for instance in case of
chargeable.
fund, w.e.f.1
tax treaty benefit being
April, 2016
availed).
Section
Proposed that seller to collect
Instead of being included as
The Finance Bill, 2016
206C: Tax
the tax at 1% on sale of motor
additional item in the Table
brought the sale of motor
Collection at vehicle of value exceeding INR 1 under section 206C(1), this
vehicle (value exceeding INR
Source
million w.e.f. 1 June 2016.
proposal now has its own sub- 1 million) within the ambit of
section – (1F); with
TCS, which is proposed to be
consequential changes.
collected by seller at the time
of debiting the amount
receivable or at the time of
receipt, which is earlier.
Now, the Finance Bill, 2016
as passed by the Lok Sabha
provides that tax shall be
collected on sale of motor
vehicle only at the time of
receipt of consideration.
Clause 96
New section Bill seeks to insert section 270A
270A w.e.f.1 in the Income tax Act relating to
April, 2017 penalty for under-reporting and
misreporting of income.
Rate of penalty proposed is 50%
of tax in case of under-reporting
of income, and 200% of tax in
case of misreporting of income.
What constitutes underreporting of income: The
Finance Bill, 2016 proposed six
instances where a person shall
be deemed to have
underreported his income.
Further in the original
Finance Bill 2016 there was
an exclusion on account of
purchase of motor vehicle for
personal consumption,
which has not been provided
in the Bill as passed by the
Lok Sabha.
Following amendments have
The Finance Bill 2016
been approved by Lok Sabha: introduced a new penalty
scheme vide section 270A.
One more instance of underThis basically bifurcated the
reporting of income is added.
cases liable for imposition of
penalty into two parts, viz:
Section 270 A(2), new clause
(f) inserted : Person is deemed cases involving under
reporting of income and
to have under-reported his
cases involving misincome if total income
reassessed as per section 115JB reporting of income.
or section 115JC (MAT or
The Finance Bill as passed by
AMT) is greater than deemed
the Lok Sabha adds on
total income assessed/
another situation for underreassessed under MAT or the
reporting of income wherein
AMT immediately before such
penalty can be levied on
reassessment.
account of reassessed
Section 270A(2), earlier clause income being under MAT
(f) re-numbered as clause (g). provisions.
Section 270A(6) : Principal
Commissioner also added to
PwC
Further, the definition of ‘tax
payable’ in respect of under-
Page 8
Tax Insights
Clause No Section in
Amendment as tabled in
in
Income-tax Lok Sabha on 29 Feb 2016
Finance
Act, 1961
Bill
Amendment as passed by
Lok Sabha
on 5 May, 2016
Comments
list of officers who can record reported income has also
satisfaction re bona fide
been amended to classify the
explanation given by taxpayer. cases in the following three
buckets:
Section 270A(10): How to
calculate tax payable in three  Where tax return has not
different scenarios.
been furnished.
 In case of loss determined
on the basis of processing
of tax return or
assessment /
reassessment.
Clause 97
New section
270AA:
Immunity
from s.270A
penalty/
prosecution
The taxpayer may apply to TO
for grant of immunity from
penalty under section 270A and
prosecution under section 276C,
provided he pays tax and
interest payable as per
assessment order within period
specified in demand notice and
does not appeal against the
order.
New Clause S 276C
106A
Clause 112
Clause 192
Fourth
Schedule
Part A , w.e.f.
1 April, 2017
Immunity application can
cover immunity from
prosecution under section
276CC as well.
Amends section 276C w.e.f. 1
April, 2017 to cover cases of
under-reporting of income
(new section 270A) as well.
Rule 6 of Sch. IV inter alia
provides that contributions
made by employer to credit of
employee participating in a
recognised provident fund over
12% of employee’s salary or INR
150,000, whichever is less, is
taxable in employee’s hands.
Proposed amendment to tax
the employer contribution to
provident Fund in excess of
INR 150,000 has been rolled
back.
References to section 119 and
section 138 of the Income-tax
Act included.
 In any other cases.
Immunity from initiation of
prosecution proceedings has
been extended to cases
covered by section 276CC
which provides for
prosecution in case of failure
to furnish the income tax
return.
With the introduction of the
new penalty scheme in
relation to under reporting
of income, referencing has
been made in section 276C
which provides for
prosecution in case of
evasion of taxes.
It was proposed to tax the
employer contribution in the
provident fund, in excess of
RINR 150,000 made on or
after 1 April, 2016.
The Finance Bill, 2016 as
passed by the Lok Sabha
withdraws such amendment
and maintains the statusquo for the taxability of
employer’s contribution to
provident fund.
The Finance Bill 2016
introduced the Income
Declaration Scheme, 2016
where taxpayers can declare
their undisclosed income by
paying tax @45%.
This Scheme also provides
for applicability of
machinery provisions of
PwC
Page 9
Tax Insights
Clause No Section in
Amendment as tabled in
in
Income-tax Lok Sabha on 29 Feb 2016
Finance
Act, 1961
Bill
Amendment as passed by
Lok Sabha
on 5 May, 2016
Comments
Income-tax Act and Wealthtax Act to the Scheme.
Now, the bill passed by Lok
Sabha also made referencing
to section 119 (Instruction to
subordinate authorities) and
section 138 (Disclosure if
information respecting
taxpayer) to the Scheme.
Let’s talk
For a deeper discussion of how this issue might affect your business, please contact:
Tax & Regulatory Services – Direct Tax
Gautam Mehra, Mumbai
+91-22 6689 1154
gautam.mehra@in.pwc.com
PwC
Rahul Garg, Gurgaon
+91-124 330 6515
rahul.garg@in.pwc.com
Page 10
Tax Insights
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