Introduction

Government of India has presented its Budget for the fiscal year 2024-25 on 23rd July 2024, wherein government has focused on Sectoral Development by identifying Priority Sectors and proposing various Reforms for these Sectors.

 

Priority Sectors of Indian Government for fiscal year 2024-25:

Section A: Reforms in Some of the Key Priority Sectors proposed in Budget 2024

Priority Sector 1: Employment & Upskilling

1.Employment Linked Incentives:

  1. Incentive for First Time Entrants in EPFO: One-month wage to new entrants in all formal sectors in 3 instalments up to ₹15,000.
  2. Incentive to promote new employment: An incentive is proposed for both employee & employer for EPFO contributions in the specified scales for the first 4 years.
  3. Reimbursement of EPFO Contribution: Government will reimburse EPFO contributions of employers up to ₹3000 per month for 2 years for all new hires.

2. Other announcements benefitting women and youth:

  1. Facilitate higher participation of women in the workforce through setting up of Working Women Hostels in collaboration with industry and establishing creches.
  2. Loans up to ₹7.5 lakh with a guarantee from a government promoted Fund.
  3. Financial support for loans upto ₹10 lakh for Higher Education in domestic institutions.
  4. Direct E-vouchers to 1 lakh students every year.
  5. Annual interest subvention of 3%
  6. Internship in 500 select corporates for 12 months, proposing benefit of Rs. 5000 p.m. as stipend and Rs. 6,000 as one-time assistance through the CSR Funds.
  7. Education Loan for youth: Government has proposed financial support upto Rs. 10 Lacs for higher education in domestic institutes with annual interest subvention up to 3%.

Priority Sector 2: Manufacturing and MSME

  1. Credit Guarantee Scheme has been proposed for MSMEs in the Manufacturing Sector with a new assessment model for MSME credit. It has also been proposed to provide credit support to MSME’s during stress period.
  2. Turnover threshold of buyers for mandatory onboarding on TReDS platform to be reduced from ₹500 crore to ₹250 crore.
  3. Mudra Loans: The limit enhanced to ₹ 20 lakh from the current ₹ 10 lakh under the ‘Tarun’ category.
  4. Financial support has been proposed for MSME Units for Food Irradiation, Quality & Safety Testing
  5. Government has proposed to set up E-Commerce Export Hubs in PPP mode which will enable MSMEs and traditional artisans to cater international markets.

Priority Sector 3: Next GEN Reforms Proposed

  1. FDI and Overseas Investments: Simplified to facilitate FDIs and promote opportunities for using Indian Rupee as a currency for overseas investments.
  2. NPS Vatsalya: A plan for contribution by parents and guardians for minors.
  3. Improvement of data governance, collection, processing and management of data and statistics.
  4. New Pension Scheme (NPS): A solution that address the relevant issues, protects the common citizen and maintains fiscal prudence will be formed.
  5. Taxonomy for climate finance: Enhancing the availability of capital for climate adaptation and mitigation related investments.
  6. Establishment of land registry
  7. Digitalized Land Records: Land records in urban areas will be digitized with GIS mapping.
  8. Various other measures have been proposed for digitisation of maps, farmer’s registries and unique land parcel identification numbers.

Section B: Income Tax Related Amendments

1.Change in the Income Tax Slab Rates for Individuals filing their ITR under the new Income Tax Regime

2. Standard Deduction: To incentivize the salaried taxpayers to switch to a new income tax regime, standard deduction has been proposed to increase from Rs. 50,000 to Rs. 75,000.

3. Family Pension: In addition, the Government has also proposed to increase the benefit of deduction for family pension income from Rs. 15,000 to Rs. 25,000.

4. Abolishment of Angel Tax: Government has proposed to abolish the Angel Tax in a bid to strengthen the startup ecosystem and to support innovation in the country.

5. Income under House Property (Section 28): Income earned by renting out a residential house or part of it by the owner will be taxed under the category of “Income from house property,” not under “Profits and gains of business or profession.” This will have the effect of not allowing the business expenditure against such income

6. Employer Contribution to Pension Scheme (Section 36): Non-government employers paying their contribution towards pension scheme under section 80CCD shall be entitled to higher deduction of 14% instead of existing 10% of the salary of the employees whose salary will be taxable under the new income tax regime.

7. Capital Gain: Finance Bill 2024 has proposed some major changes in the taxation of capital gain, including definition of short term and long-term capital gain and their tax rates:

  • Changes in the holding period of assets for categorization into Short Term & Long-Term Capital Gain:
  • Changes in the Capital Gain Tax Rates: 

8. Changes in TDS and TCS

  1. TCS on luxury goods: TCS of 1% to be collected on notified luxury goods of value exceeding 10 lakh rupees with effect from 1st January 2025.
  2. Delayed payment of TCS: The interest on delayed payment of TCS has been proposed to increase to 1.5% per month with effect from 1st April 2025.
  3. TDS on Floating Rate Savings (Taxable) Bonds (FRSB) 2020 TDS is proposed on interest exceeding ₹10,000 on Floating Rate Savings (Taxable) Bonds (FRSB) 2020 or any other notified security of the Central or State Governments
  4. Inclusion of taxes withheld outside India for purposes of calculating total: income Any amounts deducted under Chapter XVII-B and income tax paid outside India that qualify for a credit against taxes under the law are to be deemed as income received when calculating the total income of the assessee.
  5. TDS rate on E-Commerce operators is proposed to be reduced from 1% to 0.1%.
  6. TDS on remuneration by Partnership Firm to its Partners (Section 194T): A new section has been inserted in Finance Bill 2024 which mandates TDS @ 10% on payments paid by the partnership firm to its partners which includes remuneration, salary, interest, commission, bonus etc. w.e.f. 1st April 2025.
  7. Rationalization of TDS Rates: Following amendments in the TDS rates have been proposed in the Finance Bill 2024:

9. Equalization Levy

  • Earlier Equalization Levy was chargeable under section 165A w.r.t. e-commerce supply or services.
  • Clause (50) of section 10 provides for exemption to any income arising from any specified service provided on or after the date on which the provisions of Chapter VIII of the Finance Act, 2016 comes into force, or arising from any e-commerce supply or services made or provided or facilitated on or after the 1st day of April, 2020 and chargeable to equalisation levy under that Chapter.
  • Finance Bill 2024 has amended the said clause so as to exempt the income arising from any e-commerce supply or services made or provided or facilitated on or after the 1st day of April 2020 till the 1st day of August 2024.
  • Finance Bill 2024 also proposed to insert sub-section (4) under section 165A to provide that the provisions of the said section shall not apply to any consideration received or receivable by an e-commerce operator from e-commerce supply or services made or provided or facilitated by it on or after the 1st day of August, 2024.

10. Incentives and Reliefs

 

10.1 Direct Tax Vivad se Vishwas Scheme 2024

A new scheme has been introduced to reduce litigation and expedite the settlement of disputed issues. This scheme aims to provide a swift resolution mechanism for taxpayers involved in disputes with the tax authorities, thereby reducing the burden of prolonged litigation.

 

10.2 Incentives for International Financial Services Centres (IFSCs)

To promote the development of world-class financial infrastructure in India, several tax concessions have been provided to units located in IFSCs. These include exemptions for specified funds and core settlement guarantee funds, as well as relaxation of thin capitalisation rules for finance companies in IFSCs

 

10.3 Promotion of Domestic Cruise Ship Operations

To boost the cruise shipping industry in India, a presumptive taxation regime is introduced for non-resident cruise ship operators. This regime deems 20% of the aggregate amount received or receivable as profits and gains from the business of cruise shipping. Additionally, lease rentals paid by companies under this regime are exempt in the hands of the recipient company if both companies are subsidiaries of the same holding company.

11. Simplification and Rationalization

 

11.1 Block Assessment for Search Cases

The Bill proposes to reintroduce the scheme of block assessment for search cases. This aims to consolidate assessments for the block period, reduce litigation costs, and ensure coordinated investigation during search assessments. The block period will consist of six assessment years preceding the previous year in which the search was initiated, plus the period from 1st April of that year to the date of the last authorisation.

 

11.2 Rationalisation of Reassessment Provisions

The reassessment provisions under sections 147 to 151 have been rationalised to reduce litigation and provide clarity. The time limit for issuing notice under section 148 has been reduced, and the procedure for conducting inquiries before issuing notice has been streamlined.

 

11.3 Amendment to Section 245

Section 245, relating to the set-off and withholding of refunds, has been amended to provide a clearer framework for the adjustment of refunds against outstanding tax demands. The period for withholding refunds has been extended to 60 days from the date of assessment.

 

11.4 Rationalisation of Assessment Timelines

The Finance Bill, 2024, proposes significant changes to the timelines for assessment and reassessment. The new timelines aim to expedite the assessment process and reduce uncertainty for taxpayers. Key changes include:

    • Time Limit for Issuing Notice: The time limit for issuing a notice under section 148 has been reduced to three years from the end of the relevant assessment year. In specific cases involving significant amounts, the limit can be extended to five years.
    • Approval Requirements: No notice under section 148 can be issued without prior approval from the specified authority if the information suggests that income chargeable to tax has escaped assessment.

12. Provisions for Charitable Trusts and Institution

 

12.1 Merger of Exemption Regimes: To simplify the regulatory framework for charitable trusts and institutions, the Bill proposes to sunset the first regime under section 10(23C) and transition all entities to the second regime under sections 11 to 13. This will streamline the approval and registration processes and reduce administrative burden.

 

12.2 Condonation of Delay

The Bill introduces provisions allowing the Principal Commissioner or Commissioner to condone delays in filing applications for registration under section 12AB if reasonable cause is shown. This aims to prevent undue hardship for trusts and institutions.

 

12.3 Rationalisation of Timelines

Timelines for filing applications for approval under section 80G and for processing such applications have been rationalised to ensure timely grant of approvals and registrations.

13 Taxation of Buyback of Shares

 

13.1 Tax on Distributed Income

The Finance Bill, 2024, proposes a tax on the distributed income arising from the buyback of shares by domestic companies. This tax is aimed at addressing the practice of companies distributing accumulated profits through share buybacks rather than dividends, which are subject to dividend distribution tax.

Section C: Customs Related Amendments

Finance Bill 2024 has proposed to amend the customs duty and BCD (Basic Custom Duty) on various items as tabulated below:

Section D: GST Related Amendments

1.Levy of Tax & Schedule III (Section 9)

– Section 9 is proposed to be amended to exclude rectified spirit / Extra Neutral Alcohol (ENA) used for manufacture of alcoholic liquor for human consumption from the levy of GST.

– The following activities/transactions to be included in Schedule III to the CGST Act:

      • Co-insurance premium apportioned by lead insurer to the co-insurer for supply of insurance service to the insured in co-insurance agreements subject to complete payment of tax by lead insurer.
      • Transaction of ceding commission/re-insurance commission between insurer and re-insurer subject to complete payment of tax by reinsurer.

2. Power not to recover Goods and Services Tax not levied or short-levied as a result of general practice (Section 11A – New Section)

  • It has been recommended to insert Section 11A in the CGST Act, so as to empower the Government, to allow regularization of non-levy or short levy of GST, due to common trade practices.
  • Condition: On levy of tax, there should be a continued or past practice of
    1. Not levying the tax
    2. Short levying than the higher amount of tax levied
  • Mechanism: Government on recommendation of Council shall issue a notification
  • Direction: No requirement to pay tax that is or was not levied or short levied.
  • Note: In the past periods, said benefit has been given by issuance of circular u/s 168 of the Act on “as is where is basis”

3. Time of Supply in case of Reverse Charge Mechanism (Section 13(3))

Section 13(3) has been amended to draw a line between Tax Invoices issued by supplier and Self-Invoices to be issued by the recipient in cases where the supplier is unregistered. Thus, the TOS in case of RCM shall the earliest of the following dates:

  • The date of payment
  • The date of Invoice from the registered supplier
  • The date of Self-Invoice

4. Time limit to issue Self – Invoice (Section 31)

Section 31(3)(f) has been proposed to be amended to introduce a time limit to issue invoices in respect of goods or services or both received by him from the supplier who is not registered on the date of receipt of goods or services or both. Further an explanation has been added to include supplier who is registered solely for the purpose of deduction of tax under section 51.

5. Time Limit to claim ITC (Section 16 (5) & (6) – New Addition)

  • Section 16(5) Last date for claiming ITC for FY 2017-18, FY 2018-19, FY 2019-20 and FY 2020-21 in respect of any invoice or debit note through any Form GSTR-3B filed up to 30 November 2021 will be deemed to be 30 November 2021. This change will also be effective from July 1, 2017.
  • Section 16(6) to conditionally relax cases where returns for the period from the date of cancellation of registration / effective date of cancellation of registration till the date of revocation of cancellation of registration, are filed by the registered person within thirty days of the order of revocation. This change will also be effective from July 1, 2017.
  • Section 146 of the Finance Bill confirms that where ITC has already been reversed by taxpayers or tax has been discharged –no refunds shall be granted. Section is silent on and interest and penalty.

6. Sunset of Section 73 & 74 and Sunrise of Section 74A

7. Revocation of cancellation of registration (Section 30)

A proviso has been proposed to be inserted in section 30(2) to follow conditions and restrictions, as may be prescribed for revocation of cancellation of registration.

8. Summon (Section 70)

Section 70 has been amended to bound the person summoned to attend, either in person or by an authorised representative and shall state the truth during examination or make statements or produce such documents and other things as may be required.

9. Section 109

Section 109 to be amended to provide for handling of anti-profiteering cases by the Principal Bench of the GST Appellate Tribunal.

10. Section 112

  • The time limit for filing appeals to the GST Appellate Tribunal will begin from within 3 months from date of communication of order by first appellate authority or a date as notified by the Government. This gives taxpayers more time to prepare and file their appeals for pending cases.
  • The amount of pre-deposit for filing appeal with the GST Appellate Tribunal (GSTAT) to be reduced from 20% (subject to the maximum amount of INR 0.50 Bn. CGST and INR 0.50 Bn. SGST) to 10% (subject to the maximum amount of INR 0.20 Bn. CGST and INR 0.20 crores SGST).

11. Section 122(1B)

Retrospective amendment to Section 122(1B) of the CGST Act with effect from 1st October 2023 to provide that the said penal provision shall be applicable only on those E-commerce Operators (‘ECOs’) who are liable to collect tax under the provisions of Section 52 of the CGST Act.

12. Section 128A

  • Insertion Section 128A in the CGST Act, 2017 to provide conditional waiver of interest and penalty for FY 2017-18 to FY 2019-20, in cases where the orders/show-cause notice has been issued under Section 73 of the CGST Act and the taxpayer pays the tax demand. The waiver does not cover demands of account of erroneous refund. In case, a taxpayer has paid the interest and penalty, no refund will be granted in such cases.
  • No partial waiver can be availed in respect of selective issues from any given show cause notice/order, and one would have to pay the entire tax demand on the given show cause notice/order to claim this waiver.
  • The benefit is available at SCN stage or order stage of at order of appellate authority stage.
  • Order of Section 74 subsequently passed under Section 73 are also eligible for the scheme.
  • Date of March 31, 2025, is not mentioned in the Section.

13. Section 140(7)

Section 140(7) to be amended retrospectively with effect from 1 July 2017 to allow transitional credit on invoices pertaining to services provided before 1 July 2017 and where the invoices were received by the Input Service Distributor (ISD) before such date.

14. Section 171

Section 171 to be amended to provide for a sunset clause for anti-profiteering under the GST law. The sunset clause for receipt of new application regarding anti-profiteering is recommended to be 1 April 2025.

15. Section 16 of the IGST Act r/w Section 54 of the CGST Act

Exporters of goods which attract export duty shall not be eligible for claiming refund under section 54 of the CGST Act, 2017 and Section 16 of the IGST Act, 2017. Such restriction shall also apply to similar goods being supplied to SEZ developer or SEZ unit for authorized operations.

Disclaimer: The information contained in this Article is intended solely for personal non-commercial use of the user who accepts full responsibility of its use. The information in the article is general in nature and should not be considered to be legal, tax, accounting, consulting or any other professional advice. We make no representation or warranty of any kind, express or implied regarding the accuracy, adequacy, reliability or completeness of any information on our page/article. 

To stay updated Subscribe to our newsletter today

Explore other Legal updates on the 1-Comply and follow us on LinkedIn to stay updated 

Schedule A Demo