Page 30 - DHC Budget Book 2021-22 Final
P. 30
INDIA BUDGET 2021-22 additional deduction of interest upto H 1.5 lacs
on loan taken for affordable housing u/s 80EEA.
W.e.f. AY 2021-22, due date for filing return of income extended for following persons:
Reconstruction or splitting up of a public sector company into separate companies shall be deemed to be demerger u/s 2(19AA), if the same has been made to transfer any asset of the demerged company and the resultant company is a public sector company on appointed date, subject to fulfillment of other conditions as may
Partner of a firm liable to furnish report u/s
92E - from 31st October to 30th November
and be notified by Central Government.
Where Sec. 5A is applicable to Spouse (governed by Portuguese Civil Code, 1980) of
a partner of a firm liable to Tax Audit - from
31st July to 31st October
Corporate Assessee
Corporate Tax Rates remain unchanged @ 30%. Tax rate for domestic companies having annual turnover or gross receipts ≤ H 400 Crs. in FY 2019-20 shall be 25%. Tax rate for Companies opting taxation u/s 115BAA or 115BAB remains unchanged at 22% and 15% respectively.
Sec. 44DB provides specified deduction [Sec.
32, 35D, 35DD & 35DDA] in case of business reorganisation of co-operative bank. The scope of Sec. 44DB is now proposed to be extended
in case of conversion of a primary co-operative bank to a banking company. Necessary amendments has also been made in Sec. 47(vica) & (vicb) to exempt transfer of a capital asset and allotment of shares as a result of such conversion.
Sec. 72A allowing carry forward of losses and unabsorbed depreciation on amalgamation extended to amalgamation of all public sector companies with other public sector companies instead of only public sector company which is engaged in the business of operation of aircraft.
Sec. 72A also extended to amalgamation of
an erstwhile public sector company with other companies after strategic disinvestment by the Government (where share purchase agreement under strategic disinvestment restricts immediate amalgamation). Post disinvestment, amalgamation must be carried out within 5 years from end of the previous year in which restriction of amalgamation in the agreement ends. However, accumulated losses and unabsorbed depreciation available to amalgamated company shall not be more than the amount at the time of strategic disinvestment.
Sec. 115JB amended w.e.f. AY 2021-22 to provide that if income of any earlier year(s) is included in the books of accounts of current year on account of Advance Pricing Agreement u/s 92CC or Secondary Adjustment u/s 92CE, then the Book Profit of such earlier year(s) and tax payable thereon shall be re-computed by
the AO in the current year if an application is made by the assessee. Further, period of 4 years for determining time limit u/s 154(7) shall be reckoned from the end of Financial Year in which such application is received by AO.
28 Building a Resilient and Confident India
Sec. 115JB amended w.e.f. AY 2021-22 to
align treatment of dividend income in case of foreign companies with that of capital gains on transfer of securities, interest, royalty and fee for technical services. Hence, net dividend income is to be reduced in cases where such dividend income is taxed at lower than MAT rate due to DTAA.
International Taxation and Transfer Pricing
Sec. 2(29A) inserted w.e.f. AY 2021-22 to define the expression ‘liable to tax’ to mean that there is a liability of tax on that person under the law of any country and will include a case where subsequent to imposition of such tax liability, exemption has been provided.
In order to make location in International Financial Services Centre (IFSC) more attractive, it is proposed to provide various incentives as under w.e.f. AY 2022-23:-
Sec. 9A(8A) inserted to provide that any or more of the conditions for eligible investment fund and its eligible fund manager shall not apply or shall apply with such modifications as may be specified by notification, if the fund manager is located in an IFSC and has commenced operations on or before 31-03- 2024;
