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Budget 2017 – Snapshot on

key changes in Taxation

Mukund & Rohit


Chartered Accountants

For Private Circulation only


Snapshot on Union Budget 2017 For Private Circulation only

AGENDA “TRANSFORM,
HIGHLIGHTS ENERGISE AND CLEAN
INDIA” – TEC INDIA

Contents
DIRECT TAX .............................................................................................................................. 2
A. Rates of Income Tax ...................................................................................................... 2
B. Additional Resource Mobilisation ................................................................................ 4
C. Measures for Promoting Affordable Housing and Real Estate Sector .................. 5
D. Anti –Abuse Measures ................................................................................................... 6
E. Ease of Doing Business ................................................................................................... 8
F. Transparency in Electoral Funding ............................................................................. 10
G. Measures for Stimulating Growth .............................................................................. 11
H. Promoting Digital Economy........................................................................................ 12
INDIRECT TAX ......................................................................................................................... 13
A. Service Tax & Customs ................................................................................................ 13
B. Changes in CENVAT Credit Rules, 2004 .................................................................... 15

Disclaimer:
The information contained in this publication is intended for informational purposes only and does not
constitute legal opinion or advice. This document is not intended to address the circumstances of any
particular individual or corporate body. Readers are requested not to act merely based on this
publication and requested to obtained proper professional advice.

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DIRECT TAX
A. Rates of Income Tax

1. RATES

PERSONAL TAX RATES CORPORATE TAX RATES

For Individuals, HUF, BOI, AOP Turnover Limit Rate


Upto Rs. 2,50,000 NIL Less than Rs 50 crores 25%
Rs. 2,50,001 to Rs. 5,00,000 5% Exceeds Rs 50 crores 30%
Rs. 5,00,001 to Rs. 10,00,000 20%
Above Rs. 10,00,000 30% Reduction in Corporate Tax to

Individual, being a resident in India,


25%
who is of the age of 60 years or more for Companies with annual
but less than 80 years turnover for PY15-16, up to Rs. 50
Upto Rs. 3,00,000 NIL crore
Rs. 3,00,001 to Rs. 5,00,000 5%
Rs. 5,00,001 to Rs. 10,00,000 20%

Above Rs. 10,00,000 30%

Individual, being a resident in India,


who is of the age of 80 years or more
Upto Rs. 5,00,000 NIL
Rs. 5,00,001 to Rs. 10,00,000 20%
Above Rs. 10,00,000 30%

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2. SURCHARGES

Sr.
Category Total Income Surcharge on Income Tax
No.
Exceeds Rs. 50 lakhs but
Individual, HUF, BOI, AOP, 10%
not exceeding Rs. 1 Crore
1 Artificial Judicial Person as per
15% (Marginal Relief
Sec. 2(31) (vii) Exceeds Rs. 1 Crore
allowed)
12% (Marginal Relief
2 Firms and Co-operative Societies Exceeds Rs. 1 Crore
allowed)
Exceeds Rs. 1 Crore but
7% (Marginal Relief
not exceeding Rs. 10
3 Domestic Company allowed)
Crores
Exceeds Rs. 10 Crores 12%
Exceeds Rs. 1 Crore but
2% (Marginal Relief
not exceeding Rs. 10
4 Company other than Domestic allowed)
Crores
Exceeds Rs. 10 Crores 5%
Some other cases under some
5 -- 12%
Sections of Section 115

3. EDUCATION CESS AND SECONDARY AND HIGHER EDUCATION CESS will remain
same at 2% and 1%, respectively.

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B. Additional Resource Mobilisation

 Income by way of dividend under Section 115BBDA


Under section 115BBDA, tax is charged at the rate of 10% on income by way of
dividend exceeding Rs. 10 Lakh. The scope of the section is widened and is
made applicable to all resident persons other than a domestic company, a fund
or institution or trust or any university or other educational institution or any
hospital or other medical institution.
Effective From: 01.04.2017 F.Y. 2017-18, A.Y. 2018-19

 New Section 194-IB, 5 % TDS on rent exceeding Rs. 50,000 for a month or part of
month during the previous year in the case of certain Individuals and HUF (other
than those covered under 44AB of the Act)
Effective From: 01.06.2017 F.Y. 2017-18, A.Y. 2018-19

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C. Measures for Promoting Affordable Housing and Real Estate Sector

 The period of holding Long-Term Capital Asset for the benefit of Long Term
Capital Gain is reduced from the existing 36 months to 24 months.
Effective From: 01.04.2017 F.Y. 2017-18, A.Y. 2018-19

 The Provisions of Section 80-IBA amended to promote Affordable Housing.


Carpet Area instead of Built-up Area of 30 and 60 sq.mtr. will be counted, under
the scheme for profit-linked income tax deduction. 30 sq.mtr. limit in case of
municipal limits of 4 metropolitan cities while for the rest of the country including
in the peripheral areas of metros, limit of 60 sq.mtr. will apply.
Effective From: 01.04.2017 F.Y. 2017-18, A.Y. 2018-19

 Tax incentive for the development of capital of Andhra Pradesh.


Capital Gains tax to be exempted for being an individual or a Hindu undivided
family holding land from which land was pooled for creation of the state capital
of Andhra Pradesh. Further the period of completion of the housing project is
extended to five years
Effective From: Retrospectively 01.04.2014 F.Y. 2014-15, A.Y. 2015-16

 New Section 45(5A) inserted for the computation of Capital Gains in case of joint
development agreement wherein the Capital Gains shall be chargeable to tax
in the year in which certificate of completion is issued by a competent authority
to the owner of land being an Individual or a Hindu Undivided Family, and not
when the possession of the property is transferred. However, if the property under
question is transferred before receiving the certificate of completion then
Capital Gains shall be chargeable to tax in the year of such transfer.
Effective From: 01.04.2017 F.Y. 2017-18, A.Y. 2018-19

 Proposed Amendment in Section 55 for shifting base year from 1981 to 2001 for
computation of Capital Gains rendering the costs incurred before 2001 not
available for the purpose of calculation of capital gains and possibly increasing
the base of cost of asset.
Effective From: 01.04.2017 F.Y. 2017-18, A.Y. 2018-19

 Proposed Amendment in Section 54EC - Now investment in any bond


redeemable after three years which has been notified by the Central
Government in this behalf shall also be eligible for exemption.
Effective From: 01.04.2017 F.Y. 2017-18, A.Y. 2018-19

 Property held as stock in trade by a developer and not let out during a year shall
not be deemed to be let out for a period of one year form the end of year in
which the certificate of completion is received and the annual value of such
property shall be taken to be at Nil (Section 23)
Effective From: 01.04.2017 F.Y. 2017-18, A.Y. 2018-19
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D. Anti –Abuse Measures

 Exemption of Long Term Capital Gains tax on income arising from transfer of
equity shares acquired on or after 1.10.2004
 Only if the acquisition of share is chargeable to Securities Transactions Tax
meaning thereby the exemption is not applicable to unlisted equity shares.
Effective From: 01.04.2017 F.Y. 2017-18, AY 2018-19

 Fair Market Value to be full value of consideration in certain cases


Section 50CA: Where consideration for transfer of shares of a company (other
than quoted shares) is less than the Fair Market Value (FMV) of such share
determined in accordance with the prescribed manner, the FMV shall be
deemed to be the full value of consideration for the purposes of computing
income under the head" Capital Gains". Hence any transfer below the FMV of
shares, the difference shall be chargeable to capital gains tax in the hands of
seller.
Effective From: 01.04.2017 F.Y. 2017-18, AY 2018-19

 Widening scope of Income from other sources


Section 56(2)(x) inserted to include all persons within its ambit by specifying that
any receipt of the sum of money or the property by any person without
consideration or for inadequate consideration in excess of Rs. 50,000 shall be
chargeable to tax in the hands of the recipient under the head "Income from
other sources".
Effective From: 01.04.2017 F.Y. 2017-18, AY 2018-19

 Disallowance for non-deduction of tax from payment to resident


As per amended Sec. 58, a disallowance of payments made to residents while
computing income chargeable under the head "income from other sources” if
TDS is not deducted.
Effective From: 01.04.2017 F.Y. 2017-18, AY 2018-19

 Restriction on exemption in case of corpus donation by exempt entities to other


exempt entities
Explanation to Section 11 is inserted to provide that any amount credited or paid,
out of income, being contributions with specific direction that it shall form part
of the corpus of the trust or institution shall not be treated as application of
income.

It is also proposed to insert a proviso in clause (23C) of Section 10 - Income of


certain national fund, educational institutional & hospitals, so as to provide

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similar restriction as above in respect of any amount credited or paid out of their
income.
Effective From: 01.04.2017 F.Y. 2017-18, AY 2018-19

 Fee for delayed filing of return


A new Section 234F is inserted where fee for delay in furnishing of return shall be
levied for AY 2018-19 and onwards in a case where the return is not filed within
the due dates specified for filing of return under sub-Section (1) of Section 139.

1. Rs. 5,000, if the return is furnished after the due date but on or before the
31st day of December of the assessment year;
2. Rs. 10,000 shall be payable in any other case
Where the total income does not exceed Rs.5,00,000 it is proposed that the
fee shall not exceed Rs. 1,000.

Effective From: 01.04.2017 F.Y. 2017-18, AY 2018-19

 Penalty on Professionals for furnishing incorrect information in Statutory Report or


Certificate
New Section 271J inserted which propose penalty of Rs. 10,000 for each such
report or certificate.
Effective From: 01.04.2017 F.Y. 2017-18, AY 2018-19

 Limitation of Interest deduction in certain cases: Section 94B


Deduction of Interest expenses paid by an entity to its associated enterprises
shall be restricted to 30% of its earnings before interest, taxes, depreciation and
amortization (EBITDA) or interest paid or payable to associated enterprise,
whichever is less.

The Section is applicable if:


1. The borrower is an Indian company, or a permanent establishment of a
foreign company.
2. The borrower company pays interest to a non-resident or a permanent
establishment of a non-resident being an 'associated enterprise' or to a third-
party lender where an associated enterprise provides a guarantee or
deposits a corresponding and matching amount of funds with the lender.
3. Interest Expense paid exceeds one crore rupees.

Disallowed interest is allowed to be carried forward for eight assessment years


immediately succeeding the assessment year for which the disallowance was
first made. Further, this is not applicable to Banks and Insurance business.
Effective from: 01.04.2017 F.Y. 2017-18, A.Y. 2018-19

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E. Ease of Doing Business

 TDS on Insurance Commission


Non-deduction of tax at source in respect Insurance Commission referred to in
Section 194D in the case of Individuals and HUFs, if self-declaration in Form. No.
15G/15H under Section 197A is furnished.
Effective From: 01.06.2017 F.Y. 2017-18, A.Y. 2018-19

 Maintenance of Books of Accounts


In the case of Individuals and Hindu Undivided Family carrying on business or
profession [other than those mentioned in Sub-Section (1) such as legal, medical,
engineering or architectural profession or the profession of accountancy or
technical consultancy or interior decoration or any other profession as is notified
by the Board in the Official Gazette], monetary limits of income and Total sales
or turn over or gross receipts, etc. specified in clause (i) & (ii) of 44AA(2) for
maintenance of books of accounts has been increased from Rs, 1,20,000 (one
lakh twenty thousand rupees) to Rs. 2,50,000 (two lakhs fifty thousand rupees)
and from Rs.10,00,000 (ten lakh rupees) to Rs. 25,00,000 (twenty-five lakh rupees),
respectively.
Effective From: 01.04.2017 F.Y. 2017-18, A.Y. 2018-19

 Requirement of Audit of Accounts


Eligible person, who declares profits for the previous year in accordance with
the provisions of Sub-Section (1) of Section 44AD (presumptive taxation) and his
total sales, total turnover or gross receipts, as the case may be, in business does
not exceed two crore rupees in such previous year, he shall not be required to
get his accounts audited under Section 44AB.
Effective From: 01.04.2016 F.Y. 2016-17, A.Y. 2018-19

 Non-deduction of tax in case of Compulsory Acquisition of any Immovable


Property
No deduction shall be made under Section 194LA of the Act where such
payment is made in respect of any award or agreement which has been
exempted from levy of income-tax under Section 96 (except those made under
Section 46) of Right to Fair Compensation and Transparency in Land Acquisition,
Rehabilitation and Resettlement Act, 2013, ('RFCTLARR Act')
Effective From: 01.04.2017 F.Y. 2017-18, A.Y. 2018-19

 TDS under Section 194J


TDS to be deducted @2% instead of 10% in case of payments received or
credited to a payee, being a person engaged only in the business of operation
of call centre.
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Effective From: 01.06.2017 F.Y. 2017-18, A.Y. 2018-19

 Specified Domestic Transactions


Expenditure in respect of which payment has been made by the assesse to a
person referred to in under Section 40A(2)(b) are to be excluded from the scope
of Section 92BA of the Act.
Effective From: 01.04.2016 F.Y. 2016-17, A.Y. 2017-18

 Conversion of Preference Shares to Equity Shares


Conversion of Preference Share of a Company into its Equity Share shall not be
regarded as transfer for the purpose of levy of Capital Gain Tax
Effective From: 01.04.2017 F.Y. 2017-18, A.Y. 2018-19

 Advance Tax under Section 211 & Interest under Section 234C
If shortfall in payment of advance tax is on account of under-estimation or failure
in estimation of income of the nature referred to in Section 115BBDA (certain
dividends received from domestic companies exceeding 10 lakh rupees), the
interest under Section 234C shall not be levied subject to fulfilment of conditions
specified therein.
Effective From: 01.04.2016 F.Y. 2016-17, A.Y. 2017-18

 Rupee Denominated Bonds outside India


Gains arising to secondary holders due to appreciation of rupee against a
foreign currency at the time of redemption of rupee denominated bond of an
Indian company, the said appreciation of rupee shall be ignored for the
purposes of computation of full value of consideration. Further, any transfer of
capital asset, being rupee denominated bond of Indian company issued
outside India, by a non- resident to another non- resident shall not be regarded
as transfer.
Effective From: 01.04.2017 F.Y. 2017-18, A.Y. 2018-19

 Interest on Refund
Simple interest @0.5% for every month or part of a month from the date on which
claim for refund is made in the prescribed form or in case of an order passed in
appeal, from the date on which the tax is paid, to the date on which refund is
granted.
Effective From: 01.04.2016 F.Y. 2016-17, A.Y. 2017-18

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F. Transparency in Electoral Funding

Effective From: F.Y. 2017-18

 Cash Donation allowed per person: Rs. 2,000 (Earlier Rs. 20,000)

 More than Rs. 2,000 by an account payee cheque drawn on a bank or an


account payee bank draft or use of electronic clearing system through a bank
account.

 Political parties also allowed to issue Electoral Bonds for funding.

 Political party furnishes a return of income for the previous year in accordance
with the provisions of sub-Section (4B) of Section 139 on or before the due date
under Section 139.

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G. Measures for Stimulating Growth

 Carry forward and Set off of loss in case of certain companies


As per existing provisions loss would only be allowed if not less than 51% of the
voting power were beneficially held by person who beneficially held shares of
the company carrying not less than 51% of the voting power on the last day of
the year or years in which the loss was incurred.

It is proposed to amend Section 79 of the Act to provide that where a change


in shareholding has taken place in a previous year in the case of a company,
not being a company in which the public are substantially interested and being
an eligible start-up as referred to in Section 80 -IAC of this Act, loss shall be carried
forward and set off against the income of the previous year, if all the
shareholders of such company which held shares carrying voting power on the
last day of the year or years in which the loss was incurred, being the loss incurred
during the period of 7 years beginning from the year in which such company is
incorporated, continue to hold those shares on the last day of such previous
year.
Effective From: 01.04.2017 F.Y. 2017-18, A.Y. 2018-19

 Section 80- IAC


The existing provisions of Section 80-IAC, inter alia, provide that an eligible start-
up shall be allowed a deduction of an amount equal to 100% of the profits and
gains derived from eligible business for 3 consecutive assessment years out of 5
years beginning from the year in which such eligible start-up is incorporated.

It is proposed to provide that deduction under Section 80-IAC can be claimed


by an eligible start-up for any 3 consecutive assessment years out of 7 years
beginning from the year in which such eligible start-up is incorporated.
Effective From: 01.04.2017 F.Y. 2017-18, A.Y. 2018-19

 Section 115JAA -Rationalisation of Provisions relating to tax credit for Minimum


Alternate Tax
MAT / AMT Credit will be allowed till 15th A.Y. instead of earlier 10th A.Y.
Effective From: 01.04.2017 F.Y. 2017-18, A.Y. 2018-19

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H. Promoting Digital Economy

 Disallowance of Depreciation under Section 32 and Capital Expenditure under


Section 35AD.
Addition to Capital Asset and Capital Expenditure incurred under Section 35AD
will be disallowed if such asset is brought in by payment of Cash in excess of Rs.
10,000 to a single person per day.
Effective from: 01.04.2017 F.Y. 2017-18, A.Y. 2018-19

 Payment in Cash - Section 40A (3)


The Maximum Cash Payment Limit of Rs. 20,000 per day per person is now
reduced to Rs. 10,000 per day per person.
Effective From: 01.04.2017 F.Y. 2017-18, A.Y. 2018-19

 Tax on Presumptive Income - Section 44AD


The Rate of tax on Presumptive income reduced to 6% from the existing 8% of
total turnover subject to the fact that the proceeds are received otherwise than
in cash. The Limit of 8% continues on proceeds received in cash.

Corresponding change is also made under Section 44AB wherein the


requirements of audit of books of accounts of assesses falling with the ambit of
Section 44AD are exempted from getting their books audited if the total turnover
or gross receipts are less than Rs. 2 crore.
Effective From: 01.04.2017 F.Y. 2017-18, A.Y. 2018-19

 Accepting Loans /Deposits in Cash - Section 269ST


Restrictions imposed to receive Rs. 3,00,000 per person per day in single
transaction in cash.
Any contravention will attract penalty under Section 271DA which equals to
amount of such receipts.
Effective From: 01.04.2017 F.Y. 2017-18, A.Y. 2018-19

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INDIRECT TAX
A. Service Tax & Customs

 Rate of service tax remains unchanged

 Retrospective amendment to Valuation Rules for construction works contract


It is proposed to retrospectively amend the said Rule w.e.f. 01.07.2010 to provide
that under Rule 2A (i) value of land or undivided share of land shall be excluded
and in respect of Rule 2A (ii) if the amount charged includes value of land or
undivided share of land, the value of taxable service shall be same as a
percentage of total amount charged specified under abetment Notification
no. 26/2012‐ST from time to time or earlier law.
(Retrospective amendment shall come into force from the date of assent of
Finance Bill, 2017.)

 Service Tax on Long Term Lease – Retrospective exemption & refund


It may be noted that as per Notification No. 41/2016‐ Service Tax DT. 22 Sept.
2016 one time upfront amount (called as premium, salami, cost, price,
development charges or by any other name) payable on long term (thirty years
or more) lease of industrial plots provided by State Government Industrial
Development Corporations/ Undertakings is exempted from Service Tax.

However, said Notification did not operate retrospectively. It came into


operation from 22nd September 2016. Hence it has been proposed that no tax
shall be payable during the period commencing from the 1st day of June, 2007
and ending with the 21st day of September, 2016. It shall come into force from
the date of assent of Finance Bill, 2017.

Refund shall be made of all such service tax which has been collected, but
which would not have been so collected, had sub‐Section (1) been in force at
all material. An application for claim of refund of service tax shall be made within
a period of six months from the date on which the Finance Bill, 2017 receives the
assent of the President.

 R&D Cess which was levied on Royalty payment is abolished now.


Effective From: 01.04.2017 F.Y. 2017-18, A.Y. 2018-19

 Bill of entry required to be submitted within 1 day (Earlier 2 days) from arrival of
vessel.
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 Custom duty requires to be paid at the time of submission of Bill of Entry (Earlier
after assessment and valuation by the Custom Authority).

 Other exemptions
As per Notification no. 7/2017‐ Service Tax dated 02.02.2017, services provided
to the Government by way of transport of passengers, with or without
accompanied belongings, by air, embarking from or terminating at a Regional
Connectivity Scheme Airport, against consideration in the form of Viability Gap
Funding (VGF) will be included in the mega exemption notification 25/2012‐ST
(effective from 02.02.2017) and hence same shall be exempt from tax.

Exemption shall not apply on or after the expiry of a period of one year from the
date of commencement of operations of the Regional Connectivity Scheme
Airport as notified by the Ministry of Civil Aviation.

As per Notification no. 7/2017 ‐ Service Tax dated 02.02.2017, services by way of
carrying out any process amounting to manufacture or production of goods,
excluding alcoholic liquor for human consumption hitherto exempted under Sec.
66D (f) is proposed to be covered under mega exemption notification 25/2012‐
ST (effective from the date of assent to Finance Bill, 2017).

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B. Changes in CENVAT Credit Rules, 2004 (Notification No. 4/2017‐ C.E.


(N.T.) Effective From 02.02.2017)

 Interest to be included for Rule 6 in case of banking and a financial institution


As per Section 66D(n) services by way of extending deposits, loans or advances
in so far as the consideration is represented by way of interest or discount is
included in the negative list and hence no service tax is payable on such interest.

As a banking or a financial institution provides both taxable services as well as


exempted services in the nature of interest, Rule 6 of CENVAT Credit Rules, 2004
is applicable and they have an option to claim full CENVAT Credit and pay 7%
of value of exempted service or proportionately determine the ineligible credit
by applying following formula to common credits, credit exclusively attributable
to exempted service s is not allowed:

D = (E/F) × C;
Where, E is the sum total of—
(a) Value of exempted services provided; and
(b) Value of exempted goods removed, during the preceding financial
year;

Where, F is the sum total of—


(a) Value of non‐ exempted services provided,
(b) Value of exempted services provided,
(c) Value of non‐ exempted goods removed, and
(d) Value of exempted goods removed, during the preceding financial
year

In addition to above options a banking company and a financial institution


including a non‐banking financial company, engaged in providing services by
way of extending deposits, loans or advances shall have an additional option
to pay for every month an amount equal to fifty per cent of the CENVAT credit
availed on inputs and input services in that month.

If a banking company and a financial institution does not opt for last option (i.e.
claiming 50% credit) then under initial both options value of exempted services
is to be determined. As per clause (e) of Explanation 1 the value shall not include
the value of services by way of extending deposits, loans or advances in so far
as the consideration is represented by way of interest or discount. Thus, the
amount of interest is not to be added in the value of exempted service while
applying the formula.
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It is proposed that said clause (e) shall not apply to a banking company and a
financial institution including a non‐banking financial company, engaged in
providing services by way of extending deposits, loans or advances. Hence the
amount of interest will be included in the value of exempted service for
ascertaining the ineligible credit.

 Transfer of credit
Rule 10 provides that if a manufacturer of the final products/provider of output
service shifts his factory/business to another site or the factory/business is
transferred on account of change in ownership or on account of sale, merger,
amalgamation, lease or transfer of the factory/business to a joint venture with
the specific provision for transfer of liabilities of such factory/business, then, the
manufacturer or service provider shall be allowed to transfer the CENVAT credit
lying unutilized in his accounts to such transferred, sold, merged, leased or
amalgamated factory/business.

It is proposed that the transfer of the CENVAT Credit shall be allowed within a
period of three months (can be further extended for period not exceeding six
months by Principal Commissioner or Commissioner) from the date of receipt of
application by the Deputy Commissioner of Central Excise or Assistant
Commissioner of Central Excise, as the case may be.

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Other Key Features

Total resources being transferred of Rs. 4.11 lakh crores to the States and the Union
Territories, against Rs. 3.60 lakh crores in BE 2016-17

Net market borrowing of Government restricted to Rs. 3.48 lakh crores, lower than Rs. 4.25
lakh crores of the previous year

Rs. 10,00,000 Crores Target Fixed for Agriculture Credit in 2017-18.

Rs. 1,87,223 crores Total allocation for Rural, Agriculture and Allied sectors

Rs. 2,41,387 crores for transportation sector as a whole, including rail, roads and shipping

Reduction in Revenue Deficit of 2.3% reduced to 2.1% in the Revised Estimates

Allowable provision for Non-Performing Asset of Banks increased from 7.5% to 8.5%.
Interest taxable on actual receipt instead of accrual basis in respect of NPA accounts

Basic customs duty on LNG reduced from 5% to 2.5%

Mukund & Rohit, Chartered Accountants


(Head Office)

E-8, Avishkar Complex,


Old Padra Road,
Vadodara – 390007,
Gujarat, India.
Tel: +91 - 265 - 2310448, 2357845, 2313515

Web: http://mukundrohit.com/

Gandhidham Mumbai
(Branch Office) (Branch Office)

1st Floor, Bhagwati Chambers, BBZ S 515, Highway Commerce Centre, 5,


53, Zanda Chowk, Gandhidham, Laghu Udyog Kendra, I.B. Patel Road,
Kachchh, Gujarat, India. Goregaon (E), Mumbai – 400063,
India.

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