Union Budget 2015

We have analyzed some provisions of Finance Bill 2015 which are special one but not circulated in our general messages since budget. The same has been divided into provisions related to Appellate Proceedings, International Taxation and general.


Appellate Proceedings:


  • The income-limit of the cases that may be decided by single member bench of ITAT has been increased.
  • Procedure for appeal by revenue has been prescribed when an identical question of law is pending before Supreme or High Court (Procedure for assessee has already been there).
  • Only once in a life time, an approach to Settlement Commission can be made.
  • 253(1) has been amended to appeal against the order passed for Sec. 10(23C) to ITAT.
  • 153C has been amended.
  • There has been Simplification of approval regime for issue of notice for re-assessment
  • 263 amended – Revision of order that is erroneous in so far as it is prejudicial to the interests of revenue


International Taxation:


  • Clarity has been provided regarding indirect transfer provision
  • The threshold for specified domestic transaction u/s 92BA has been raised.
  • Section 295(2) has been amended to enable CBDT to notify rules for giving foreign tax credit.
  • Clarity has been provided for Section 9(1)(v) regarding source rule in respect of interest received by the non-resident in certain cases
  • Sec 6(1) has been amended and powers given to CBDT to prescribe manner and procedure for computing stay in India.
  • 115JB amended that exclude income from securities (other than short term) arising to FII.
  • 6 has been amended for determining the residential status of company.




  • Surcharge will be levied at the rate of 7% and 12% for domestic company.
  • No cash transaction > Rs.20,000 even for purchase of immovable property. Consequently 271D and 271E penalty provisions amended for violation.
  • Extension of eligible period of concessional tax rate under section 194LD
  • Section 80JJAA amended for deduction of employment of new workmen.
  • Clarification provided for Allowance of balance 50% additional depreciation.
  • Tax neutrality effect has been given on merger of similar schemes of Mutual Funds.
  • Section 80D amended to include payment made on account of medical expenditure in respect of a very senior citizen
  • Form 15G/H has been enabled for payment made under Life Insurance Policy.
  • The requirement of obtaining TAN number for Certain deductors (immovable property transaction) has been relaexed.
  • Time limit has been prescribed for submit for 10B relating to provisions of section 11 relating to accumulation of Income by charitable trusts and institutions
  • Rules for providing certificate from govt. doctor u/s 80DDB relaxed.
  • Provision of MAT u/s 115JB has been rationalized in case of company where it is a member of an AOP.
  • Clarification has been provided regarding deduction of tax from payments made to transporters.
  • 194A has been amended to rationalize provisions relating to TDS on interest other than securities.