UNION

BUDGET
2024‑25
 Comments on Budget 2023-24
“On a deeper analysis the changes in Direct taxes seem to be
made ranging with a nuanced attempt at simplification and
rationalization. The decriminalization of certain TDS defaults,
introduction of a Vivaad Se Vishwas Scheme and increase in the
limits for filing appeals will definitely result in reduced litigation
and benefit taxpayers.”
CA. ASHWANI KUMAR, FOUNDING PARTNER

Contents
Foreword 03
“ The overall tenor of the Union Budget seems to suggest a
renewed thrust towards the Governments avowed aim of a
“Viksit Bharat”. The focus on fiscal consolidation, specially after Key Policy Announcements 04
the pressures created by the pandemic, and the nine priorities, as
listed out, will hopefully lead to sustained and equitable Fiscal and Economic Overview 07
growth.”

Direct Tax Proposals 08

CA. SANJEEVA NARAYAN, MANAGING PARTNER

Indirect Tax Proposals 13

“The subtle modifications in the rates of customs duty reflect the Sectoral Analysis 15
needs of the Indian economy. The focus on making the
administration of GST Department more user‐friendly with a
robust technological backbone will lead to better compliance. Contact Us 19
Hopefully the appellate mechanism will see the light of the day
in the near future.”

CA. ADITYA KUMAR, CEO & PARTNER

This publication is intended as a service to clients and to provide clients with the details of the Budget proposals for the year
2024‐2025. It has been prepared for general guidance on matters of interest only, and does not constitute professional advice.
No person should act upon the information contained in this publication without obtaining specific professional advice.
Further information and assistance may be obtained from any of the offices listed in the publication. No representation or
warranty (express or implied) is given as to the accuracy or completeness of the information contained in this publication, and,
Ashwani & Associates, its members, employees and agents accept no liability, and disclaim all responsibility, for the
consequences of any person acting, or refraining to act, in reliance on the information contained in this publication or for any
decision based on it.
© 2024 Ashwani & Associates. All rights reserved.
For Private Circulation Only
 the tinkering of the rates and efforts towards reduced those relating to assessment/reassessment, taxation
scenario as also a reflection of the economic needs the
litigation by decriminalizing certain delays and of charitable organizations and the renewed thrust
focus is on nine priorities viz. productivity and
defaults. The increase in the limits of filing appeals towards simplification is likely to embellish the user‐
resilience in agriculture, employment and skilling,
before higher appellate authorities, and the intention friendly face of the department with resultant positive
inclusive human resource development and social
to introduce another “Vivad Se Vishwas Scheme 2024” effects on voluntary compliance by the taxpayers.
j u s t i ce , m a n u f a c t u r i n g a n d s e r v i ce s , u r b a n
will help to ease the burden on the legal system. All told a budgetary exercise which, while attempting
development , energy security infrastructure,
However, the hope for a vibrant, all‐encompassing and to synergize rational economics with sagacious
innovation, research and development and next
dynamic alternate dispute resolution mechanism politics, endeavors to propel India on a path of
generation reforms. Of course, an insightful analysis of
which could effectively reduce pending litigation, sustained economic growth and wholesome, inclusive
the fine print conveys a package delicately balancing
reduce arrears of taxes and garner substantial all round development with equity and justice as its
regional aspirations, societal balance, political
revenue has been effectively belied. The series of bulwarking focus
compulsions dovetailed into the ultimate objective of
changes on the tax administration front, including
sustained economic growth.

FOREWORD Given their political and economical significance, the

focus on agriculture, special emphasis on job creation, KEY POLICY Announcements
skilling and internships to benefit the youth and
The Economic Survey, a customary curtain raiser to the This year, the Hon'ble Finance Minister articulated having salary of up to `1 lakh per month will
support for MSMEs is bound to have an exponential
Union Budget while sounding a cautionary optimistic trigger effect in accelerating economic growth. All the pursuit of a "Viksit Bharat". It focuses on 4 be provided one‐month salary in three
note highlighted some major issues especially arising told, a Budgetary exercise pump‐primed by the aim major groups which are 'Garib' (Poor), 'Mahilayen' instalments up to `15,000.
out of climate change, geo‐political challenges and, of fiscal consolidation and wholesome inclusive growth. (Women),'Yuva' (Youth) and 'Annadata' (Farmer). b. Incentives will be provided to first‐time
course, capital intensive technologies, such as Artificial The only concern, as always being the last mile delivery
PRIORITY 1‐ PRODUCTIVITY AND RESILIENCE IN employees and their employer linked to EPFO
Intelligence (AI) as potential areas of concern. In fact, and resultant beneficial effect of the schemes to
AGRICULTURE contributions over the first 4 years of
while dealing with the challenges/threats of AI, the translate intentions into results. employment.
Chief Economic Advisor, Shri V. Anantha Nageswaran • An allocation of `1.52 lakh crore has been
very colorfully emphasized on the need to redesign the Broad fiscal direction apart, on the indirect taxes front, c. Employers creating additional employment
made for increase in productivity and
existing curricula to make them “AI compatible” and “AI the Budget seeks to iterate and rationalize custom within a salary limit of ` 1 lakh per month will
resilience in agriculture and allied sectors
employable”. Pegging the GDP growth for F/Y 2025 at a duties, with the aim, in the Finance Minister's own get reimbursement up to `3,000 per month for
words to “support domestic manufacturing, deepen • The government aims to enhance agricultural
somewhat modest 6.5% (perhaps a case of overjealous 2 years towards their EPFO contribution for
local value addition, promote export competitiveness productivity and resilience by adopting various
optimism given the somewhat higher projections of each additional employee.
the multilateral financing institutions and agencies), and simplifying taxation while keeping the interest of measures like releasing 109 new high‐yielding
the general public and consumers surmount”. and climate‐resilient crop varieties, initiating • To boost women's workforce participation by
the survey highlights the challenges that the country
1 crore farmers into natural farming, and collaborating with industries to set up working
faces and is likely to encounter as it endeavours to On the direct taxes front, the stock market perhaps
strengthening pulses and oilseeds production women hostels and creches.
realize its dream of a “Viksit Bharat”. expectedly has not taken kindly to the Finance
Minister's attempts to tinker with the regime of to achieve 'atmanirbharta'. • To announce as 4th scheme under the Prime
Encapsulating this edifying backdrop, the Union
taxation of capital gains with the slew of wide‐ranging • Financial support will be provided for shrimp Minister's package, 20 lakh youth will be
Finance Minister Smt. Nirmala Sitharaman presented a
record breaking seventh consecutive budget and in a changes with epochal ramifications coming into production, and a National Cooperation Policy skilled over a 5‐year period and 1,000
sign of the changing times, delivered a paperless immediate effect. As regards personal taxes again as will be introduced to boost the rural economy Industrial Training Institutes will be upgraded
budget using a digital tablet encased in a traditional somewhat expected, in an attempt to popularize the and employment. for the same.
red “bahi khata” shaped red pouch – symbolizing an new scheme and endeavour to move to a somewhat
• The Model Skill Loan Scheme will be revised to
exemption free personal taxation ecosystem, the new PRIORITY 2꞉ EMPLOYMENT & SKILLING
effort to synergize tradition with modern technology. facilitate loans up to ` 7.5 lakh with a
Semantics and appearances apart, the Budget regime (the “default regime”) has been sought to be • To Support employees and employers, 3 guarantee from a government promoted Fund
forecasts the fiscal deficit for FY 25 at a healthy 4.9% in made more attractive. With the ghost of the Direct
schemes under the 'Employment Linked to help 25,000 students every year.
contrast to the 5.1% forecast in the interim budget, and Taxes code having already been interminably buried,
Incentive' as part of the Prime Minister's
reflecting the focus on fiscal consolidation resolves to the promise of a time bound comprehensive review of • To help the youth loans up to ` 10 lakhs for
package will be implemented꞉
reduce the deficit to below 4.5% in the next year. the Income‐tax Act is certainly welcome. What is also higher education in domestic institutions will
welcome is the rationalization of the TDS regime with a. All persons newly entering the workforce
Perhaps in a sign of the somewhat altered political

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 interest‐free loans.
be provided to 1 lakh students every year for PRIORITY 4 ꞉ Manufacturing & Services and orderly peri‐urban development.
annual interest subvention of 3 per cent of the
• Introduced to facilitate collateral‐free term • A framework will be created for the creative • Private sector infrastructure investments will be
loan amount. fostered through viability gap funding and a
loans for MSMEs to purchase machinery and redevelopment of cities and transit‐oriented
development plans for 14 large cities. market‐based framework.
PRIORITY 3꞉ INCLUSIVE HUMAN RESOURCE equipment.
DEVELOPMENT AND SOCIAL JUSTICE • Enabling policies for rental housing markets will • Significant financial support of `11,500 crore will
• A new mechanism will ensure continued bank
be introduced. Water supply, sewage treatment, be allocated for flood control and irrigation
• An allocation of `2.66 lakh crore has been credit for MSMEs during financial stress,
and solid waste management projects will be projects across Bihar, Assam, Himachal Pradesh,
made for rural development, including backed by a government fund guarantee.
promoted for 100 large cities, including using Uttarakhand, and Sikkim. Additionally, efforts will
infrastructure. • Increased loan limit to `20 lakh for
treated water for irrigation. focus on boosting tourism by developing key
• For women‐led development, over `3 lakh entrepreneurs who successfully repay loans religious and scenic sites, including the Vishnupad
crore is allocated for schemes benefiting under the 'Tarun' category. • A scheme will support the development of 100 and Mahabodhi Temple Corridors, Rajgir, Nalanda,
women and girls. weekly street markets over five years, and states and Odisha
• Lowered turnover threshold to `250 crore to
will be encouraged to lower stamp duty, especially
• The government will invest `26,000 crore in onboard more buyers onto the TReDS platform PRIORITY 8 ꞉ INNOVATION, RESEARCH &
for properties purchased by women.
road projects, `21,400 crore in a new 2400 MW for benefiting MSME suppliers
DEVELOPMENT
power plant at Pirpainti, and construct new • SIDBI plans to establish 24 new branches this
PRIORITY 6 ꞉ ENERGY SECURITY
airports, medical colleges, and sports facilities • The government will establish the 'Anusandhan'
year to serve 168 out of 242 major MSME • The aim of PM Surya Ghar Muft Bijli Yojana to
in Bihar. National Research Fund for basic research and
clusters within 3 years. install rooftop solar plants which enables 1 crore
prototype development. Additionally, plan to set
• The government is committed to • Financial support for setting up 50 food households to obtain free electricity up to 300
up a mechanism aimed at encouraging private
comprehensive development, focusing on irradiation units and 100 quality testing labs units every month.
sector‐driven research and innovation on a
farmers, youth, women, and the poor, using a with NABL accreditation in the MSME sector. • Nuclear energy is a very significant part of the commercial scale, supported by a `1 lakh crore
saturation approach to cover all eligible energy mix for Viksit Bharat. Towards that pursuit, financing pool
• To set up in E‐Commerce Export Hubs in PPP
individuals through programs in education our government will partner with the private
mode to facilitate global market access for • A venture capital fund of ` 1,000 crores will be set
and health. sector for setting up Bharat Small Reactors,
MSMEs. up for expanding the space economy by 5 times in
• E co n o m i c s u p p o r t s c h e m e s l i k e P M research & development of Bharat Small Modular
• Reforms aimed at increasing the share of the next 10 years.
Vishwakarma, PM SVANidhi, National Reactor, and research & development of newer
Indian shipping industry and generating more PRIORITY 9 ꞉ INNOVATION, RESEARCH &
Livelihood Missions, and Stand‐Up India will technologies for nuclear energy.
employment.
be intensified for various groups. • A joint venture between NTPC and BHEL will set up
DEVELOPMENT
• Initiative for domestic production, recycling,
• The 'Purvodaya' plan will develop the eastern to develop 800 MW commercial thermal power • The government will develop an Economic Policy
and acquisition of critical minerals, with a
region, including Bihar, Jharkhand, West plant using Advanced Ultra Super Critical AUSC Framework to enhance productivity and
focus on technology and financing.
Bengal, Odisha, and Andhra Pradesh, with a technology efficiency across land, labor, capital, and
focus on human resources, infrastructure, and • Integrated Technology Platform to improve technology.
• For moving the 'hard to abate' industries from
economic opportunities. Insolvency and Bankruptcy Code outcomes.
'energy efficiency' targets to 'emission targets' and • It will support state and federal collaboration
• Grants will be given to backward regions like PRIORITY 5 ꞉ URBAN DEVELOPMENT from the current 'Perform, Achieve and Trade' mode with a focus on employment and high growth,
Rayalaseema, Prakasam, and North Coastal to 'Indian Carbon Market' mode will be put in place. using a significant portion of a 50‐year interest‐
• Under PM Awas Yojana Urban 2.0, `10 lakh
Andhra. Three crore additional houses under free loan to incentivize state reforms.
crore will be invested to address the housing PRIORITY 7 ꞉ INFRASTRUCTURE
PM Awas Yojana have been announced. • The government will advance land reforms by
needs of 1 crore urban poor and middle‐class
• The Central Government will invest `11,11,111
• The Pradhan Mantri Janjatiya Unnat Gram families, with central assistance of `2.2 lakh digitizing rural and urban land records, assigning
crore in infrastructure this year, amounting to 3.4%
Abhiyan will improve the socio‐economic crore over five years and provisions for unique IDs, and establishing IT systems for
of GDP, and maintain strong support over the next
condition of tribal communities by covering affordable loan rates. management and tax administration. These
5 years.
63,000 villages and benefiting 5 crore tribal reforms aim to improve credit access, agricultural
• The government will develop 'Cities as Growth
people. • States will be encouraged to match this services, and urban financial efficiency.
Hubs' through economic and transit planning,
investment with `1.5 lakh crore in long‐term

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 Fiscal and Economic Overview Direct Tax assessee to settle proceedings initiated in
relation to a contravention under any law for
ESTIMATED FISCAL DEFICIT Proposals
1.0%
the time being in force, as may be notified by
the Central Government in the Official Gazette
FOR 2024‑25 – 4.9% in this behalf. This amendment will be
FOR 2023‑24 – 5.9% TAX RATES applicable w.e.f AY 2025‐26.
• The tax slabs and rates of Section Deductions under section‐36
115BAC(1A)(ii) of the Act (“new regime”) by an • It is proposed to amend section 36(1)(iva) of
Individual/HUF/AOP/BOI/AJP for A.Y. 2025‐26 the Act to increase the amount of employer
For pursuit of 'Viksit Bharat' the Focus is on 4 major areas, Annadata shall be as follows꞉ contribution towards pension scheme as
(Farmer),Garib(Poor),Yuva(Youth), Mahilayen(Women). Slabs of Total Income Rate of Tax referred to in section 80CCD allowed as
Upto ` 3,00,000/‐ Nil deduction, from 10% to 14% of the salary of the
KEY ECONOMIC INDICATORS From ` 3,00,001/‐ to ` 7,00,000/‐ 5 per cent employee. This amendment will be applicable
• The Gross and Net Borrowing during FY 2024‐25 are Estimated at 14.01 Lakh Crore and 11.63 Lakh From ` 7,00,001/‐ to ` 10,00,000/‐ 10 per cent w.e.f AY 2025‐26.
crore respectively. From ` 10,00,001/‐ to `12,00,000/‐ 15 per cent
From ` 12,00,001/‐ to `15,00,000/‐ 20 per cent
• India's inflation continues to be low, stable and moving towards the 4 per cent target. Core inflation
Above `15,00,000/‐ 30 per cent SALARY
(non‐food, non‐fuel) currently is 3.1 per cent.
• Under new regime of taxation u/s 115BAC(1A)
• Overall, while revenue appears robust with rising tax and other revenues, the reduction in capital • There is no change in rates of tax for
of the Act, it is proposed to increase the limit of
receipts signals a cautious approach to borrowing and capital inflows. The significant uptick in both Individual/HUF/AOP/BOI/AJP (under old
standard deduction available in respect of
revenue and capital expenditures reflects strategic priorities in enhancing infrastructure and regime), for Co‐operative Societies, Firms,
“Income from Salaries” u/s 16(ia) from the
operational capabilities. Local Authorities and Domestic Companies.
existing limit of Rs. 50,000/‐ to Rs. 75,000/‐.
• In case of a Company other than a Domestic This amendment will be applicable w.e.f AY
Company, w.e.f. A.Y. 2025‐26, it is proposed to 2025‐26.
reduce the rate of tax from 40% to 35% on
incomes other than incomes chargeable at
special rates. HOUSE PROPERTY
BUSINESS • It is proposed to amend the section 28 of the
Act so as to clarify that any income from letting
Removal of Angel Tax on closely held companies
out of a residential house or a part of the house
• Section 56(2)(viib) provides that where a by the owner shall not be chargeable under the
closely held company, receives, in any previous head “Profits and gains of business or
year, from any person being a resident, any profession” and shall be chargeable under the
consideration for issue of shares, if the head “Income from house property”. This
consideration received for issue of shares amendment will be applicable w.e.f AY 2025‐
exceeds the face value of such shares, the 26.
aggregate consideration received for such
CAPITAL GAIN
shares exceeding such fair market value shall
be chargeable to income tax under the head • It is proposed that the holding period for STCG
“Income from other sources”. It is proposed to is ꞉
ALLOCATION TO MAJOR SCHEMES꞉
abolished the provisions of this clause w.e.f. ‐ Listed securities & Listed Business Trust –
• ` 36,785 Crore towards National Health Mission. 12 Months
A.Y. 2025‐26.
• For promoting women‐led development, the budget carries an allocation of more than 3 lakh crore for ‐ Bonds, Debentures, Gold, Unlisted Shares
Disallowance of settlement amounts being paid to
schemes benefitting women and girls. & Immovable Property – 24 months
settle contraventions
• `10 Lakh Crore towards PM Awas Yojana Urban 2.0 • It is proposed to amend the Explanation 3 of
• `15,000 Crore Andhra Pradesh Reorganization Act section 37(1) of the Act to clarify that • Following rates have been changed for
• `2.05 Lakh crore towards Pardhan Mantri Garib Kalyan Ann Yojana(PMJKAY) "expenditure incurred by an assessee for any incomes chargeable under capital gains꞉
purpose which is an offence or which is
• `86,000 Crore towards MGNREGA
prohibited by law" under Explanation 1 shall
• `12,000 Crore towards Pardhan Mantri Gram Sadak Yojana include any expenditure incurred by an

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 transfers
of shares under buy‐back will be considered as person proves that after paying TDS/ TCS
transfers before after TDS on sale of immovable property
nil. This amendment will be applicable w.e.f. along with fees and interest to the credit of the
Income 23.07.24 23.07.24 • It is proposed to amend sub‐section (2) of
01.10.2024. Central Government, he has filed the TDS/TCS
long‐term capital gains section 194‐IA of the Act to clarify that where statement before the expiry of period of one
10 % 12.5%
Deduction in respect of Family Pension
referred to in section 115E
there is more than one transferor or transferee month (earlier one year) from the time
long‐term capital gains • Under the new regime of taxation u/s
in respect of an immovable property, then prescribed for furnishing such statement.
referred to in sub‐clause (iii) Not 115BAC(1A), it is proposed to increase the
Applicable w.e.f. AY 2025‐26. This amendment
of clause (c) of sub‐ section 10 % applicable deduction available u/s 57(iia) of the Act in threshold of Rs. 50 lakhs for deducting TDS
(1) of section 112 will be applicable w.e.f. 01.10.2024.
respect of family pension to the lower Rs. shall be the aggregate of the amounts paid or
long‐term capital gains 25,000/‐ or thirty‐three and one‐third percent Reducing time limitation for orders deeming any
referred to in section 112A payable by all the transferees to the transferor person to be assessee in default
of such income. This amendment will be
exceeding one lakh twenty‐ 10 % 12.5% or all the transferor for transfer of such
applicable w.e.f AY 2025‐26. • It is proposed to amend section 201(3) and
five thousand rupees
OTHERS immovable property. insert new subsection (7A) in section 206C of
long‐term capital gains [not
being long‐ term capital This amendment will be applicable w.e.f. the Act to provide that no order shall be made
STT
gains referred to in clauses 01.10.2024. deeming any person to be assessee in default
20 % 12.5% • It is proposed to increase the said rates of
(33) and (36) of section 10] for failure to deduct/ collect the whole or any
securities transaction tax on sale of an option TDS u/s 194J
part of the tax from any person, at any time
in securities from 0.0625 per cent to 0.1 per • It is proposed that section 194C will not be
short‐term capital referred after the expiry of six years from the end of the
20 % 12.5% cent of the option premium, and on sale of a
to in section 111A applicable where TDS on any sum is already financial year in which payment is made or
futures in securities from 0.0125 per cent to
covered under section 194J(1) of the Act. credit is given or tax was collectible or two
• Exemption Limit is proposed to increase for 0.02 per cent of the price at which such
This amendment will be applicable w.e.f. years from the end of the financial year in
long‐term capital gains under section 112A “futures” are traded. This amendment will be
which the correction statement is delivered,
from Rs. 1 lakh to Rs. 1.25 lakh. applicable w.e.f. 01.10.2024. 01.10.2024.
whichever is later. This amendment will be
• It is proposed that the rates specified under Set off and withholding of refund Exemption from prosecution in case of failure to applicable w.e.f AY 2025‐26.
the provisions of section 50AA of the Act will • It is proposed to amend withholding of refund deposit TDS Ease on claiming Credit for TCS collected/TDS
apply on unlisted debentures and unlisted u/s 245 to be extended up to sixty days from • It is proposed to amend section 276B of the Act deducted by salaried employees
bonds. the date on which such assessment or to provide for exemption from prosecution to a • It is proposed to amend section 192(2B) to
• Indexation available under second proviso to reassessment is made. This amendment will
person covered under clause (a) of the said include any tax deducted or collected under
section 48 is proposed to be removed. take effect from the 1st day of October, 2024 i.e.
section, if the payment of tax deducted in the provisions of Chapter XVII‐B or Chapter
AY 2025‐26
• Sections 115AD, 115AB, 115AC, 115ACA and XVII‐BB, to be taken into account for the
TDS/TCS PROVISIONS respect of a quarter has been made to the
115E are being introduced to align the rates of purposes of making the deduction u/s 192(1).
taxation in respect of long/short term capital TDS on payment of salary, remuneration, interest, credit of the Central Government at any time
The amendment will take effect from the 1st day
gains proposed u/s 112A/112 and 111A. bonus or commission by partnership firm to on or before the time prescribed for filing the of October, 2024 w.e.f. AY 2025‐26
These amendments will take effect from the 23rd of partners quarterly return. This amendment will be Increase in Interest Rate for delay in deposit of TCS
July, 2024 w.e.f. AY 2025‐26 • It is proposed to insert new section 194T to applicable w.e.f. 01.10.2024. • It is proposed to increase simple interest for
INCOME FROM OTHER SOURCES provide TDS on payments such as salary, Time limit for correction statement/ revision of non‐payment of TCS u/s 206C(7) from 1% to
remuneration, commission, bonus and interest
Buy Back of shares TDS return 1.5%. The amendment will take effect from the
to any account (including capital account) of
• It is proposed that the sum paid by a domestic • It is proposed to amend section 200 and 1st day of April, 2025 w.e.f. AY 2025‐26
the partner of the firm for aggregate amounts
company for purchase of its own shares shall section 206C(3B) to provide that no correction Increase in limit of remuneration to working
more than Rs 20,000 in the financial year.
be treated as dividend in the hands of partners of a firm allowed as Deduction
Applicable TDS rate will be 10%. This statement shall be filed after the expiry of six
shareholders, who received payment from The amendment will take effect from the 1st day of April,
amendment will be applicable w.e.f AY 2025‐ years from the end of the financial year in
such buy‐back of shares and shall be charged 2025 w.e.f. AY 2025‐26
26.
to income‐tax at applicable rates. No which the statement were originally filed. This
TCS on Luxury Goods
deduction for expenses shall be available amendment will be applicable w.e.f AY 2025‐ on the first Rs. 6,00,000 Rs. 3,00,000 or at the rate
a g a i n s t s u c h d i v i d e n d i n co m e w h i l e • It is proposed to amend sub‐section (1F) of of the book‐profit or in of 90 per cent of the book
26.
determining the income from other sources. section 206C to also levy TCS on any other case of a loss profit, whichever is more;
goods (in nature of luxury goods) of value No Penalty for failure to furnish statements /
• The cost of acquisition of original shares which
exceeding ten lakh rupees, as may be notified returns on the balance of the at the rate of 60 per cent
have been bought back would generate capital
by the Central Government in this behalf. • It is proposed to amend section 271H(3) to book‐profit
loss in hands of shareholder as deeming value
The amendment will be applicable w.e.f AY25‐26. provide that no penalty shall be levied if the
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SEARCH & SEIZURE of seized material to the Assessing Officer. cases where return of income is furnished in
trusts, funds or institutions would continue
Introduction of block assessment provisions – u/s consequence of an order under section
(viii) Approval ‐ The notice 158BC(1)(a) to get the benefit of exemption, till the
132 and requisition under section 132A 119(2)(b) (i.e Condonation of delay for late
requiring the searched assessee to furnish validity of the said approval. Further, eligible
filing of return) may be completed within
• It is proposed to amend the provisions of Chapter return of income and the order of assessment for registration under section 12A.
twelve months from the end of the financial
XIV‐B of the Act꞉ for the block period shall be issued/passed, • I t i s p r o p o s e d t h a t t h e Pr i n c i p a l
year in which such return is furnished. This
(i) Where on or after the 1st day of September, with the previous approval of Additional Commissioner/Commissioner may be
amendment will be applicable w.e.f.
2024, a search is initiated under section 132, or Commissioner/Director or Joint enabled to condone the delay in filing
01.10.2024.
requisitioned u/s 132A, the income will be Commissioner/Director. application after considering a reasonable
VIVAD SE VISHVAS SCHEME, 2024
assessed or reassessed in accordance with the (ix) The provisions of section 144C of the Act cause for the same.
provisions of the said Chapter. shall not apply to any proceeding under the It is proposed to introduce Direct Tax Vivad se
• It is proposed to rationalise timelines for
said Chapter. Vishwas Scheme, 2024 with the objective of
(ii) The 'block period' shall consist of previous disposing applications for fur ther
providing a mechanism of settlement of
years relevant to six assessment years preceding These amendments will take effect from the 1st day of registration/ approval u/s 12AB or 80G, shall
disputed issues, thereby reducing litigation
the previous year in which the search was September, 2024 i.e. AY 2025‐26. be before the expiry of the period of six
without much cost to the exchequer. This
initiated shall include the period from the 1st of REASSESSMENT PROCEEDINGS months from the end of the quarter in which
scheme is similar to erstwhile Vivad Se
April of the previous year ending on the date of the application was received.
The salient features of the proposed amendments Vishvas Scheme and a more detailed paper
the execution of the last of the authorisations These amendments will take effect from the 1st day
are as follows꞉‐ will be shared on this separately.
for search/requisition. of October, 2024 i.e. w.e.f. AY 2025‐26
• Information received from survey ‐ Any APPELLATE PROCEEDINGS
(iii) Regular assessments for the block period
information emanating from survey conducted Power of CIT(Appeals)
shall abate and one consolidated assessment
under section 133A, other than under sub‐ • It is proposed to amend sub‐section (7) of
for the block period. Till block assessment is • It is proposed that the cases where
section (2A), it is proposed to be an section 11 of the Act to include reference of
complete, no further assessment/reassessment assessment order was passed as best
'information' with the Assessing Officer for clause (23EA), clause (23ED) and clause (46B)
proceeding shall take place for the period. judgement case under section 144 of the Act,
consideration as escaped assessment. of section 10 of the Act, to enable trusts u/s
(iv) The assessment in respect of any other Commissioner (Appeals) shall be empowered
• Where information has been received under 11 to 13 to claim exemption under the
person shall be governed by the provisions of to set aside the assessment and refer the case
the scheme notified u/s 135A, no notice u/s above‐noted specific clauses of section 10.
section 158BD, if AO is satisfied that any back to the Assessing Officer for making a
148 shall be issued without prior approval of fresh assessment. This amendment will be • A new section 12AC is proposed to be
undisclosed income belongs to or pertains to or
the specified authority. applicable w.e.f. 01.10.2024. inserted for Merger of trusts and it shall not
relates to any person, other than the person
• It is proposed to amend the time limit u/s 149 attract provisions of Chapter XII‐EB relating
searched or any assets were requisitioned, then Appeals to Appellate Tribunal
of the Act ‐ to tax on accreted income in certain
any such information seized or requisitioned. • It is proposed to include u/s 253(1)(a), penalty circumstances.
Then the same shall be handed over to AO ‐ Where the income escaping assessment is orders u/s 158BFA passed by Commissioner
having jurisdiction over such other person and less than fifty lakh rupees ‐ no notice under These amendments will take effect from the 1st day
(Appeals) for filing appeals before Income Tax
shall proceed under section 158BC. section 148 shall be issued if three years and of April, 2025 w.e.f. AY 2026‐27
Appellate Tribunal.
(v) The tax rate will be sixty per cent for the block three months have elapsed from the end of
• It is proposed to consider two months period
period and no interest or penalty under section the relevant assessment year. DEDUCTIONS UNDER CHAPTER VI‐A
to file appeal before ITAT from the end of the
270A shall be levied or imposed. ‐ In Other cases ‐ not beyond the period of month in which the order sought to be Deduction in respect of Contribution to pension
(vi) Penalty on the undisclosed income of the five years and three months. appealed against is communicated. scheme referred to in section 80CCD
block period ‐ 50% of the tax payable and no • It is proposed to amend the specified authority These amendments will take effect from the 1st day Under the new regime of taxation u/s
such penalty shall be levied if disclosed and tax granting approval u/s 151 of the Act which of October, 2024 i.e. AY 2025‐26 115BAC(1A), w.e.f. it is proposed to amend sub‐
paid along with the return. now be Additional Commissioner / Director or section (2) of section 80CCD of the Act, to
CHARITABLE TRUSTS.
(vii) The time‐limit for completion of block Joint Commissioner / Director. provide that where any contribution has been
Rationalisation of provisions of Charitable Trust
assessment ‐ 12 months from the end of the These amendments will take effect from the 1st day of made by any other employer (not being Central
and Institutions
month in which the last of the authorisations for September, 2024. i.e. AY 2025‐26. Government or State Government), the
• It is proposed to merge trusts under sub employee shall be allowed as a deduction an
search or requisition was executed or made.
sections of 10(23C) with Section 11 to 13꞉ amount not exceeding 14% of the employee's
In case of person other than searched ‐ 12 Time limit for completion of assessment,
• No applications for provisional approval salary. This amendment will be applicable w.e.f AY
months from the end of the month in which the reassessment and recomputation
under sub sections of 10(23C) shall be 2025‐26.
notice u/s 158BC was issued. However, an • It is proposed to insert a new sub‐section (1B) considered on or after 1.10.2024. Approved
exclusion of nearly six months shall be available to section 153 in relation to time limit for
from date of search to the date of handing over completion of assessment u/s 143/144 of

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 • Restricting applicability of penal provisions on E‐ limit for filing appeals before appellate
Indirect Tax Proposals • Conditional waiver of interest and penalty for
demand notices under section 73 for all
commerce operators. tribunal has been revised with effect from
Presidial Changes in working of Appellate Tribunal꞉ 1st August 2024.
financial years till 2019‐20 [Section 128A]
Amendment to Section 171 has been done to notify Updating Negative List꞉ Section 17 has
• Various sections amended to incorporate a
GSTAT to handle anti‐profiteering cases and to been amended to restrict availability of ITC
reference to the proposed new section 74A in
provide sun‐set clause for accepting anti‐profiteering for tax demands paid under section 74
the said section.
case. Additionally, due to non‐constitution of GSTAT upto FY 2023‐24.
Prescribing Time of Supply for RCM, answering
and to avoid appeals from getting time barred, time
some unsolved questions꞉ Simultaneous
TARIFF RATE CHANGES ‐ INCREASE W.E.F. 24.07.2024
amendment has been made in section 31 and 13 to
Now (%) Proposed (%)
empower CG to prescribe;
FM charting the course for transforming India into • The time period for issuance of invoice and by Poly vinyl chloride (PVC) flex films 10 25
“VIKSIT BHARAT” by 2047 made announcements the recipient
relating to simplification and overhaul Indirect Tax • Time of supply of services in case of supplies Laboratory Chemicals 10 25
structure. As regards, amendments in the GST Act subject to reverse charge. TARIFF RATE CHANGES (without change in effective rate) W.E.F. 01.10.2024
2017, some eagerly anticipated changes in the Restricting Refunds꞉ Simultaneous insertion in
Finance Bill 2024 are as follows꞉ Section 54 of CGST Act and Section 16 of IGST Act Other roasted nuts and seeds, including such arecanuts 30 150
GST has been proposed to prohibit refund on zero rated Other nuts, otherwise prepared or preserved, including such arecanuts 30 150
Carry Forward of ITC an old saga꞉ Sub‐Section 5 is supplies of goods, where such goods are subjected
to export duty. AMENDMENTS IN THE BASIC CUSTOM DUTY RATES W.E.F. 24.07.2024
being inserted in Section 16 of CGST Act 2017,
carving out the provisions mentioned in 16(4) to Bringing Clarity to Insurance Sector꞉ Schedule 3 Ammonium Nitrate, whether or not 7.5 10
has been updated through insertion of para 8 and 9 in aqueous solution
retrospectively provide the due date to claim ITC
pertaining to FY 2017‐18, 2018‐19, 2019‐20 and to declare the following as neither supply of goods Cancer Drugs‐
‐ Trastuzumab Deruxtecan, 10 Nil
2020‐21, till 30th Nov'2021. Additionally, time or services ‐ Osimertinib,
limits for availment of credit in cases of revocation ‐ Durvalumab
• Activity of apportionment of co‐insurance
of cancelled registration have also been premium by lead insurer to co‐insurer. X‐ray tubes for use in manufacture of X‐ray machines for medical, 15% 5/7.5/10
prescribed. surgical, dental or veterinary use.
• Services by insurer to reinsurer for which *5% (till 31st March 2025)
New Assessment Provisions with New Mindset꞉ 7.5% (w.e.f 1st April,2025 to 31stMarch, 2026)
ceding commission is deducted. 10% (w.e.f 1st April,2026)
Sunset of Section 73 and 74 of the CGST Act 2017
Administrative Provisions꞉ Cellular mobile phone 20 15
has been decided to apply till FY 2023‐24 and New
Section 74A is being inserted to provide for • New Sub‐section 11A has been inserted in
Charger/Adapter of cellular mobile 20 15
determination of tax irrespective of whether CGST Act, to empower the Government to Phone
regularise to non‐ levy or short‐levy of Central Printed Circuit Board Assembly
charges of fraud and alike are invoked or not. Key (PCBA) of cellular mobile phone 20 15
Features of the section are as follows꞉ Tax due to any general practice prevalent in
Specified parts for use in
trade. manufacture of connector 7.5/5 Ni
• Common time limit for issuance of demand
notices and orders i.e. 42 months from due date • Removal of extra neutral alcohol from the Goods under S. No. 404 of Notification No. 50/2017 As Applicable Nil
purview of GST. Customs, used for petroleum exploration operations
of annual return.
• Higher penalty for cases involving fraud or • Mandatory filing of monthly returns by TDS Finished leather as defined by Nil Nil
DGFT finished leather norms
wilful mis‐statement. Deductors
Raw fur skins 60/10 40
• Penalty shall be redetermined where it is • Retrospective amendment to enable availment
of transitional credit of CENVAT received by Tanned or dressed furn 60 20
proven that it is no longer in case of fraud
[Section 75(2A)] ISD.

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SECTORAL ANALYSIS AUTOMOTIVE AND MANUFACTURING
The government is proposing to implement several key measures to
INFRASTRUCTURE boost the manufacturing and service sectors which include the
An economy's infrastructure is pivotal in propelling its progress Internship in Top Companies, as part of the Prime Minister’s
and setting the stage for its future development possibilities.
Comprehensive scheme, comprehensive internship scheme will be
Infrastructure development is crucial to achieve the India 2047
vision for a $ 40 trillion economy and be reclassified from a launched. This will result in increasing opportunities for
developing economy to a developed economy. Vide this budget employment. Additionally, the government proposes to develop
the government will endeavour to maintain strong fiscal support investment‐ready “plug and play” industrial parks with full
for infrastructure over the next 5 years. This year, the government infrastructure in or near 100 cities, partnering with states and the
has provided `11,11,111 crores for capital expenditure which private sector, by better using town planning schemes and will
would be 3.4 per cent of Nation's GDP. To achieve this vision, the
sanction 12 more parks under the National Industrial Corridor
government has proposed various initiatives including the set up
a venture capital fund of ` 1000 crore for the space economy. Development Programme. These schemes in the different areas of infrastructure will indirectly boost the
Considering the last few years of, Bihar being the epi‐center of construction sector in our country. The Indian shipping industry reforms in ownership, leasing, and flagging
floods many of which are originating from countries such as Nepal, Bengal etc., the government plans to will enhance the competitiveness of and create more employment opportunities. The government plans to
build control structures in Nepal and aims to provide fiscal support of `11,500 crores through projects. extend the export period for repaired imported goods to one year and increase the re‐import time for
The government has also introduced ‐PM SURYA MUFT BIJLI GHAR YOJANA to install rooftop solar plants warranty repairs to five years. To boost domestic manufacturing and promote local value addition, Budget
to enable 1 crore households to obtain free electricity up to 300 units every month. This scheme has
2024‐25 has proposed reduction or withdrawal of customs duties on a slew of items including gold & silver,
generated remarkable response with more than 1.28 crore registrations and 14 lakh applications. The
government has allocated ` 1 trillion for the above purpose mobile phones & chargers, medicines & medical equipment, critical minerals and inputs for leather &
Impact꞉ As a result of aforesaid inter‐connectivity of roads, a substantial boost to the employment and textiles industry. Withdrawal of exemptions or increase in customs duties have also been announced for
industrial growth will be ensured. With the increased focus on Research & development of nuclear some sectors such as chemicals and telecom equipment to incentivise domestic manufacturing in our
energy, it is a big step towards Net Zero Emission by 2070. Along with that it recognises the need for country. Also, the PLI allocation for auto & components sector having increased from `484 crores to ` 3500
equatorial development of the economy and development of newer technologies. crores will provide a positive outlook to the sector.

BANKING AND FINANCIAL SECTOR

AGRICULTURE & RURAL The Financial and Banking Sector stands as the bedrock of the
Indian Economy in facilitating economic growth and safeguarding
The Hon'ble Finance Minister, Nirmala Sitharaman, has unveiled a
comprehensive plan for a major upgrade in the agriculture sector. In Budget individual & Corporate assets. Key analysis of budget for such a
2024, nine key priorities were outlined, with a focus on Productivity & crucial sector are as follows.
Resilience in Agriculture. A substantial allocation of `1.52 lakh crore has In order to promote MSME's entrepreneurship individuals can start
been made for agriculture and allied sectors, and `2.66 lakh crore for rural businesses with lower capital investment which promotes
development, including infrastructure.The initiatives include Phase IV of innovation & creativity in the economy. This budget provides
the Pradhan Mantri Gram Sadak Yojana (PMGSY) to provide all‐weather special attention to MSMEs with respect to financing, regulatory
connectivity to 25,000 rural habitations, which could enhance crop changes, and technological support, to help them grow and
transport and reduce costs. It is assumed that PMGSY will trigger an 8%
compete globally in the following ways꞉
increase in the share of crops transported to markets for sale, tripling the
1. Provision of Collateral free loan to purchase of Capital equipment
average share of crops sold in the market. Land‐related reforms will
improve land administration and urban planning, reducing inequalities in up to Rs.100 crore.
rural India. These will be incentivized for completion within the next 3 years through appropriate fiscal support. The 2.MSME Credit capability will be in‐house assessed by Public Sector banks.
Pradhan Mantri Awas Yojana is set to construct an additional 3 crore houses. This step will not only lead to a surge in 3. Providing bank credit to MSMEs during their stress period and to avoid getting them into the NPA stage.
demand for affordable homes but will also bring cash flows to the real estate industry. More liquidity will give a boost 4. Helping to unlock working capital by converting their trade receivables into cash threshold limit of
to the construction and the allied sectors such as steel and housing materials and will generate multiple job turnover will be reduced to `250 crores from `500 crores.
opportunities. The Pradhan Mantri Janjatiya Unnat Gram Abhiyan aims to improve tribal communities' socio‐economic Additionally, A provision of 1.5 lakh crore for long‐term interest free loans has been made this year to
conditions by benefiting 5 crore people in 63,000 villages. It is crucial to focus on creating livelihood opportunities
support the states in their resource allocation to encourage states to provide support for infrastructure,
and ensuring that their skills and craftsmanship are preserved and promoted. Digital Public Infrastructure (DPI) for
Agriculture will support data‐driven farming and efficient resource allocation, with digital crop surveys and further, subject to their development priorities and the limit of Mudra loans will be enhanced to ` 20 lakh from
the issuance of Jan Samarth based Kisan Credit Cards will be enabled in 5 states. Natural farming will be promoted the current limit of ` 10 lakh for those entrepreneurs who have successfully repaid previous loans under
among 1 crore farmers, encouraging low‐cost, eco‐friendly practices. A strategy for self‐sufficiency in pulses and the 'Tarun' category which will further help them to grow their business. Further, the budget proposed to
oilseeds is being developed to strengthen production and marketing. Large‐scale clusters for vegetable production increase securities transaction tax (STT) on the trading of derivatives on stock exchanges and increased
will improve supply chains and ensure fair prices for farmers. Finally, the National Cooperation Policy will foster the the LTCG/STCG which may seem like a dampner for the long term investor
growth of the cooperative sector, accelerating rural economic growth and creating employment opportunities.
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 HEALTHCARE
“At we strive with an ever‐increasing desire to fulfill the needs of our clients
According to global healthcare security index 2021 India is
ranked 66 out of 195 countries. Therefore, to improve this where quality counts. For us, quality is synonymous with aiming to embody the highest entry
position, government has allocated `89,287 crore for developing,
maintaining and improving the country's healthcare system and standards of professional excellence in everything we aspire to do. provides a
`2,143 crore for PLI for the pharmaceutical industry. "Cancer is
only going to be a chapter of your life not the whole story" to turn range of Tax & Regulatory, Assurance & Audit and Management Consultancy services to individual
this into reality three cancer drugs have been exempted from
custom duty by FM. Additionally, the FM proposed changes to the and corporate clients, both locally and internationally. With offices in Ludhiana, New Delhi, Mumbai
basic customs duty for X‐ray tubes and flat panel detectors used in
Chandigarh, UAE and affiliates all over the country and outside the country through its co‐
medical X‐ray machines. The government will operationalize the
Anusandhan National Research Fund for basic research and prototype development and will also set up a operation partner Geneva Group International.
mechanism for spurring private sector‐driven research and innovation at commercial scale with a
financing pool of `1 lakh crore in line with the announcement in the interim budget. Allocation for
biotechnology research and development was increased from `500 crore in 2023‐24 to `1,100 crore in
2024‐25.Normally, medicines attract a BCD of 10%, while some life‐saving drugs or vaccines attract a
concessional rate of 5%, or are completely exempt from duties. Thus, it is a major step towards availability
of Heath facilities to all sectors of the economy. Also, there has been a significant hike in the budget of
Ayush ministry by 23.74%. this boost acknowledges the importance of integrating traditional medicine
systems like ayurveda, yoga and homeopathy into mainstream healthcare.

EDUCATION
The initiatives outlined in the budget regarding education and skill
development are poised to have a multifaceted impact on the sector in
India. Firstly, the provision of education loans up to 10 lakh for students who
do not qualify for existing government schemes addresses a critical gap in
financial assistance. By offering e‐vouchers with an annual interest
subvention of 3%, the government aims to make higher education more
accessible and affordable, thereby potentially increasing enrolment rates in
domestic institutions. This financial support directly targets students who
might otherwise struggle to finance their education independently, thereby
levelling the playing field and promoting inclusivity in higher education.
Secondly, the internship program facilitated by India’s top companies is
designed to enhance youth employability through practical training
experiences. By focusing on individuals aged 21‐24 who are not employed or in full‐time education, the program aligns
with industry needs, bridging the gap between academia and employment. Moreover, the cost‐sharing model, where
the government and companies contribute towards allowances and training costs respectively from CSR funds,
encourages private sector involvement in skill development. This collaboration not only reduces financial burdens on
interns but also ensures that training is aligned with industry standards and needs, enhancing the employability of
participants. For internship in top companies, there is emphasis in giving opportunities to class of students who cannot
afford/reach these organisations. In conclusion, these initiatives are poised to have a transformative impact on the
education sector by expanding access to higher education, enhancing employability through practical training, and
fostering collaboration between government, industry, and educational institutions. They signify a proactive approach
towards bridging the gap between education and employment, ultimately contributing to a more skilled and
competitive workforce in India.

For more details on the impact on your industry, please feel free to email us at

[email protected]

or you can connect with us at

twitter.com/ashwaniassociat

https꞉//www.linkedin.com/company/ashwani‐&‐associates

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