Ghaziabad Chapter of NIRC of ICSI ICSI-NIRC …...GHAZIABAD CHAPTER E-NEWSLETTER Page 64 AIFS, WHERE RTAHAVE NOT BEEN APPOINTEDSO FAR, SHALL APPOINT RTA, AT THE EARLIEST, BUTNOTLATER

Ghaziabad Chapter of NIRCof ICSI

ICSI-NIRC Ghaziabad Chaptere-Newsletter

JULY 2020

GHAZIABAD CHAPTER E-NEWSLETTER Page 01

Ghaziabad ChapterOf NIRC Of ICSI

ChairmanCS Arjunn Kumar

TyagiVice Chairperson

CS Sonal JainSecretary

CS Pooja BhasinMembers

CS Charu GuptaCS Aarti Jain

CS Sakshi MittalCS Nimisha Madan

Editors for this issueCS Arjunn Kr. Tyagi

CS Pooja Bhasin

Ghaziabad Chapter of NIRC of ICSI,

B-23, Nehru Apartment, Nehru Nagar,

Ghaziabad – 201 001Tel: 0120-4559681

Email ID: [email protected]

Chapter Office StaffMr. Vinay Kumar

Mr. Anil UpadhyayMr. Rahul Verma

From the Desk of the Chairperson,Ghaziabad Chapter of NIRC of ICSI

The person can become

whatever, if he reflects on the

desired object with confidence.

― Bhagavad Gita

Dear Readers,

I hope this newsletter receives

you in good health of you and

your family. My biggest gratitude

goes to the team of Ghaziabad

Chapter of NIRC of ICSI for

believing and having faith on me. I

pay my sincere gratitude to the

entire team of Ghaziabad Chapter

for the hard work and dedication

they have shown in this difficult

time of global pandemic for

efficient working of chapter.

It is a matter of great pleasure

and satisfaction that our chapter

has took initiatives towards

conducting member student

interaction by digital means and

have conducted meetings through

video conference and seminars

through webinars. We have put

our sincere efforts to keep both

members and students updated

and have selected topics which

will help members especially the

young members to cope with this

pandemic effectively on

professional front and bring

changes in their professional lives

to meet the emerging challenges.

“To succeed in your mission, you

must have single-minded

devotion to your goal.”

-A. P. J. Abdul Kalam

JULY 2020

**********************


Our chapter also conducted webinars on regular

basis during the month. Webinars in topics such as

Reinventing the Profession after Lockdown by CS

Richa Sharma, Decriminalizing of offences by CS

Deepak Sharma etc were conducted which were

found useful by the members.

As we all know July of every year is celebrated as

Students Month, keeping this in mind we have

conducted various activities viz. Essay writing

competition, quizzes, webinars on topics of

students interest, felicitation of students securing

good marks in previous examination etc. were

conducted by the Chapter. Students took keen

interest and actively participated with full zeal in

these activities, we strive to continue such

activities in future as well.

.“The highest result of education is tolerance”. -

Hellen Keller

Lastly will like to extend my wishes to all the

students taking CSEET examination in August

2020.

Happy ReadingYours Sincerely,

CS Arjunn Tyagi, ChairpersonGhaziabad Chapter of NIRC of ICSI

JULY 2020


Ghaziabad chapter management committee express its gratitude towards CORONA WARRIORS - DIL SE THANK YOU

S. No Particulars Page No.1. Chairperson’s Message 012. Past Events Photographs 042. Members & Students Corner

(i) Covid-19: Right Time To Buy Dream Home By CS Suman Goyal 12(ii) Compounding Under FEMA by CS Mohit Singh Kharayat 15(iii) Corporate Social Responsibility(CSR)- Post Amendments & In

Pandemic(covid-19) Scenario by CS Kamal Nath Thakur 19(iv) What Taxes Shall You Pay For The Financial Year 2019-20?

by CS Ujjwal Jindal 21(v) Stamp Duty On Transfer Of Shares In Dematerialized Form

by CS Ravi Garg 323. Corporate Compliance Calendar by CS Lalit Rajput 354. Future Events of Ghaziabad Chapter of NIRC of ICSI 745. Rules for the Articles of e-Newsletter 756. Health Initiatives 76

INDEX


Webinar organized by Ghaziabad Chapter of NIRC of ICSI on “Reinventing the Profession after Lockdown” on July 15, 2020

JULY 2020


Webinar organized by Ghaziabad Chapter of NIRC of ICSI on “De criminalising of Offences” on July 30, 2020

JULY 2020


Ghaziabad Chapter of NIRC of ICSI celebrated Student Month and organized various activities during July, 2020

JULY 2020



JULY 2020

CS Suman GoyalPracticing Company Secretary

COVID-19: RIGHT TIME TO BUY DREAM HOME

JULY 2020

Covid-19 pandemic has dipped the Indian economyon very high and few sectors like Tourism, Banking,Real Estate are in danger zone. However, theGovernment and RBI has come out with variousperquisites for Homebuyers to boost the RealEstate and Banking Sector like:

• Reduction in CRR and SLR, which has caused toreduce the bank loan interest rate; and

• Extension in the Pradhan Mantri Awas Yojana(PMAY) for MIG-I and II categories peoples.

Now, the Homebuyers have four reasons to buytheir dream home:

1. HOME LOAN RELIEF: Without talking toomuch, let’s try to understand with thefollowing examples:

HDFC Bank


Bank home loan interest rate has reduced

Last date of PMAY for MIG category increased upto March, 2021

Attractive GST rate

Various income tax reliefs under the Income Tax Act, 1961

Interest @

8.05%

(before

lockdown)

Current interest @

6.95%

(due to Covid)

Loan

amount

Rs. 25 Lakhs Rs. 25 Lakhs

Duration 20 Years 20 YearsMonthly

EMI

Rs. 20,987 Rs. 19,308

Total savings in monthly EMI: Rs. 1,679/-

Total savings in EMI (yearly): Rs. 1,679 * 12 = Rs.

20,148/-

State Bank of India

Interest @

7.95%

(before

lockdown)

Current interest

@ 6.95%

(due to Covid)

Loan

amount

Rs. 25 Lakhs Rs. 25 Lakhs

Duration 20 Years 20 YearsMonthly

EMI

Rs. 20,833 Rs. 19,308

Total saving in monthly EMI: Rs. 1,525/-

Total savings in EMI (yearly): Rs. 1,525 * 12 =

Rs. 18,300/-

Note: Interest rate has taken out from therespective bank website.

JULY 2020


2. PMAY RELIEF: “Housing for All” Mission toprovide central assistance in the form ofinterest subsidy on housing loans foracquisition/ construction of houses forEconomically Weaker Section (EWS), LowerIncome Group (LIG) and Middle Income Group(MIG). Previously, last date for MIG Categorywas 31st March, 2020. Now, the Governmenthas extended the scheme for MIG Category upto 31st March, 2021. MIG Category is dividedinto two category i.e. MIG-I and MIG-IICategory.

The key parameters for each categories are asfollows:

a) Beneficiary family should not own a puccahouse either in his/her name or in the nameof any member of his/her family in any part ofIndia.

b) Beneficiary family should not have availed ofcentral assistance under any housing schemefrom Government of India or any benefitunder any scheme in PMAY.

c) Beneficiary family will comprise husband,wife, unmarried sons and unmarrieddaughters. However, an adult earningmember and a married son or marrieddaughter shall be treated as a separatehousehold.

3. GST RATES: On the GST aspect, let’s try tounderstand the GST rates with the followingtable:

Particul

ars

EWS LIG MIG-I MIG-II

Family

Income

Rs. 0 to

Rs.

3,00,00

0

Rs.

3,00,00

1 to Rs.

6,00,00

0

Rs.

6,00,00

1 to Rs.

12,00,0

00

Rs.

12,00,0

01 to

Rs.

18,00,0

00

Max

Carpet

Area

(sq. m.)

30 60 160 200

Max

Subsidy

Rs. 2.67

lakh

Rs. 2.67

lakh

Rs. 2.35

lakh

Rs. 2.30

lakh

EXAMPLE: The borrower avails a loan for Rs. 25Lakhs and the subsidy works out to Rs. 2,35,000.The amount (Rs. 2,35,000) would be reducedupfront from the loan (i.e., the loan would reduceto Rs. 22,65,000) and the borrower would pay EMIson the reduced amount of Rs. 22,65,000.

However, the following things must be taken inmind before applying for PMAY:

Property

Type

GST rate till

March, 2019

GST rate from

April, 2019Affordable

housing*

8% with ITC 1% without ITC

Non-

affordable

housing

12% with ITC 5% without ITC

*Definition of affordable housing: Only thoseflats with the carpet area of 60 sq. m. in metroscities (i.e. Delhi-NCR, Bengaluru, Chennai,Hyderabad, Mumbai and Kolkata) and 90 sq. m. innon-metros cities falling under the Rs. 45 lakh capis affordable housing.

4. INCOME TAX ASPECTS: Interest payable onloans borrowed for the purpose of acquisitionor construction of housing property can beclaimed as deduction under section 24(b) ofthe Income Tax Act, 1961. However, totalinterest deduction cannot be more than Rs. 2lakhs.

JULY 2020


Interest on pre-construction period: Interestpayable on loan for the period prior to the previousyear in which the property has been acquired orconstructed (pre-construction period) can beclaimed as deduction over a period of 5 years inequal instalments commencing from the year ofacquisition or completion of construction.Note: ‘Pre-construction period’ is the period priorto the previous year in which property is acquiredor construction is completed.

Interest for the year in which construction iscompleted/ property acquired: Interest relating tothe year of completion of construction/ acquisitionof property can be fully claimed in that yearirrespective of the date of completion/ acquisition.

For Example: Assume interest @ 7%.

a) Pre-construction

period

2 years (2020-21

& 2021-22)

Total interest:

Rs. 1,73,116

(2020-21)

+

Rs. 1,68,817

(2021-22)

= Rs. 3,41,933

Eligible deduction u/s 24(b)a) Eligible deduction of

interest in FY 2020-21

Not eligible Nil

a) Eligible deduction of


Not eligible Nil

a) Eligible deduction of


One-fifth of

interest paid for

the pre-

construction

period

+

Interest payable

in FY 2022-23

(Maximum

deduction: Rs. 2

lakhs)

68,387 [one-

fifth of the

amount refer in

point (c)]

+

1,64,206 [total

amount refer in

point (b)]

= Rs. 2,32,593

So, eligible

deduction for

FY 2022-23:

= Rs. 2,00,000/-

Conditionsa) Loan sanctioned 2020-21 Loan: Rs. 25

lakhsa) Completion of

construction

2022-23 Interest for FY

2022-23:

= Rs. 1,64,206

**********************

CS Mohit Singh Kharayat

COMPOUNDING UNDER FEMA

JULY 2020

INTRODUCTION

As per the Black’s Law Dictionary, to“Compound” means “to settle a matter by amoney payment, in lieu of other liability.” Thismeaning clearly defines the concept ofCompounding as a mechanism that provides theoffender an opportunity to avoid prosecutionfrom the offence committed by him after payingoff monitory payment.Compounding of an offense in the context of law

means an amicable settlement for the purpose ofpreventing prosecution for an offense, however,Compounding is not an inherent right butprovided/delegated by the respective Act underwhich the offence has been committed. Thus, theperson get acquittal of the offense he hascompounded.

BASIC CONCEPTS UNDER FEMA

1. As far as Foreign Exchange Management Act,1999 (FEMA), the provisions of section 15,permit compounding of contraventions andempowers the Reserve Bank of India(RBI) tocompound any contravention as definedunder section 13 of the FEMA, exceptcontraventions under section 3 (a) of FEMA,on an application made by the personcommitting such contravention.

1. Further, where a contravention has beencompounded as above, there cannot be anyfurther proceeding, initiating or continuing, asthe case may be, in respect of thecontravention so compounded.

2. The provisions of Section 13, provides that ifany person contravenes any provision ofFEMA, or any rule, regulation, notification,direction or order issued in exercise of thepowers under this Act, or contravenes anycondition subject to which an authorization isissued by the Reserve Bank, he shall, uponadjudication, be liable to a penalty up to thricethe sum involved in such contravention, wherethe amount is quantifiable or up to RupeesTwo lakhs, where the amount is not directlyquantifiable and where the contravention is acontinuing one, further penalty which mayextend to Rupees Five thousand for every dayafter the first day during which thecontravention continues.

3. Whereas, in exercise of the powers conferredby section 46 read with sub-section (1) ofsection 15 of FEMA, the Central Governmenthad made the Foreign Exchange(Compounding Proceedings) Rules, 2000relating to compounding contraventionsunder chapter IV of FEMA in the form ofMaster Direction which were effective from03.05.2000 however, since them the Ruleshave been amended many a times and thelast updating was done on April, 04, 2019.

POWER TO COMPOUNDIf any person contravenes any provisions of FEMA except clause (a) of Section 3 of that Act then the following authorities under RBI shall have power to entertain the Compounding application on the basis of monetary limits, which are as follows:


JULY 2020

*Provided that no contravention shall becompounded unless the amount involved in suchcontravention is quantifiable.

Delegation of Powers to Regional Offices

As a measure of customer service and in order tofacilitate the operational convenience,compounding powers have been delegated to theRegional Offices of the Reserve Bank of India tocompound the following contraventions of FEMA,1999.

1. Delay in reporting inward remittancereceived for issue of shares.

2. Delay in filing form FC(GPR) after issue ofshares.

3. Delay in fining the Annual Return in respect ofthe Foreign Liabilities and Assets (FLAR).

4. Delay in issue of shares/refund of shareapplication money beyond 180 days, mode ofreceipt of funds, etc.

5. Violation of pricing guidelines for issue ofshares.

6. Issue of ineligible instruments such as non-convertible debentures, partly paid shares,shares with optionality clause, etc.

7. Issue of shares without approval of RBI orFIPB respectively, wherever required.

8. Delay in submission of form FC-TRS ontransfer of shares from Resident to Non-Resident or from Non-Resident to Resident.

9. Taking on record transfer of shares byinvestee company, in the absence of certifiedfrom FC-TRS.

10. Delay in reporting the downstreaminvestment made by an Indian entity or aninvestment vehicle in another Indian entity(which is considered as indirect foreigninvestment for the investee Indian entity interms of these regulations), to Secretariat forIndustrial Assistance, DIPP.

11. Delay in reporting receipt of amount ofconsideration for capital contribution andacquisition of profit shares by Limited LiabilityPartnerships (LLPs)/ delay in reportingdisinvestment/transfer of capital contributionor profit share between a resident and a non-resident (or vice-versa) in case of LLPs.

12. Gift of capital instruments by a personresident in India to a person resident outsideIndia without seeking prior approval of theReserve Bank of India.

PRE-REQUISITE FOR COMPOUNDING PROCESS

Following are pre-requisites those needs to beconsider before applying for Compoundingapplying with RBI:

1. No compounding of similar offence can bedone upto three years from the date on whicha similar contravention was compounded bythe applicant. However, any second orsubsequent contravention committed afterthe expiry of a period of three years from thedate on which the contravention waspreviously compounded shall be deemed tobe a first contravention.

1. Contraventions relating to any transactionwhere proper approvals or permission fromthe Government or any statutory authority


S.

No.

Monetary Limit Manager of

RBI

1 Rs. Ten Lakh or less Assistant

General

Manager

2 more than Rs. Ten Lakh but

less than Rupees Forty Lakh

Deputy

General

Manager

3 Rs. Fourty Lakh or more but

less than Rs Hundred Lakh

General

Manager

4 Rs. One Hundred Lakh or

more

Chief General

Manager

JULY 2020

2. concerned, as the case may be, have not beenobtained, such contraventions would not becompounded unless the required approvals areobtained from the concerned authorities.

3. Cases of contravention, such as, those having amoney laundering angle, national securityconcerns and/or involving seriousinfringements of the regulatory framework orwhere the contravener fails to pay the sum forwhich contravention was compounded withinthe specified period in terms of thecompounding order, then such offence shallnot be dealt by RBI rather be referred to theDirectorate of Enforcement for furtherinvestigation.

PROCEDURE OF COMPOUNDING

1. All applications in the prescribed format andother mentioned documents for compoundingto submitted along with the prescribed fee ofRs.5000/- by way of a demand draft drawn infavour of “Reserve Bank of India” and payableat the concerned Regional Office and by way ofa demand draft drawn in favor of “ReserveBank of India” and payable at Mumbai for casessubmitted to the Compounding Authority.

2. On receipt of the application for compounding,the Reserve Bank shall examine the applicationbased on the documents and submissions madein the application and assess whethercontravention is quantifiable and, if so, theamount of contravention.

3. In case the application has to be returnedwhere required approvals are not obtainedfrom the authorities concerned or in case ofincomplete application or for any other reason,the application fees of Rs.5000/- received alongwith the application will be returned.

4. Then after entertaining the Compoundingapplication will be disposed off by theauthority within 180 days from the date ofreceipt of the completed application forcompounding.

5. It is not necessary to attend the hearing if theApplicant is not able to do so, and he cansubmit his written clarifications orsubmissions to the RBI and that shall have noadverse effect on the process or onCompounding fees to be levied by the RBI.

6. *The applicants are advised to give notice of,if any, in the address/ contact details of theapplicant during the pendency of thecompounding application with Reserve Bank.

QUANTITY OF PENALTY

The RBI is guided by the provisions of section 13of FEMA, whereby it is said that the amountimposed can be up to three times the amountinvolved in the contravention. However, theamount imposed is calculated on the basis ofguidance note which was given in initial circulerA.P. (DIR Series) Circular No. 73 dated May 26,2016 and which has been updated from time totime and which is also available on the RBI’swebsite for information of general public.However, the guidance note is only for thepurpose of indicating the basis on which theamount to be imposed is derived by thecompounding authorities. The actual amountimposed may sometimes vary, depending on thecircumstances of the case taking into account thefactors which are indicative in nature:

A. the amount of gain of unfair advantage,wherever quantifiable, made as a result of thecontravention;

B. the amount of loss caused to any authority/agency/ exchequer as a result of thecontravention;


JULY 2020C. economic benefits accruing to the contravener

from delayed compliance or complianceavoided;

D. the repetitive nature of the contravention, thetrack record and/or history of non-complianceof the contravener;

E. contravener’s conduct in undertaking thetransaction and in disclosure of full facts in theapplication and submissions made during thepersonal hearing; and any other factor asconsidered relevant and appropriate.

Recent Development:

1. Public disclosure of Compounding Orders2. For disseminating the information pertaining to

compounding orders, it has been decided tohost the compounding orders passed on orafter June 1, 2016 on the Bank’s website(www.rbi.org.in). The data on the website willbe updated at monthly intervals.

2. Public disclosure of guidelines on the amountimposed during compounding

3. Now it has been decided to put the guidancenote on the Bank’s website for information ofgeneral public, which has already beendiscussed earlier and the same are live now incirculer number RBI/FED/2015-16/1 FEDMaster Direction No.4/2015-16.

CONCLUSION

Dealing with RBI has been never been an easy taskbut with the passage of time RBI has been puttinglot of efforts to bridge this connotation and now aday’s every step of RBI is in this direction. A verygood example is the consolidated Master Circularfor each subject matter, issued annually or halfyearly, whereby it complies up all the alterationsdone or circulars issued during the year, into oneso as to give the concerned persons an easyaccess and comfort while dealing with it andwhich has also served the base of this article.


**********************

CS Kamal Nath Thakur,Dy. General Manager-FinanceNTPC Ltd.

CORPORATE SOCIAL RESPONSIBILITY(CSR)- POST AMENDMENTS & IN PANDEMIC(COVID-19) SCENARIO.

❖ CSR can be defined as a Company’s sense ofresponsibility towards the community andenvironment, both ecological and social inwhich it operates.

❖ CSR is not charity or mere donations. CSR is away of conducting business, by whichcorporate entities visibly contribute to thesocial good.

❖ On 31 July 2019, the Companies (Amendment)Act 2019 (Amendment) received assent of thePresident of India. The Amendment also retainsthe ‘crackdown’ provisions on black money andshell companies. The new crackdown provisionis the revisions to the existing framework ofCorporate Social Responsibility (CSR). The CSRregime is now no longer “comply or explain”but “comply or imprisonment”. Erstwhile CSRrequirements under Section 135: Under theerstwhile framework, all companies having networth of INR 500 Crore or more, or turnoverof INR 1000 Crore or more, or net profit of INR5 Crore or more during any financial year, arerequired to constitute a CSR committee. Suchcompanies were required to develop adedicated CSR policy (giving preference to localareas where the company operates) andestablish a CSR fund equivalent to 2 percent ofthe average net profits made by the companyin 3 (three) immediately preceding financialyears. Under the Companies Act 2013(Companies Act), if the company failed to meetits CSR obligations, the reasons for notspending the CSR amounts were required to bedisclosed

❖ If there are any unspent CSR funds during afinancial year (in respect of an ongoing CSRProject), in accordance with its CSR policy, thecompany must transfer such unspent CSRfunds into a special account within a period of30 (thirty) days from the end of the financialyear. Such account, to be opened with ascheduled bank by the company, will be calledan Unspent Corporate Social ResponsibilityAccount (Unspent CSR Account) and theproceeds of the Unspent CSR Account will haveto be spent by the company towards the CSRprojects (under its CSR policy) within 3 (three)financial years from the date of such transfer. Ifthe company is unable to spend the sum in theUnspent CSR Account within the prescribedperiod of 3 (three financial years, then, suchunspent amount should be transferred to afund specified under Schedule VII of theCompanies Act (Schedule VII Fund) within 6(six) months from the end of the relevantfinancial year.

❖ Considering the spread of novel Coronavirus(COVID-19) in India, the Ministry of CorporateAffairs (MCA) has announced that spending ofCSR Funds for COVID-19 is an eligible CSRactivity of a company. The Governmentclarified that the funds spent on measures totackle the Covid-19 outbreak would beconsidered as the corporate socialresponsibility (CSR) activity of firms.

JULY 2020


JULY 2020Ineligible spending on CSR are:-

1. Contribution to CM’s/ state relief fund.

2. Payment of wages to employees.

3. Payment to casual workers during lockdown period.


Eligible CSR Expenditure Related to COVID-19 Activities are:-

1. Contribution to PM CARE Fund

2. Contribution to the State Disaster Management Authority.

3. Spending of CSR fund for Covid-19.

**********************

CS Ujjwal JindalB.Com, CA, CS

WHAT TAXES SHALL YOU PAY FOR THE FINANCIAL YEAR 2019-20? A complete tax guide for your income tax computation!

JULY 2020

In India, every year, the Finance Ministerannounces an annual Union Budget for theup-coming financial year.

According to Article 112 of the IndianConstitution, the Union Budget of a year (referredto as the annual financial statement), is astatement of the estimated receipts andexpenditure of the government for thatparticular year.

Annual Union Budget keeps the account of thegovernment's finances for the fiscal year thatruns from 1st April to 31st March.

However, during the transition period, when anew government is due to take over, an InterimBudget is presented by the outgoing governmentbefore the General Elections for Lok Sabha (heldevery five years). The term ‘interim’ meanstemporary or for the time being. The InterimBudget contains detailed documentation of everyexpense to be incurred and every rupee to beearned through taxes in the coming few monthsuntil the new government comes to power.During the transition period, the rulinggovernment needs the Parliament’s approval toextract money from the Consolidated Fund ofIndia, where the government puts all its revenue.When the election is around the corner, it isunrealistic for the ruling government to launch aregular Annual Budget. So it gets passed as anInterim Budget, consisting of full estimates of therevenue and expenditure and some policymeasures too.

An Interim Budget differs from the AnnualBudget in many ways. A Budget has two parts –the report of expenses and income in the previous

year and the proposed expenses and incomegeneration in the coming year.As for the Interim Budget, the first part will remainthe same. However, the second part will containdocumentation of only basic expenses until theelection. According to the Electoral CommissionRegulations, the current government is not allowedto introduce any major policy changes, new rules oramendments that can influence the vote banksunfairly.

The year 2019 was an election year and thereforehad an Interim Budget that was presented by Sh.Piyush Goyal before the end of PM Narendra Modi-led NDA government’s first term (2014-2019) andan Annual Budget (also known as Final Budget) thatwas presented by Sh. Nirmala Sitharaman after theModi-led NDA government received a massivemandate to form the government once again(2019-2024). On 1st February, 2020 the FinanceMinister announced Union Budget for financial year2020-2021. Everyone went busy discussing andinterpreting the new provisions that wereintroduced by the said Budget.Further, the COVID-19 breakout lead to a nation-wide lockdown for over 2 months.

All these happening made the people forget thetaxes that they were to pay for the financial year2019-2020.


http://www.financialexpress.com/tag/narendra-modi/

JULY 2020This article is focused on highlighting theprovisions of Budget 2019 based on which thepeople of India are required to pay theirrespective taxes for the previous financial yeari.e. 2019-2020.

This article will act as a ready reckoner for taxcomputation, for all the people who would befiling their income tax returns on or before 30th

day of November, 2020 (extended due date

for filing income tax return as announced by theFinance Minster on 13th May, 2020 under theSpecial Economic Atmanirbhar Bharat Package)for the financial year 2019-2020.

BUDGET 2019 AND THE FINANCE ACT, 2019

As mentioned earlier, the year 2019 was anelection year and therefore had 2 budgets i.e. theInterim Budget and the Annual or Final Budget.The amendments, additions, changes, etc. weremade by both the Budgets.

First, we would take up the amendments,additions, changes, etc. that were made by theInterim Budget, 2019.

I. INTERIM BUDGET and THE FINANCE ACT,2019

The Interim Budget gave many tax reliefs andexemptions to the small taxpayers’ i.e. middleclass, salary earners, pensioners and seniorcitizens.

Let’s discuss these provisions in detail.

1. No tax payment on total income up to Rs.5,00,000/- for individual resident taxpayers

An assessee, being an individual resident in India,whose total income does not exceed Rs.5,00,000 shall be entitled to a deduction, from theamount of income-tax on his total income, of an

amount equal to 100% of such income-tax or anamount of Rs. 12,500, whichever is less.

The government did not raise the tax-slab;however, it raised the limit of rebate of incometax under section 87A to exempt income tax ontotal income for a resident individual up to Rs.5,00,000 w.e.f. 1st April, 2020 i.e. for thefinancial year 2019-2020.

As a result, of this relief, even persons havinggross income up to Rs. 6,50,000 may not berequired to pay any income tax if they makeinvestments in provident funds, specified savings,insurance etc. In fact, with additional deductionssuch as interest on home loan up to Rs. 2,00,000,interest on education loans, National PensionScheme (NPS) contributions, medical insurance,medical expenditure on senior citizens etc.persons having even higher income will not haveto pay any tax.

It is pertinent to note that• this rebate is available to resident individuals

only and not to HUFs.• this rebate is only available when the total

income does not exceed Rs. 5,00,000

2. Standard deduction for salaried individualsraised to Rs. 50,000

For salaried taxpayers and pensioners, StandardDeduction has been raised from the current Rs.40,000 to Rs. 50,000 w.e.f. 1st April, 2020 i.e. forfinancial year 2019-2020. Thus, an additional taxbenefit on income of Rs. 10,000 has been added.

ILLUSTRATIONS ON POINT 1 & POINT 2:

FIRST: Mr. A, aged 32, earned salary income of Rs.8,25,000 for the financial year 2019-20. Hisemployer deposited Rs. 1,00,000 in PF and heinvested Rs. 50,000 in a 5 year tax saver fixeddeposit with a bank. He also paid interest on loan


JULY 2020of Rs. 1,00,000 taken for his self-occupied house.He also paid a premium for a family floater healthinsurance policy of Rs. 25,000.

What taxes shall Mr. A pay for the financial year2019-20?

SECOND: Mr. Z, aged 61, earned salary income inform of pension of Rs. 8,80,000 for the financialyear 2019-20. He also received Rs. 60,000 frominterest on FD made with SBI. He deposited Rs.1,50,000 in PPF. He also paid interest on loan ofRs. 2,10,000 taken for his self- occupied house. Healso paid a premium for a floater health insurancepolicy of Rs. 55,000 for himself and his spouse. Healso made a donation of Rs. 21,000 to the PMNation Relief Fund.

What taxes shall Mr. Z pay for the financial year2019-20?


Statement showing computation of Total Income ofMr. A and Tax payable thereon

Description Amount(Rs.)

Income under the headSalary

7,75,000

Gross Salary 8,25,000

Less: Standard Deduction 50,000*

Income under the headHouse Property

(1,00,000)

Less: Interest paid on loantaken for self-occupied house

1,00,000

Gross Total Income (GTI) 6,75,000

Less: Deductions underChapter VI-A

(1,75,000)

80C – PF contributions &deposit in 5 year FixedDeposit with a bank

1,50,000

80D – Medical InsurancePremium paid

25,000

Total Income (TI) 5,00,000

Tax payable on total income 12,500

Up to Rs. 2,50,000 NIL2,50,001 to 5,00,000 @ 5% 12,500

Less: Rebate on tax undersection 87A**

(12,500)

Add: Health and EducationCess @ 4%

NIL

Total Tax Payable NIL

Statement showing computation of Total Income ofMr. Z and Tax payable thereon0Description Amount

(Rs.)Income under the headSalary

8,30,000

Gross Salary/Pension 8,80,000Less: StandardDeduction

50,000*


(2,00,000)

Less: Interest paid onloan taken for self-occupied house

2,10,000**

Income under the headOther Sources

60,000

Interest on Fixed Depositwith SBI

60,000

Gross Total Income (GTI) 6,90,000Less: Deductions underChapter VI-A

(2,71,000)

80C – PPF contribution 1,50,00080D – Medical InsurancePremium

50,000

80G – Donations to PM-NRF

21,000

80TTB – Interest on FD 50,000***Total Income (TI) 4,19,000Tax payable on totalincome

5,950

Up to Rs. 3,00,000 NIL

*Standard deduction increased from Rs. 40,000 toRs. 50,000 by the Finance Act, 2019**Added by the Finance Act, 2019

JULY 2020


3,00,001 to 4,19,000 @5%

5,950

Less: Rebate on taxunder section 87A****

(5,950)

Add: Health andEducation Cess @ 4%

NIL


*Standard deduction increased from Rs. 40,000 toRs. 50,000 by the Finance Act, 2019**Max. interest on loan paid taken for self-occupied house that can be allowed as deductionis Rs. 2,00,000 under section 24. The balance ofRs. 10,000 is disallowed.***Max. allowance under section 80TTB is Rs.50,000.****Added by the Finance Act, 2019

THIRD: Mr. F, aged 45, earned salary income ofRs. 10,00,000 for the financial year 2019-20. Hereceived Rs. 15,000 as interest on his saving bankaccount. He deposited Rs. 1,50,000 in a 5 year FDwith post office. He also paid interest on loan ofRs. 2,50,000 taken for his self-occupied house. Healso paid a premium for a floater health insurancepolicy of Rs. 20,000 for himself and his spouse. Healso paid medical expenses for his father duringthe year of Rs. 35,000 who was not covered byany insurance policy. He also made a donation ofRs. 25,000 to the PM Nation Relief Fund. He hasalso paid interest on loan of Rs. 25,000 taken forhigher education of his son.

What taxes shall Mr. F pay for the financial year2019-20?

*Standard deduction increased from Rs. 40,000 toRs. 50,000 by the Finance Act, 2019.

Statement showing computation of Total Income of Mr. F and Tax payable thereon

Description Amount (Rs.)

Income under the headSalary

9,50,000

Gross Salary/Pension 10,00,000

Less: StandardDeduction

50,000*


(2,00,000)

Less: Interest paid onloan taken for self-occupied house

2,50,000**

Income under the headOther Sources

15,000

Interest on Saving BankAccount

15,000

Gross Total Income(GTI)

7,65,000

Less: Deductions underChapter VI-A

(2,60,000)

80C – PPF contribution 1,50,00080D – Medical InsurancePremium and Medicalexpenditure for hisFather

50,000***

80E – Interest on loanfor higher education

25,000

80G – Donations to PM-NRF

25,000

80TTA – Saving BankInterest

10,000****

Total Income (TI) 5,05,000Tax payable on totalincome

13,500

Up to Rs. 2,50,000 NIL3,00,001 to 5,00,000 @5%

12,500

5,00,001 to 5,05,000 @20%

1,000

Less: Rebate on taxunder section 87A

(NIL astotalincomeexceedsRs.5,00,000)

NIL


540

Total Tax Payable 14,040

JULY 2020


**Max. interest on loan paid taken for self-occupied house that can be allowed as deductionis Rs. 2,00,000. The balance of Rs. 50,000 isdisallowed.***Max. amount deductible under section 80D isRs. 50,000 therefore Rs. 5,000 is disallowed.****Max. allowance under section 80TTA is Rs.10,000.

3. No tax on notional rent of a second self-occupied house

Currently, income tax on notional rent is payableif one has more than one self-occupied house.Considering the difficulty of the middle classhaving to maintain families at two locations onaccount of their job, children’s education, care ofparents etc. the Interim Budget, 2019, exemptedthe levy of income tax on notional rent on asecond self-occupied house.

To give effect to this, the Finance Act, 2019amended Section 23(4) of the Act as follows:

Section 23(4): Where the property referred to insub-section (2) consists of more than [one twohouse]—a) the provisions of that sub-section shall apply

only in respect of [one two] of such houses,which the assessee may, at his option, specifyin this behalf;

b) the annual value of the house or houses,[other than the house or houses] in respect ofwhich the assessee has exercised an optionunder clause (a), shall be determined undersub-section (1) as if such house or houses hadbeen let.

4. Benefit of rollover of Capital Gains increasedfrom investment in 1 residential house to 2residential houses

The benefit of rollover of capital gains undersection 54 of the Act has been increased from

investment in 1 residential house to 2 residentialhouses for a tax payer having capital gains up toRs. 2 crore. This benefit can be availed once in alife time.Let’s understand this with an example.

Illustration: In December, 2019, Mr. Q sold his 5BHK residential house at Delhi for Rs. 3.25crores. The cost of acquisition for this house wasRs. 1.25 crores (after indexation).He bought 2 new 4 BHK residential houses atNoida in a newly developed township at a cost ofRs. 1 crore each in order to provide sufficientliving space for his expanding family.

What taxes by of capital gain will Mr. Q pay?

Extract of Statement of Total Income of Mr. Q showing computation of Income under the head

Capital Gain for financial year 2019-2020Description Amount

(Rs.)Income under the head Capital Gain

NIL

Sale Consideration 3,25,00,000

Less: Cost of Acquisition (Indexed)

1,25,00,000

Capital Gains 2,00,00,000

Less: Deduction under Section 54(Rs. 1 crore x 2 houses)

2,00,00,000

Notes:

1. This benefit cannot be availed by the assesseein any future years. This benefit is availableonce in a life time only to an assessee.

2. The capital gains shall only be up to Rs. 2crores in order to avail this benefit.

We are here done with the amendments thatwere made by the Interim Budget, 2019.

JULY 2020


Let’s now understand the amendments, changes,additions, etc. made by the Annual or FinalBudget, 2019.

II. ANNUAL/FINAL BUDGET and THE FINANCE(NO. 2) ACT, 2019

1. Tax incentive for Electric Vehicles [Section80EEB]

A new section 80EEB has been introduced by theBudget that provides for a deduction in respect ofinterest on loan taken for purchase of an electricvehicle from any financial institution up to Rs.1,50,000 subject to the following conditions:

(i) the loan has been sanctioned by a financialinstitution (incl. NBFC) during the periodbeginning on the 1st April, 2019 to 31st March,2023.(ii) the assessee does not own any other electricvehicle on the date of sanction of loan.

This has been done with a view to improveenvironment and to reduce vehicular pollution.

Where a deduction under this section is allowedfor any interest, deduction shall not be allowed inrespect of such interest under any otherprovisions of this Act.

2. Tax incentive for Affordable Housing [Section 80EEA]

A new section 80EEA has been introduced by the Budget that provides for a deduction in respect of interest up to Rs. 1,50,000 on loan taken for residential house property from any financial institution subject to the following conditions:i. loan has been sanctioned by a financial

institution during the period beginning on the 1st April, 2019 to 31st March 2020.

ii. the stamp duty value of house property does not exceed Rs. 45,00,000.

iii. assessee does not own any residential houseproperty on the date of sanction of loan.

This has been done in order to provide an impetusto the ‘Housing for all’ objective of theGovernment and to enable the home buyer tohave low-cost funds at their disposal.

Where a deduction under this section is allowedfor any interest, deduction shall not be allowed inrespect of such interest under any otherprovisions of this Act.

3. Incentives to National Pension System (NPS)subscribers

Under the existing provisions, any payment fromNPS to an assessee on closure of his account or onhis opting out of the pension scheme, to theextent it does not exceed 40% of the total amountpayable to him at the time of such closure or onhis opting out of the scheme, was exempt fromtax.

With a view to enable the pensioner to have moredisposable funds, the said exemption limit hasbeen increased from 40% to 60% of the totalamount payable to the person at the time ofclosure or his opting out of the scheme.

Further, under the existing provisions of section80CCD, in respect of any contribution by theCentral Government or any other employer to theaccount of the employee, the assessee shall beallowed a deduction in the computation of histotal income, of the whole of the amountcontributed by the Central Government or anyother employer, as does not exceed 10% of hissalary in the previous year.

In order to ensure that the Central Governmentemployees get full deduction of the enhancedcontribution, the limit has been increased from10% to 14% of the contribution made by the

JULY 2020


Central Government to the account of itsemployee.Also, to enable the Central Governmentemployees to have more options of tax savinginvestments under NPS, section 80C is amendedso as to provide that any amount paid ordeposited by a Central Government employee asa contribution to his Tier-II account of thepension scheme shall be eligible for deductionunder the said section.

4. Mandatory furnishing of return of income bycertain persons

Currently, a person (other than a company or afirm) is required to furnish the return of incomeonly if his total income exceeds the maximumamount not chargeable to tax, subject to certainexceptions. Therefore, a person entering intocertain high value transactions is not necessarilyrequired to furnish his return of income. In orderto widen and deepen the tax net, the budgetprovided that a persons who enter into certainhigh value transactions shall be mandatorilyrequired to file his return of income, if during theprevious year, he

i. has deposited an amount or aggregate of theamounts exceeding Rs. 1 crore in one ormore current account maintained with abanking company or a co-operative bank; or

ii. has incurred expenditure of an amount oraggregate of the amounts exceeding Rs.2,00,000 for himself or any other person fortravel to a foreign country; or

iii. has incurred expenditure of an amount oraggregate of the amounts exceeding Rs.1,00,000 towards consumption ofelectricity; or

iv. fulfils such other prescribed conditions, asmay be prescribed.

Further, currently, a person claiming rolloverbenefit of exemption from capital gains tax oninvestment in specified assets like house, etc., isnot required to furnish a return of income, if afterclaim of such rollover benefits, his total income isnot more than the maximum amount notchargeable to tax. The annual Budget 2019provided that a person who is claiming such

rollover benefits on investment in a house orother assets, under sections 54, 54B, 54D, 54EC,54F, 54G, 54GA and 54GB of the Act, shallnecessarily be required to furnish a return, ifbefore claim of the rollover benefits, his totalincome is more than the maximum amount notchargeable to tax.

THE TAXATION AND OTHER LAWS (RELAXATIONOF CERTAIN PROVISIONS) ORDINANCE, 2020AND N/N 35/2020

Keeping in view the challenges faced by taxpayersin meeting the compliance requirements underlockdown conditions, the Finance Minister hadannounced several relief measures relating tostatutory and regulatory compliance mattersacross sectors in view of COVID-19 outbreak on24.03.2020 vide a press release. In order to giveeffect to the announcements, the governmentbrought in an Ordinance on 31.03.2020 whichprovided for extension of various time limitsunder the Taxation and other Acts.

Again, on 24th June, 2020, the Government issueda Notification No. (N/N) 35/2020 extendingfurther , the various time limits (i.e. beyond thetime limits provided by the Ordinance) under theIncome Tax Act, 1961 and other related Acts inorder to provide further relief to the taxpayers formaking various compliances.

The salient features of the Notification are asunder:

JULY 2020


Description Implication

FURTHER EXTENSION in

the date for making

investment/deposit/pay

ment for claiming

deduction under

Chapter VIA-B

Date for making

investment/deposit/

payment for claiming

deduction under

Chapter VIA-B which

includes Section 80C

(LIC, PPF, NSC, etc.),

80D (Mediclaim, etc.),

80G (Donations), etc.

has been further

extended to 31st July,

2020.

1.

Investments/Deposits/Paym

ents can now be made up to

31.07.2020 for claiming

deduction under these

sections for financial year

2019-2020.

2. The deduction can be

availed only once for a

financial year and cannot be

taken for both the financial

years simultaneously.

For example, Mr. A can

make PPF deposit on

25.07.2020 and claim the

deduction for the same

under section 80C for F/Y

2019-2020 or for F/Y 2020-

2021. He cannot claim it for

both the years

simultaneously.


the date for claiming

deduction under Section

54 to 54GB

Date for making

investment,

construction or

purchase for claiming

roll over benefit or

deduction in respect of

capital gains under

sections 54 to 54GB of

the Act has been further

extended to

30th September, 2020.

The investment,

construction or purchase

made up to 30.09.2020 shall

be eligible for claiming

deduction from capital gains

arising during F/Y 2019-

2020.


the date for Aadhaar-

PAN linking

Extension of Aadhaar-

PAN linking date to 31st

March, 2021.

The earlier date was 30th

June, 2020.

To avoid penalty and

invalidation of PAN,

Aadhaar needs to be linked

with PAN by 31.03.2021.

EXTENSION in payment

of Self-Assessment Tax

if the tax liability is upto

Rs. 1,00,000/-

The date for payment ofself-assessment tax in thecase of a taxpayer, whoseself-assessment tax liabilityis upto Rs. 1 lakh has beenalso extended to 30thNovember, 2020.

However, it was clarified

that there shall not be any

extension in the date for the

payment of self-assessment

tax for the taxpayers having

self-assessment tax liability

exceeding Rs. 1 lakh. In this

case, the whole of the self-

assessment tax shall be

payable by the due dates

specified in the Income Tax

Act and delayed payment

would attract interest under

section 234A of the Act.

EXTENSION in the date

for furnishing TDS/TCS

statements and

issuance of TDS/TCS

certificates pertaining to

FY 2019-2020

Date of furnishing

TDS/TCS

statements/certificates

extended to 31st July,

2020 and 15th August,

2020 respectively.

The furnishing of theTDS/TCS statements andissuance of TDS/TCScertificates being theprerequisite for enabling thetaxpayers to prepare theirreturn of income for FY2019-20, the date forfurnishing of TDS/TCSstatements and issuance ofTDS/ TCS certificatespertaining to the FY 2019-20has been extended to 31stJuly, 2020 and 15th August,2020 respectively.

JULY 2020


PM CARES FUND

A special fund “Prime

Minister’s Citizen

Assistance and Relief in

Emergency Situations

Fund (PM CARES

FUND)” has been set up

for providing relief to

the persons affected

from the outbreak of

COVID-19.

The Ordinance

amended the provisions

of the Act to provide

the same tax treatment

to PM CARES Fund as

available to Prime

Minister National Relief

Fund.

1. The donations made to

the PM CARES Fund shall be

eligible for 100% deduction

under section 80G of the

Act.

2. The limit on deduction of

10% of gross income shall

also not be applicable for

donation made to PM

CARES Fund.

3. As the date for claiming

deduction under section

80G has been extended up

to 31.07.2020, the donation

made up to 31.07.2020 shall

also be eligible for

deduction from income of

F/Y 2019-2020.

Let’s discuss a very important implication of theabove extension.

In the Illustration FIRST (Section I), discussedabove, if Mr. A has a Total Income (TI) of, say, Rs.5,01,000, what taxes will Mr. A have to pay?

As per the extension provided, is there any wayby which Mr. A can still save his tax? The answeris YES!

Mr. A can save a tax of Rs. 13,208 only if his totalincome is upto Rs. 5,00,000. Thus, in order tolower his total income, Mr. A is required todonate Rs. 1,000 to PM CARES FUND or PM-Nation Relief Fund which provides 100%deduction under section 80G by 31.07.2020 (asfurther extended by N/N 35/2020 discussedabove).

By virtue of this, his tax payable would be asfollows:


12,700

Up to Rs. 2,50,000 NIL2,50,001 to 5,00,000 @5%

12,500

5,00,001 to 5,01,000 @20%

200


(NIL as totalincomeexceeds Rs.5,00,000)

NIL


12,700 x 4% 508

Total Tax Payable 13,208

Extract showing computation of Total Income of Mr.A and Tax payable thereonGross Total Income (GTI) 6,76,000Less: Deductions underChapter VI-A

(1,75,000)

80C – PF contributions &deposit in 5 year FixedDeposit with a bank

1,50,000

80D – Medical InsurancePremium paid

25,000

80G – Donation to PMCares Fund

1,000


12,500

Up to Rs. 2,50,000 NIL2,50,001 to 5,00,000 @5%

12,500

5,00,001 to 5,01,000 @20%

200


(as totalincome isnow notexceedingRs.5,00,000)

12,500


12,700 x4%

NIL


JULY 2020


Thus, Mr. A would save the entire tax by makinga small donation towards a noble cause. Thus,there would be a multi-fold benefit!

Effective net saving to Mr. A would be (13,208-1,000) Rs. 12,208.The extensions announced by the Government bythe Ordinance and the Notifications shall thusprovide much relief to the taxpayers during theongoing COVID-19 pandemic.

ATMANIRBHAR BHARAT (SPEICAL ECONOMICPACKAGE) – vide Press Release dated 13th May,2020

The COVID-19 lockdown made everything non-operational. The businesses are shut, people arelocked at their homes, there is no commercialactivity and the entire world economy is at its alltime low!

Considering the above, the economic package, inorder to ease the burden of compliances onvarious stakeholders has extended the timeframe for:

1. Filing Return of Income and Tax Audit Reportfor F/Y 2019-2020 i.e. A/Y 2020-2021

2. Assessments

As the dates of filing return of income have beenextended the assessment period is extended aswell.

Description Before Now- ITR by a Company or- Where there is Auditrequirement under IncomeTax Act or any other law or- ITR by a partner of afirm whose accounts arerequired to be audited

31st

October,2020

30th

November,2020

Others31st July,2020

30th

November,2020

Filing of Tax Audit Report 30th

September, 2020

31st

October,2020

Assessments gettingbarred on

Extended to

30th September, 2020 31st December, 202031st March, 2021 30th September, 2021

Vivad se Vishwas Scheme

The scheme was introduced by the Budget 2020and came in form of an Act in March, 2020. Sinceits introduction this scheme has remained inVivads with regard to its due date.

Earlier the last date for dispute settlementbetween the taxpayer and the department,without any interest and penalty, was 31st March,2020 but as the scheme was notified late, it wasextended to 30th June, 2020.

Again, the economic package has extended thisdate to 31st December, 2020. Therefore, nowtaxpayers can settle their existing disputeswithout payment of any additional amount by 31st

December, 2020.

CONCLUSION:

With the help of this article, all individuals wouldbe able to compute their total income and thetax payable thereon for the financial year 2019-2020.

All the amendments, notifications, orders,circulars, acts, press releases, etc. notified till datehas been fully incorporated in the above article.At the time of filing your income tax returns, theprovisions highlighted in this article shall serve asa ready reckoner for computing total income andtax payable thereon for the financial year 2019-2020 for an individual.

JULY 2020All our readers are requested to kindly take noteof the following:

[For ITR-1, 2, 3 and 4]

We advise all the taxpayers to file their ITRs onlyafter 31st July, 2020 (being the extended last datefor making investments/payments/deposits inorder to claim deductions under chapter VIA-Bi.e. 80C, 80D, 80G, etc.) so that they do not missout on the last opportunity for claiming anydeduction in a hurry to file for their ITRs.

[For ITR-2 and 3]We advise all the taxpayers to file their ITRs onlyafter 30th September, 2020 (being the extendedlast date for makinginvestments/construction/purchase in order toclaim roll over benefit/deductions under section54 to 54GB, if applicable) so that they do not missout on claiming any benefit/deduction in a hurryto file for their ITRs.File your income tax returns in time to avoid lastminute rush, late fees, interest, penalties andother statutory fines.

For any queries with respect to the above articleor to get assistance with regard to income and taxcomputation or alike send us an e-mail [email protected]


**********************

mailto:[email protected]

CS Ravi Garg

STAMP DUTY ON TRANSFER OF SHARES IN DEMATERIALIZED FORM

JULY 2020


DETAILS OF THE AMENDMENT

This is to inform your that pursuant to theamendments to the Indian Stamp Act, 1899notified in The Finance Act, 2019, Ministry ofFinance (Department of Revenue) through itsnotification dated December 10, 2019 has notifiedthe Indian Stamp (Collection of stamp-dutythrough Stock Exchanges, Clearing Corporationand Depository) Rules 2019 to regulate the liabilityof the instruments of transaction in stockexchanges and depositories to duty. (Earliereffective date: 9th day of January, 2020)

Further, the Central Government (Ministry of Finance) vide notification dated March 30, 2020 has deferred the effective date of amendments in Indian Stamp Act to 01st day of July, 2020.

PURPOSE OF THE AMENDMENT

The purpose of making such amendment is tostreamline the process of levying and collection ofStamp Duty on the Instruments related to issue ortransfer of securities, by all the States throughcommon agencies i.e. Stock Exchanges or ClearingCorporations or Depositories, as the case may be.

The Amended Stamp Act and the Rules addressthe payment of stamp duty on securities. It bringsclarity with respect to modalities and obligationsin relation to payment of stamp duty, and theresponsibility of the stock exchanges anddepositories for collection of duty, while effectingsuch transactions. Furthermore, the Rules alsoprovide for the duty of the collecting agents, thatis, the stock exchanges and the depositories totransfer the duty collected to the relevant stategovernments (basis the domicile of the

transacting parties) and submit monthly returns inrespect of the duty so collected.

*Union List did not have power to specify rates of stamp duty in respect of issue of shares, the same comes under the purview of the State Legislature.

KEY UPDATES FROM THE AMENDED STAMP ACT AND THE RULES

1. Amendment in the Definitions: theAmended Stamp Act amends the existingdefinitions to align them with the definitionsprovided under other laws/act(s), such as“debenture”, “market value” and“securities”. The new definition of“securities” is extensive and has the neteffect of extending the list of instrumentsliable to stamp duty.

2. Removal of the exemption of stamp duty ontransfer of shares in dematerialized form:Prior to the amendment, transfer ofsecurities in physical form was subject to thepayment of stamp duty and transfer ofsecurities in dematerialized form wasexempted. This exemption has been remivedand stamp duty is now payable on transfer ofsecurities (with consideration) indematerialised form.

3. Stamp Duty on Commercial Papers:Commercial Papers will be stamped asDebentures.

4. Stamp Duty on principal instrument only:The existing provisions of section 4 of the Acthave been amended by including sub section(3) which is as follows:

.”

JULY 2020


“(3) Notwithstanding anything contained in sub-sections (1) and (2), in the case of any issue, saleor transfer of securities, the instrument on whichstamp-duty is chargeable under section 9A shall bethe principal instrument for the purpose of thissection and no stamp-duty shall be charged on anyother instruments relating to any suchtransaction.”

A single transaction through the stockexchange or depository often involves theexecution of several instruments (e.g., notes,memorandums, etc.). To avoid multiplicity ofpayments of stamp duty on suchtransactions, the Amended Stamp Actprovides that stamp duty is payable only onthe principal instrument. The principalinstrument for different transactions isspecified in the Amended Stamp Act. TheAmended Stamp Act clarifies that no stampduty shall be charged on any instrument(other than the principal instrument) on asingle transaction.

5. Liability for payment of stamp duty: As per the Amended Stamp Act, the persons liable to pay stamp duty in different transactions are as per the below table:

6. Revised Stamp Rates: The Finance Act hasalso amended the Schedule I of the StampAct, to change some existing duties andprovides for new duties in case oftransactions related to transfer.

Prior to the introduction of the AmendedStamp Act, stamp duty was payable at a flatrate of 0.25% of the consideration on atransfer of shares. There was no stamp dutyprescribed on the issue of shares (apart fromthe share certificate issued to theshareholder). The Amended Stamp Actspecifies the following rates of stamp duty fordifferent kinds of transactions involvingsecurities.

SN

Nature of transaction Onus

1Sale of security throughstock exchange

Buyer

2Sale of security otherwisethan through stock exchange

Seller

3Transfer of security throughdepository

Transferor

4

Transfer of securityotherwise than through astock exchange ordepository

Transferor

5Issue of security (whetherthrough a stock exchange ora depository or otherwise)

Issuer

6In case of any other instrumentnot specified in Section 29 of theIndian Stamp Act, 1899

By thepersonmaking,drawing orexecutingsuchinstrument

Sl. no.

TypeStamp duty

1 Debentures

i. Issuance of debentures 0.005%

ii.Transfer or re-issuance of debentures

0.0001%

2 Securities other than debentures

i. Issuance of securities 0.005%

ii.Transfer of securities on delivery basis

0.015%

iii.Transfer of securities on non-delivery basis

0.003%

iv. Derivatives

a. Futures (equity and commodity) 0.002%

b. Options (equity and commodity) 0.003%

c.Currency and interest rate derivatives

0.0001%

JULY 2020


1. Transactions not attracting stamp duty[Rule 6 (3)] : Creation or destruction ofsecurities on account of corporate actionsviz. Stock split, Stock consolidation andMergers and acquisition in case there is nochange in beneficial ownership will notattract stamp duty [Rule 6 (3)] subject tobelow exceptions:Change in Beneficial ownership shall be subject to stamp dutyFresh issue to investor as a part of corporate action shall be subject to stamp duty

1. Timeline for transfer of Stamp duty underSection 9A(4) to State Government: Thestock exchange or a clearing corporationauthorised by it or the depository, as thecase may be, shall, within three weeks ofthe end of each month and in accordancewith the rules made in this behalf by theCentral Government, in consultation withthe State Government, transfer the stamp-duty collected under this section to theState Government where the residence ofthe buyer is located and in case the buyer islocated outside India, to the StateGovernment having the registered office ofthe trading member or broker of such buyerand in case where there is no such tradingmember of the buyer, to the StateGovernment having the registered office ofthe participant.

APPLICABILITYThis amendment shall be applicable with effectfrom 01st day of July, 2020.

OTHER IMPORTANT POINTS

➢ For the purpose of stamp duty, option trades

shall be valued at premium

➢ If the consideration, for off market

transaction(s), is paid in part or in

installments, then the stamp duty shall be

paid on the entire sale consideration.

➢ For transfer of securities pursuant to

invocation of pledge, stamp duty shall be

collected from the pledgee on the market

value of the securities.

➢ In case of off-market transfers Stamp duty

shall be paid by the transferor on the

consideration amount specified by him in the

'Delivery Instruction Slip (DIS)’.

➢ For all off market transactions stamp duty is

to be paid in advance i.e. prior to execution

of the instruction. In continuation of above,

applicable rates of Transaction and Clearing

Charges (on Turnover) effective from July 01,

2020 are:

Disclaimer:

IN NO EVENT THE AUTHOR SHALL BE LIABLE FOR ANY DIRECT, INDIRECT, SPECIAL OR INCIDENTAL DAMAGE RESULTING FROM OR ARISING OUT OF OR IN CONNECTION WITH THE USE OF THIS INFORMATION.

d. Other derivatives 0.002%

v. Government securities 0%

vi. Repo on corporate bonds 0%

*************************

CORPORATE COMPLIANCE CALENDAR

PCS LALIT RAJPUT

JULY 2020


ABOUT ARTICLE :This article contains various Compliance requirements under Statutory Laws. Compliance means “adhering torules and regulations.” Compliance is a continuous process of following laws, policies, and regulations, rules tomeet all the necessary governance requirements without any failure.

If you think compliance is expensive, try non‐ compliance”

Compliance Requirement Under

1 Foreign Exchange Management Act, 1999 (FEMA) and Important Notifications page no. 36

2. Income Tax Act, 1961 page no. 39

3. Goods & Services Tax Act, 2017 (GST) and Important Updates / Circulars page no. 42

4. Other Statutory Laws and Updates page no. 46

5. SEBI (Listing Obligations & Disclosure Requirements) (LODR) Regulations, 2015 page no. 48

6. SEBI Takeover Regulations 2011 page no. 56

7. SEBI (Prohibition of Insider Trading) Regulations, 2015 page no. 57

8. SEBI (Issue of Capital and Disclosure Requirements) Regulations, 2018 page no. 57

9. SEBI (Buyback of Securities) Regulations, 2018 page no. 59

10. SEBI (Depositories and Participants) Regulations 2018) and Circulars / Notifications page no. 59

11. Minimum Public Shareholding (MPS) requirements page no. 60

12. Regulatory Requirements by the trading members / clearing members / depository

participants, mentioned in the SEBI circulars page no. 61

13. Timelines for compliance with the regulatory requirements by DPS / RTAS / KRAS page no. 62

14. SEBI Relaxations for Preferential Issues Matters page no. 63

15. Stamp duty rates w.e.f. 1st July 2020 & AIF update page no. 63

16. Companies Act, 2013 (MCA/ROC and LLP Compliance) and Notifications page no. 67

17. IEPFA (Accounting, Audit, Transfer and Refund) Rules 2016 page no. 71

18. Insolvency and Bankruptcy Board of India (IBBI) Updates page no. 71

19. NBFC Compliance Overview page no. 72

20. RERA Gujarat Quarterly Return page no. 73

JULY 2020


1. COMPLIANCES UNDER FEMA / RBI

Applicable

Laws/Acts

Due Dates Compliance Particulars Forms / (Filing mode)

FEMA ACT 1999 14.08.2020

(extended)

Annual Return on Foreign liabilities and assets

The FLA return is required to be submitted by the

companies who have received Foreign direct

investment (FDI) and/or made Foreign direct

investment abroad in the previous year(s)

including the current year

FLA Return

FEMA ACT 1999 Monthly Basis External Commercial Borrowings

Borrowers are required to report all ECB

transactions to the RBI on a monthly basis

through an AD Category – I Bank in the form of

‘ECB 2 Return’.

ECB 2 Return

FEMA ACT 1999 Not later than 30

days from the date

of issue of Capital

instrument.

FC-GPR is a form filed when the Indian company

receives the Foreign Direct Investment and the

company allots shares to a person resident

outside India.

Form FC-GPR

FEMA ACT 1999 With in 60 days of

receipt/ remittance

of funds or transfer

of capital

instruments

whichever is earlier.

Reporting of transfer of shares and other eligible

securities between residents and non-residents

and vice- versa is to be made in Form FC-TRS.

The onus of reporting shall be on the resident

transferor/ transferee.

Form FC-TRS.

FEMA ACT 1999 within 30 days from

the date of receipt of

the amount of

consideration.

A Limited Liability Partnership receiving amount

of consideration and acquisition of profit shares is

required to submit a report in the Form FDI LLP-1

Form FDI LLP-I


the date of receipt of

funds in

A Limited liability Partnership shall report

disinvestment/ transfer of capital contribution or

profit share between a resident and a non

resident (or vice versa)

Form FDI LLP-II


the date of allotment

of capital

instruments

The domestic custodian shall report the issue/

transfer/ of sponsored/ unsponsored depository

receipts

Downstream

statement -Form DI

IMPORTANT UPDATES:

1. The due date for submission of FLA for the year 2019-20 is extended to August 14, 2020.

2. RBI Extends Timeline For Finalisation Of Audited Accounts For Applicable NBFCs: every applicable NBFC

shall finalise its balance sheet within a period of 3 months from the date to which it pertains or any date as

notified by SEBI for submission of financial results by listed entities.

3. RBI COVID 19 Regulatory Complete package

The Reserve Bank of India (RBI) has released 21st Issue of the Financial Stability Report (FSR), on 24th

July 2020 which reflects the collective assessment of the Sub-Committee of the Financial Stability and

Development Council (FSDC) on risks to financial stability, and the resilience of the financial system in

the context of contemporaneous issues relating to development and regulation of the financial

sector.

RBI has discussed about various relaxation due to COVID 19 via Press Conferences.

Regulatory package – COVID-19

JULY 2020


Liquidity Measures Rationale/Impact

Targeted long-term repo operations

(TLTRO) - RBI conducted term repo

auctions of up to 3-year tenor for a total

amount of Rs. 1,00,000 crore for investing

in corporate bonds, commercial papers

and non- convertible debentures with

concessionin MTM guidelines.

Borrowing costs in financial markets have dropped to their lowest in a

decade on the back of abundant liquidity. Interest rates on 3-month CPs

(NBFC), 3-month CPs (non-NBFC) and 3-month CDs have softened by

around 320 bps, 365 bps, 472 bps, respectively between March 23,

2020 and June 30, 2020. The spread of 3-year AAA-rated Corporate

Bond (CB) over similar tenor government securities has decreased

from 320 bps on March 26, 2020 to 114 bps on June 26, 2020 for NBFCs.

Lower borrowing costs, coupled with deployment of TLTRO funds,

have led to record primary issuance of corporate bonds of `2.09 lakh

croreinthefirstquarterof 2020-21.

To enable better transmission of its

monetary policy, RBI introduced Long Term

Repo Operation (LTRO) under which RBI

conducted term repos of one year and

threeyeartenorsatpolicyreporate.

(*LTROs of `1 lakh crore each were

announced on Feb 06, 2020 and Mar 16,

2020 of which auction for a total of

`1,25,000 crores have been conducted so

far).

Abundant liquidity conditions along with 3-year LTROs have anchored

the short-term G-sec yields closer to the policy repo rate. The 3-month

T-Bill yield has dropped around 195 bps since LTRO announcement in

February and has generally remained lower than the reverse repo rate

consistently since March. The 3-year G-sec yield too has droppedby158

basis points while the 10-year yield has dropped by 74 bps between

announcementofLTROsandJuly10,2020.

The government securities market has remained resilient and the G-

Sec yields have remained in tight-range despite significant

enlargement of government borrowing programme and increase in

the borrowinglimitof state governments.

JULY 2020

RBI CIRCULARS / NOTIFICATIONS:


The policy repo rate was brought down from 5.15 per cent on March 27, 2020

to 4 per cent on May 22, 2020. The Marginal Standing Facility (MSF) rate was

reduced from 5.40 per cent to 4.25 percentwhilethe reverse repo rate under

the Liquidity Adjustment Facility (LAF) wasreducedfrom4.90percentto3.35

percent.TheMonetaryPolicyCommittee(MPC)also decidedtocontinuewith

the accommodative stance for as long as it is necessary to revive growth and

mitigate the impact of COVID-19 on the economy while ensuring that

inflationremainswithintarget.

To lower borrowing costs and revive growth prospects.

CRR reducedby 100 basispoints to 3 percentof NDTL.UnderMSF,bankswere

allowedtoborrowby dipping up to 3 per cent into SLR.

Reduction in CRR led to injection ofliquidity of around `1,37,000 croreinto the banking system whileenhancement in MSF ceilingenabledthemfor bettermanagementof day to dayliquidity.

S. N. Particulars of the Circulars Link

1 Special liquidity scheme for NBFCs/HFCs https://www.rbi.org.in/Scripts/NotificationUs

er.aspx?Id=11925&Mode=0

2 Master Circular on SHG-Bank Linkage Programme https://www.rbi.org.in/Scripts/NotificationUs


3 Master Circular – Lead Bank Scheme https://www.rbi.org.in/Scripts/NotificationUs


4 Distressed Assets Fund - Subordinate Debt for Stressed

MSMEs

https://www.rbi.org.in/Scripts/NotificationUs


5 Credit flow to Micro, Small and Medium Enterprises Sector https://www.rbi.org.in/Scripts/NotificationUs


6 Exemption from Registration as NBFC – Alternative

Investment Fund (AIF)

https://www.rbi.org.in/Scripts/NotificationUs


7 Fair Practices Code for Asset Reconstruction Companies https://www.rbi.org.in/Scripts/NotificationUs


8 Implementation of Indian Accounting Standards https://www.rbi.org.in/Scripts/NotificationUs


9 Indian Stamp Act, 1899 Amendments and Rules made

thereunder

https://www.rbi.org.in/Scripts/BS_PressRelea

seDisplay.aspx?prid=50033

10. RBI Working Paper No. 08/2020: Subnational Government

Debt Sustainability in India: An Empirical Analysis

https://www.rbi.org.in/Scripts/BS_PressRelea

seDisplay.aspx?prid=50037

11. Are Dynamic Shifts Underway in the Indian Economy?

(Shri Shaktikanta Das, Governor, Reserve Bank of India - July

27, 2020 – Addressed to CII National Council, Mumbai)

https://www.rbi.org.in/Scripts/BS_SpeechesV

iew.aspx?Id=1098

https://www.rbi.org.in/Scripts/NotificationUser.aspx?Id=11925&Mode=0https://www.rbi.org.in/Scripts/NotificationUser.aspx?Id=11927&Mode=0https://www.rbi.org.in/Scripts/NotificationUser.aspx?Id=11926&Mode=0https://www.rbi.org.in/Scripts/NotificationUser.aspx?Id=11933&Mode=0https://www.rbi.org.in/Scripts/NotificationUser.aspx?Id=11934&Mode=0https://www.rbi.org.in/Scripts/NotificationUser.aspx?Id=11936&Mode=0https://www.rbi.org.in/Scripts/NotificationUser.aspx?Id=11937&Mode=0https://www.rbi.org.in/Scripts/NotificationUser.aspx?Id=11940&Mode=0https://www.rbi.org.in/Scripts/BS_PressReleaseDisplay.aspx?prid=50033https://www.rbi.org.in/Scripts/BS_PressReleaseDisplay.aspx?prid=50037https://www.rbi.org.in/Scripts/BS_SpeechesView.aspx?Id=1098

2. COMPLIANCE REQUIREMENT UNDER INCOME TAX ACT, 1961

JULY 2020


Applicable

Laws/Acts

Compliance Particulars Due Dates Revised

Due Dates

Income Tax

Act, 1961

Filing of original return for the Assessment Year 2019-20 u/s 139 (1) 30-07-2020 30-09-2020

Income Tax

Act, 1961

Filing of belated return for the Assessment Year 2019-20 u/s 139 (4) 30-06-2020 30-09-2020

Income Tax

Act, 1961

Filing of revised return for the Assessment Year 2019-20 u/s 139 (5) 30-06-2020 30-09-2020

Income Tax

Act, 1961

TDS/ TCS Return for quarter ending 31.03.2020 (Q4 of F.Y. 2019-20) for

Government Offices

30-06-2020 15-07-2020

Income Tax

Act, 1961

TDS/ TCS Return for 31.03.2020 (Q4 of F.Y.

2019-20) quarter

30-06-2020 31-07-2020

Income Tax

Act, 1961

Date of issuance of TDS

certificate to employees in form 16A and other in form 16

15-07-2020 15-08-2020

Income Tax

Act, 1961

Investments for claiming deduction under Chapter-VIA-B of the IT Act which

includes section 80C, 80D, 80G etc. for the A.Y. 20-21 i.e. F.Y. 19-20

30-06-2020 31-07-2020

Income Tax

Act, 1961

Investment/ construction/ purchase for claiming roll over benefit/ deduction

in respect of capital gains under sections 54 to 54GB

30-06-2020 30-09-2020

Income Tax

Act, 1961

Furnishing of Form 24G by an office of the Government for the month of:

• February 2020

• March 2020

• April to November 2020

05-03-2020

30-04-2020

Within 15

days from

the end of

the month

15-07-2020

15-07-2020

31-03-2020

Income Tax

Act, 1961

New procedure for registration, approval or notification entities under u/s

10(23C), 12AA, 35 and 80G

01.06.2020 01.10.2020

Income Tax

Act, 1961

Form 24QB, 24QC and 24QD of February and March 2020 (Section 200 read

with Rule 31A or Section 206C read with Rule 31AA)

30-03-2020

30-04-2020

30-06-2020

Income Tax

Act, 1961

Date of filing of declaration and payment of tax under VI VAD SE VISH WAS 30-06-2020 31-12-2020

Income Tax

Act, 1961

Due date for any of the following actions, except mentioned above, under

the the Wealth-Tax Act, 1957, Income-tax Act, 1961, Prohibition of Benami

Property Transactions Act, 1988, Chapter VII of Finance (No. 2) Act, 2004

(dealing with Securities Transaction Tax), Chapter VII of Finance Act, 2013

(dealing with Commodities Transaction Tax), Black Money (Undisclosed

Foreign Income and Assets) and Imposition of Tax Act, 2015, Chapter VIII of

Finance Act, 2016 (dealing with Equalisation Levy) and Direct Tax Vivad se

Vishwas Act, 2020 by any Authority, Commission or Tribunal:

20-03-2020

to

31-12-2020

31-03-2021

JULY 2020


➢ IMPORTANT UPDATES:

1. PAN-Aadhaar linking deadline FURTHER extended to beyond JUNE, 2020

2. The due date for linking of PAN with Aadhaar as specified under sub-section 2 of Section 139AA of the

Income-tax Act,1961 has been extended from 31st December, 2019 to 31st March, 2020 and further

extended to 31st March, 2021 due to COVID – 19 outbreak.

2. Government to infuse Rs 50,000 crores liquidity by reducing rates of TDS, for non-salaried specified

payments made to residents, and rates of Tax Collection at Source for specified receipts, by 25% of the

existing rate.

3. Due date of Tax audit has been extended from 30th September 2020 to 31st October 2020.

4. The IT department has extended the date to issue form 16 tds certificates for its employees till 30th

November concerned for FY 2019 – 20

5. The last date to deposit TDS Deducted under section 194IA for the month of march is on or before 30th

April of 2020.

6. In June, the government had extended the date for making investment, construction, purchase for

claiming deduction in respect of capital gains under Sections 54 to 54GB of the Income Tax Act to

September 30, 2020. Section 54 relates to tax exemptions available from capital gains if the capital gains

are invested in purchase or construction of residential property. Therefore, the investment, construction,

purchase made up to September 30, 2020 shall be eligible for claiming deduction from capital gains.

Income Tax

Act, 1961

• passing order

• issuance of notice, intimation, notification,

sanction or approval

• completion of proceedings

• any other action

• filing of appeal, reply, application

• furnishing of reports, document, return, statement or any such record

20-03-2020

to

31-12-2020

31-03-2021

Income Tax

Act, 1961

Due date for any of the following actions, except mentioned above, under: the

Wealth-Tax Act, 1957, Income-tax Act, 1961, Prohibition of Benami Property

Transactions Act, 1988, Chapter VII of Finance (No. 2) Act, 2004 (dealing with

Securities Transaction Tax), Chapter VII of Finance Act, 2013 (dealing with

Commodities Transaction Tax), Black Money (Undisclosed Foreign Income and

Assets) and Imposition of Tax Act, 2015, Chapter VIII of Finance Act, 2016

(dealing with Equalisation Levy) and Direct Tax Vivad se Vishwas Act,

2020 by the Taxpayers and/or Authority:

• filing of appeal, reply, application

• furnishing of reports, document, return, statement or any such record

20-03-2020

to

31-12-2020

31-03-2021

JULY 2020o IMPORTANT NOTIFICATIONS:


S.

No

Particulars of the Notification(s) File No. / Circular No. Notification Link(s)

1 One-time relaxation for Verification of tax-

returns for the Assessment years

201S-16, 2016-17, 2017-18, 2018-19 and

2019-20 which are pending due to non-filing

of ITRV form and processing of such returns

- reg.

Circular No. 13/2020/

F. No. 225/59/2020/ITA-1I

https://www.incometaxindia.gov

.in/communications/circular/circ

ular_13_2020.pdf

2 Clarification in relation to notification issued

under clause (v) of proviso to

section 194N of the Income-tax Act, 1961

(the Act) prior to its amendment by Finance

Act, 2020 (FA, 2020)-Reg

Circular No.14/2020

F. No. 370142/27/2020-TPL



ular_14_2020.pdf

3 Notification of Sovereign Wealth Fund under

section to(23FE) of the Income-tax Act, 1961

Circular No. 15 of 2020

F No 370142/26/2020-TPL



ular_15_2020.pdf

4 Income-tax (16th Amendment) Rules, 2020 Notification No. 43/2020/F.

No. 370142/11/2020-TPL


.in/communications/notification

/notification_43_2020.pdf

5 Notification of Harmonised Master List of

Infrastructure Sub-sectors for the purposes

of section 10(23FE) of the Income-tax Act,

1961

Notification No. 44/2020/F.

No. 370142/24/2020-TPL




6 The National Pension Scheme Tier II- Tax

Saver Scheme, 2020.

Notification No. 45 /2020/F.

No.370142/26/2019-TPL




7 ‘National Aviation Security Fee Trust’ (PAN

AADTN2508F)

Notification No. 46 /2020/F.

No. 300196/07/2020-ITA-I




8 Notification u/s 138 (1)(ii) of the Income-tax

Act, 1961 under PM-KISAN Yojana

F. No. 225/49/2019-ITA.II

Notification No. 51 /2020



/notification_no_51_2020.pdf

9 Notification u/s 138 of the Income-tax

ACt,1961 in respect of Intelligence Bureau,

Cabinet Secretariat, National Investigation

Agency and Narcotics Control Bureau

F. No. 225/53/2020-IT A.II

Notification No. 52 /2020



/notification_no_52_2020.pdf

https://www.incometaxindia.gov.in/communications/circular/circular_13_2020.pdfhttps://www.incometaxindia.gov.in/communications/circular/circular_14_2020.pdfhttps://www.incometaxindia.gov.in/communications/circular/circular_15_2020.pdfhttps://www.incometaxindia.gov.in/communications/notification/notification_43_2020.pdfhttps://www.incometaxindia.gov.in/communications/notification/notification_44_2020.pdfhttps://www.incometaxindia.gov.in/communications/notification/notification_45_2020.pdfhttps://www.incometaxindia.gov.in/communications/notification/notification_46_2020.pdfhttps://www.incometaxindia.gov.in/communications/notification/notification_no_51_2020.pdfhttps://www.incometaxindia.gov.in/communications/notification/notification_no_52_2020.pdf

JULY 2020

3. COMPLIANCE REQUIREMENT UNDER GOODS & SERVICES TAX ACT, (GST) 2017

Keep

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Ghaziabad Chapter of NIRC of ICSI ICSI-NIRC …...GHAZIABAD CHAPTER E-NEWSLETTER Page 64 AIFS, WHERE RTAHAVE NOT BEEN APPOINTEDSO FAR, SHALL APPOINT RTA, AT THE EARLIEST, BUTNOTLATER