Friday, 23 March 2018

23 March 2018 Updates

Less than 1% of IT Returns selected for Investigation: CBDT asks to file ITR without Fear*

Read more at: http://www.taxscan.in/less-than-1-of-it-returns-selected-for-investigation-cbdt-asks-to-file-itr-without-fear/19606/
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No Penalty when difference in Declared Income and Assessed Income is on the basis of Assumption and Estimation only: ITAT [Read Order]

Read more at: http://www.taxscan.in/no-penalty-difference-declared-income-assessed-income-assumption-estimation-itat/19615/
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GST: CBEC to probe on Proprietors, LLPs and HUF for Fraudulent Transitional claims*

Read more at: http://www.taxscan.in/gst-cbec-to-probe-on-proprietors-llps-and-huf-for-fraudulent-transitional-claims/19629/
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Delhi HC asks Young Indian To Deposit Rs. 10 Cr in National Herald Case* [Read Order]

Read more at: http://www.taxscan.in/delhi-hc-young-indian-deposit-rs-10-cr-national-herald-case/19633/
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Debit Notes are Valid Documents for Availing Credit: CESTAT allows Refund to Ford* [Read Order]

Read more at: http://www.taxscan.in/debit-notes-valid-documents-availing-credit-cestat-allows-refund-ford/19601/
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📺 *Updates*

➡1. No immunity to payer for TDS default if recipient doesn't pay tax on income received by him from payer
Academy of Medical Sciences v. Commissioner of Income-tax

➡2. NCLT can’t adjudicate on eligibility of resolution applicant as it was under consideration of Committee of creditors
State Bank of India v. Electrosteel Steels Ltd.

➡3. Sec. 153 proceedings couldn't be invoked against third party without recording satisfaction note; SLP dismissed.
Income Tax Officer v. Canyon Financial Services Ltd.*

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S. 80HH Benefit allowable to Assessee who carries on processing in an Industrial Undertaking belonging to Another, but situated in a Backward Area: Kerala High Court* [Read Judgment]

Read more at: http://www.taxscan.in/s-80hh-assessee-carries-processing-industrial-undertaking-backward-area/19595/
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Sale Price approved by Charity Commissioner had to be followed in case of Trust’s Sale Deed: ITAT* [Read Order]

Read more at: http://www.taxscan.in/sale-price-charity-commissioner-followed-trusts-sale-deed-itat/19532/
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*Assessee eligible for Benefit of Sec 54F since Gain on entering into the Development Agreement is LTCG: ITAT* [Read Order]

Read more at: http://www.taxscan.in/assessee-eligible-for-benefit-of-sec-54f-since-gain-on-entering-into-the-development-agreement-is-ltcg-itat/19582/
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# *MCA* has permitted Two proposed names and One Resubmission (RSUB) while Reserving Unique Names for companies through the RUN web service w.e.f. 24.03.2018.

# Parliament has passed the *Payment of Gratuity (Amendment) Bill, 2018* that will double the ceiling of gratuity from Rs.20 Lac from Rs.10 Lac presently.

# *IBC*: Committee of Creditors (‘CoC’) of Bhushan Steel Ltd. has declared Tata Steel Ltd. as the successful resolution applicant.

# *SEBI* has issued a Circular w.r.t Due diligence and reporting requirements under Foreign Account Tax Compliance Act (FATCA) and Common Reporting Standards (CRS) as issued by the issued by the CBDT.

# Union Cabinet has approved North-East Industrial Development Scheme *(NEIDS)* 2017 with financial outlay of ₹ 3000 crores upto March, 2020.

# Union Cabinet has approved the *Ayushman Bharat*-National Health Protection Mission that aims to cover as much as 10 crore families.

# *IT*: If the shares were of some fictitious company which was not listed in the BSE/NSE, the same could never have been transferred to demat account - revenue failed to prove that transaction were bogus – Pr.CIT Vs. Dipali Mahendra Shah (2018 (3) TMI 1084 - Gujarat HC).
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👉🏻After PNB, SBI, now Union Bank of India hit by bank fraud*

(CBI has registered a Rs1,394.43 crore bank fraud case against Hyderabad-based Totem Infrastructure Ltd on a complaint by Union Bank of India)
👇🏻 👇🏻 👇🏻
https://goo.gl/yZgHnm 

*👉🏻Govt to set up more NCLT benches to handle wave of bankruptcy cases*

(Govt will also hire more judicial and technical officers—the hiring is expected to start in about two months—to take into account the requirement of the new NCLT benches at Cuttack, Jaipur and Kochi)
👇🏻 👇🏻 👇🏻
https://goo.gl/XR1NWZ 
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Govt asks Non-Compliant NBFCs to fulfill their Obligations under PML Rules*

Read more at: http://www.taxscan.in/govt-non-compliant-nbfcs-obligations-pml-rules/19563/
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Capital Gain u/s 45(4) does not attract on Admission or Retirement of Partners: ITAT [Read Order]

Read more at: http://www.taxscan.in/capital-gain-u-s-454-does-not-attract-on-admission-or-retirement-of-partners-itat/19480/
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*Activities of IIPM fall under ‘Commercial Training or Coaching Centre’ : CESTAT Upholds Service Tax Demand* [Read Order]

Read more at: http://www.taxscan.in/iipm-commercial-training-or-coaching-centre/19525/
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*Transitional Credit is Vested Right and can’t be Denied: Gujarat HC Issues Notices to Centre-State Govts, GST Council & GSTN*

Read more at: http://www.taxscan.in/transitional-credit-vested-right-gujarat-hc-issues-notices-centre-gst/19512/
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*Pune-based GST Officer Arrested for receiving Bribe of 30,000 Rupees*

Read more at: http://www.taxscan.in/pune-based-gst-officer-arrested-receiving-bribe/19508/
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GST: Kerala HC permits release of Goods by furnishing Simple Bond, directs Expedite Adjudication* [Read Judgment]

Read more at: http://www.taxscan.in/gst-kerala-hc-permits-release-of-goods-by-furnishing-simple-bond-directs-authorities-to-complete-adjudication-within-7-days/19538/
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*Finance Ministry clarifies Queries on E-Way Bill*

Read more at: http://www.taxscan.in/finance-ministry-clarifies-queries-on-e-way-bill/19553/
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*Finance Ministry Explains Applicability of GST on Skill Development, Start-Ups and Tourism*

Read more at: http://www.taxscan.in/finance-ministry-explains-applicability-of-gst-on-skill-development-start-ups-and-tourism/19555/

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Promoting Universal Teaching of Shri Guru Granth Sahib and Other Religious ‘Granths’ among the General Public is Charitable Activity: ITAT [Read Order]

Read more at: http://www.taxscan.in/promoting-universal-shri-guru-granth/19426/
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*E-Assessment: CBDT Asks AOs to Use Revised Format of Notice u/s 142(1)(ii)&(iii)* [Read Letter]

Read more at: http://www.taxscan.in/e-assessment-cbdt-revised-format-notice/19495/
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📺 *Updates*

➡1. FAQs on Cost of Inventories as per Ind AS 2
https://accountsandaudit.taxmann.com/fileopennew.aspx?id=222330000000014791&mode=home&page=

➡2. GST not applicable on work contracts for which agreements executed before July 1, 2017: HC

Coimbatore Corporation Contractors Welfare Association v. State of Tamil Nadu

➡3. Exporters are required to furnish bonds in order to export without paying IGST: Delhi HC
Aphro Ecommerce Solutions (P.) Ltd. v. Union of India*

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CBDT through its press release announce that the India and Hong Kong sign Double Taxation Avoidance Agreement (DTAA) and the Prevention of Fiscal Evasion with respect to taxes on income.

ITAT recently held that the provisions relating to Tax Deduction at Source ( TDS) under section 194C of the Income Tax Act are not applicable to off-transactions made by the assessee. In M/s. Sukumar Dutta versus Income Tax Officer, the Kolkata ITAT.

CBEC has issued a circular clarifying the position w.r.t Refund of IGST on Export – Export General Manifest (Extra Ordinary General Meeting) Error related cases.

SEBI has liberalised spread margin benefit in commodity futures contracts now allowed spread contracts across futures contracts in a commodity complex or inter-commodity spreads, with margin benefits from July.

Get PF balance by giving missed call or sending SMS to EPFO. Activate your Mobile number with UAN allotted by EPFO.

Govt. has extended the facility of hiring workers on fixed term employment to all sectors for improving the ease of doing business for players intending to hire people for completing specified projects, tasks or orders.

CAs cannot be compelled to give response on his involvement in Income Tax Act, FEMA, PMLA, Benami Act Violations before ICAI: No proceedings can be initiated against the petitioner since the action was merely on the basis of SFIO report and no subjective satisfaction has been recorded by the Disciplinary Authority in the impugned ‘prima facie opinion’, which renders it illegal. Delhi HC- CA Vijay Kumar Gupta Vs Director (Discipline) of  ICAI.
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✳Direct Tax:

▶Mumbai ITAT allows deduction u/s. 37 for penalty paid by assessee-company (engaged in the business of property development) to Slum Rehabilitation Authority (SRA) during AY 2010-11, rules that penalty was paid for regularization of certain construction work within the permissible byelaws of concerned authority and not for infringement or violation of any law;
[TS-119-ITAT-2018(Mum)]

▶Pune ITAT quashes CIT's order u/s. 263 denying deduction u/s 80IA(4) to assessee (a partnership firm having 3 corporate entities as its partners) for AY 2012-13, rejects Revenue’s stand that deduction u/s 80IA(4) is available only to a company or a consortium of companies and since the assessee is a partnership firm, it is not eligible for impugned deduction; [TS-118-ITAT-2018(PUN)]

✳Indirect Tax:

▶CBEC made amendment by way of notification no 27/2011-Customs, dated the 1st March, 2011, published in the Gazette of India, Extraordinary, vide number G.S.R. 153(E), dated the 1st March, 2011. Vide notification no 30 /2018-Customs, dated 20th March 2018.
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# *NFRA*: Section 132 (3) & (11) of the Companies Act, 2013 regarding the constitution of NAFRA has been notified w.e.f. 21.03.2018.

# *GST*: CBEC has issued Circular clarifying the position w.r.t Refund of IGST on Export – Export General Manifest (Extra Ordinary General Meeting) Error related cases – Cir.No.06/2018-Custom,dt.16.03.18. 

# *ICAI* has issued applicable amount of Membership & CoP Fee with GST for the year 2018-19 to be payable by 30 SEP 2018. Link at: https://resource.cdn.icai.org/49346mss39091.pdf.

# *IBC*: SEBI is planning to bring in additional disclosure requirements for listed corporates undergoing insolvency resolution process as well as amend norms pertaining to minimum public shareholding and other provisions for such entities.

# *ST*: CENVAT credit - prior to amendment w.e.f. 1.4.2008 - tax paid on GTA from the place of removal upto the first point, has to be allowed – CCE Vs. Vasavadatta Cements Ltd. (2018 (3) TMI 993 - Supreme Court).
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Section 50C not applicable to Cold Storage Building: ITAT* [Read Order]

Read more at: http://www.taxscan.in/50c-cold-storage-building-itat/19423/
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✍✍✍✍✍✍✍✍✍✍
ITAT: Notional rental income addition u/s. 23 on Builder’s unsold flats, unsustainable

Mumbai ITAT deletes  notional income addition  u/s. 23  towards annual letting value of unsold flats of Runwal builders (‘assessee’) during AY 2012-13; ITAT observes that flats sold by assessee were assessed under the head ‘income from business’ and the unsold flats were treated as its stock-in-trade, therefore holds that AO was incorrect in taxing notional value of unsold flats under the head ‘income from house property’; Relies on co-ordinate bench ruling in C.R. Developers Pvt. Ltd wherein Revenue’s reliance on Delhi HC ruling in Ansal Housing Finance & Leasing Co. Ltd. was rejected, notes that the coordinate bench had derived analogy from SC ruling in Chennai properties to reject applicability of Sec. 23; Also relies on Gujarat HC ruling in Neha Builders Pvt.Ltd.:ITAT
The ruling was delivered by the ITAT bench of Shri C.N. Prasad and Shri A.L. Saini

Mr. Rishabh Shah argued on behalf of the assessee while the Revenue was represented by Mr. V. Vidhyadhar

Note:

Delhi HC in Ansal Housing and Construction [TS-418-HC-2016(DEL)] had ruled in favour of Revenue and had reversed ITAT order holding that Sec. 22 and 23 were inapplicable to properties owned by the assessee. HC  had distinguished the assessee’s reliance on SC decision in Chennai Properties & Investments Ltd. [TS-238-SC-2015] as the main object of assessee therein was holding the properties and earning income by letting out properties, as against assessee in Ansal Housing case where letting out of properties was not part of its objects.

SC had admitted SLP against Delhi HC ruling in Ansal-Housing.

It is noteworthy that Finance Act 2017 amended Sec. 23 to insert sub-section (5) which provides that where the property consisting of any building or land appurtenant thereto is held as stock-in-trade and the property or any part thereof is not let during relevant previous year, the annual value of such property, for the period up to one year from the end of the financial year in which the certificate of completion of construction of the property is obtained from the competent authority, shall be taken to be nil.

[TS-124-ITAT-2018(Mum)]
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CBDT

 

CBDT through its press release announce that the India and Hong Kong sign Double Taxation Avoidance Agreement (DTAA) and the Prevention of Fiscal Evasion with respect to taxes on income. In so far as India is concerned, the Central Government is authorized under Section 90 of the Income-tax Act, 1961 to enter into an Agreement with a foreign country or specified territory for avoidance of double taxation of income, for exchange of information for the prevention of evasion or avoidance of income tax chargeable under the Income-tax Act, 1961. The Agreement will stimulate flow of investment, technology and personnel from India to HKSAR & vice versa, prevent double taxation and provide for exchange of information between the two Contracting Parties. It will improve transparency in tax matters and will help curb tax evasion and tax avoidance. The Agreement is on similar lines as entered into by India with other countries.

  

CBEC

 

CBEC has issued a circular clarifying the position w.r.t Refund of IGST on Export – Export General Manifest (Extra Ordinary General Meeting) Error related cases. To address the problems related to IGST refund, CBEC has already issued Circulars which highlighted the common errors and combination of error that hindered the sanction and disbursal of refund of IGST paid against exports. In Order to overcome this issue, the Shipping lines have been mandated to include the shipping bills originating from ICDs while filing the electronic EGMs at the gateway ports. In cases where the EGMs have not incorporated the shipping bills pertaining to ICDs, the Shipping lines/agents have been asked to file supplementary EGMs. In order to ensure a hassle free processing of refund claims, the following steps may be ensured by the jurisdictional officers in ICDs: (a) filing of local EGM i.e train or truck summary, as the case may be, immediately after cargo leaves the port, (b) liaising with jurisdictional officers at gateway port for incorporation of Shipping Bills pertaining to the cargo originating in ICDs, in the EGMs filed at gateway port by the Shipping lines/agents (c) rectification of errors in local and gateway EGM, wherever necessary.
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March End Activities

"Must do Things before March Closing"

Many changes were made in Indian Taxation in FY 2017-18.
One of the major change is introduction of GST law which replaced various old indirect tax laws of india.
In order to prevent adverse consequences in future it is essential to comply with GST
Act & Rules.

• This is the last month of the financial year 2017-18.

• Many changes occurred during the current year in GST laws.

• All rectification in the books of accounts should be done before 31st March, 2018.

• All the taxpayers should complete their pending work before 31st March., 2018.

• The taxpayers, who are liable to make payment, should do the payment on time.

• Filing of returns, if pending, should be done before 31.03.18

• Everyone should follow the correct tax system from this new financial year.

• So, pay the tax as per provisions of the Act and file your returns in time.

• Carryout all adjustments, corrections etc. before March 2018 Otherwise  taxpayers will have to face consequences in the future.

Following is the check-list for taxpayer:

1. Reversal of Input tax credit – As per the rules of Input tax credit, after issuance of tax invoice if receiver does not made the full payment of amount within 180 days then the credit taken on that invoice is to be reversed. And whenever the payment is made, the receiver can take the credit of the amount. Therefore the aging analysis of the debtors and creditors is to be done. all old invoices issued before 1st October, 2017, should be paid
before 31st March 2018.
Ex. Suppose the fees Rs. 10000 is payable to the Chartered Accountant on 15th September, 2017, and the credit on that of Rs. 1800 has been taken in
the return of that month, then the fees should be paid before 31st March, 2018. Otherwise the extra payment of Rs. 1800 is to be made in the month of March.

2. E way bill – It is compulsory to issue E way bill from 1st April, 2018 for inter-state transport. In case of inter-state supply, the goods are in transit as on 1st April, 2018, it is compulsory to generate e way bill for them. Therefore, it is necessary to take the registration under E way bill system before
31st March.

3. Reconciliation – All the taxpayers should reconcile the cash ledger, credit ledger and liability ledger with their books of accounts. All the entries should be done before the year end. Also debit note, credit note, rate difference,
discount, etc. also to be reconciled.

4. HSN Code in the Invoice – Before preparing first invoice in the new financial year, taxpayers should check the turnover for the year 2017-18. Taxpayers
whose turnover is above Rs. 1.5 crores but below Rs. 5 crores shall use 2-digit code and the taxpayers whose turnover is Rs. 5 crores and above shall use 4-digit code. Taxpayers whose turnover is below Rs. 1.5 crores are not
required to mention HSN Code in their invoices.

5. New series for tax invoice – If anyone wants to change the series for billing in the New Year, then he can do that from 1st April. New numbering should
be started form 1st April.

6. Composition scheme – If any taxpayer wants to register under composition scheme then he can apply in Form GST CMP – 02 before 31st March. Similarly,
those who wants to cancel the registration under composition scheme, they have to apply in Form GST CMP – 04 before 7th April. They have to calculate
the effects of ITC on closing stock.

7. Due dates of the returns – There are various due dates in the April month for filing the returns relating to 31st march. Such as GSTR 3B for March is to be filed up to 20th April. GSTR 1 is to be filed up 10th April.GSTR 4 is to be up
to 18th April and GSTR 6 is to be filed up to 13th April.

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# *IT*: 31 MAR 18 is the last day for filing of ITRs for AY 2016-17 & AY 2017-18.

# *GST*: Only 16% of GSTR-3B filed for Jul-Dec, 17 matched with GSTR-1. 34% of businesses paid Rs.34,400 crore less tax b/w Jul-Dec while filing GSTR-3B.

# *SEBI* has passed an Order providing exit to the Universal Commodity Exchange Limited (UCX).

# *RTI*: Supreme Court has capped maximum RTI fees to be charged by all government authorities at Rs.50 per application and Rs.5 for photocopying charges.

# *GST*: The Petitioner sought to avail concessional duty of 0% IGST Vs. 5% IGST for importing GSL ARTEMIA BRINE SHRIMP EGGS by relying upon NN002/2017-Cus, dt.28.06.17 in Sl.No.33, allowed to file an appeal before CoC(Appeals) – Priyanka Enterprises Vs. JCoC (2018 (3) TMI 971 - Madras HC).

# *IT*: Non-compliance with condition precedent u/s 179(1) - recovery of dues of the company from the directors - Order set aside - AO is at liberty to pass a fresh order after issuing an appropriate notice to the Petitioner - Chintan Arvind Shah Vs. ITO & Ors. (2018 (3) TMI 959 - Bombay HC).
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CBEC to verify 50,000 Transitional Credit Claims. In a bid to tackle fraudulent transitional credit claims by the taxpayers in their TRAN-1 return.

Kerala High Court quashed order of CESTAT since it failed to decide the issue that SCN is barred by time specifically raised by the party and directed to issue afresh.  Excell Corrogogated Boxes P Ltd. Vs CCE 2018 (359) 639 Kerala.

The Bombay High Court has directed the Tribunal  to decide the specific issues raised in the rectification application wherein  it was pleaded  that tribunal has not considered vital issues  in the final  order. National Torches and Tubes Vs CCE 2018 (359)669.

SEBI has passed an order providing exit to the Universal Commodity Exchange Limited (UCX) vide its Circular dated January 11, 2016, had issued guidelines for the exit of Commodity Derivatives Exchanges.

ICAI publication on Banking Frauds helpful in Bank Audits for Members. Download from https://www.icai.org/post.html?post_id=1456

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31-03-18 is last day for filing of ITR 1 to 7 for AY 2017-18 (Note change in law. ITR cannot be filed later) and for A.Y. 2016-17 with penalty of Rs. 5,000.

Deemed Rent from Unsold Flats not Taxable as they are Stock-in-Trade of Assessee-Builder: ITAT Mumbai In the case between M/s. Runwal Constructions vs. Assistant Commissioner of Income Tax.

Last date for Revision of DVAT Returns and Correction of 2A/2B Mismatch for the year 2016-17 (01-04-16 to 31-03-17) is 31-03-2018.

Only 16 per cent of the summary sales returns under GST matching with the final returns, the revenue department has started to analyze major gaps with a view to check any possible tax evasion.

CBEC has issued a detailed circular on verification of credit transitioned to GST through Form TRAN-1. Key aspects are stated below:
i.   Credit verification to be remain the primary focus area during FY 18-19.
ii.  Credit verification to take place by CGST authorities even if the jurisdiction is with state.
iii. Credit of KKC/SBC/E cess is not eligible.
iv.  Each line wise data in Tran-1 to be verified in detail.
v.   Supporting documents and other info to be sought from assessee.
vi.  Credit taken in excess of INR 25 Lakhs is being verified.
vii. List of 50000 assessee is being targeted for initial verification.
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New Entry in Reverse Charge Wef 25-1-18*
Services supplied by the Central Government, State Government, Union territory or local authority by way of renting of immovable property to a person registered under the Central Goods and Services Tax Act, 2017

*Who is to be Supplier of service*
Central Government, State Government, Union territory or local authority 

*Who is to be Recipient of Service*
Any person registered under the Central Goods and Services Tax Act, 2017.  
[3/23, 6:36 PM] CA Rohit Jaiswal: ICAI publication on Banking Frauds helpful in Bank Audits for Members. Download from https://www.icai.org/post.html?post_id=14566

Bank Branch Audit: Guidance Note on Audit of Banks 2018 edition issued by ICAI https://resource.cdn.icai.org/49205icai-aasb-gnabanks2018.pdf

*E way bill* – It is compulsory to issue E way bill from 1st April, 2018 for inter state transport.  In case of inter state supply, the goods are in transit as on 1st April, 2018, it is compulsory to generate e way bill for them. Therefore, it is necessary to take the registration under E way bill system before 31st March.

*Composition scheme* – If any taxpayer wants to register under composition scheme then he can apply in Form GST CMP – 02 before 31st March. Similarly, those who wants to cancel the registration under composition scheme, they have to apply in Form GST CMP – 04 before 7th April. They have to calculate the effects of ITC on closing stock.

Form *GST TRAN 2* – The taxpayers who have filed the TRAN 1 and have taken the credit of Excise duty paid, without any documents, they have to file the details of outward supplies for six months in TRAN 2 before 31st March 2018 for availing 40%/ 60% credit.
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CBEC

 

CBEC has observed instances where exporters are committing errors while filing refund claims and to help them, the department has started giving out refunds partially with manual intervention. To ease exporters' GST refund woes, revenue authorities will set up camps across the country for a fortnight beginning March 15, 2018 to March 29, 2018. There are going to be camps all over the country so that all exporters can come with refund problem and they will be explained what their problem is, they will be asked to rectify it and then the process will completed and refund will be given. The GST Council in its recent meeting decided to implement e-wallet scheme for refunds to exporters by October 1. Under the e-wallet mechanism, a notional credit would be transferred to the exporters account based on their past record and the credit can be used to pay taxes on input. Accordingly, merchant exporters can pay a tax at the rate of 0.1 per cent on goods procured for export purposes and obtain a refund for the same.Also, domestic procurement made under Advance Authorisation, EPCG and EOU schemes are being recognised as 'deemed exports' with flexibility for either the suppliers or the exporters being able to claim a refund of GST/IGST paid thereon.

 

SEBI

 

SEBI has passed an Order providing exit to the Universal Commodity Exchange Limited (UCX). UCX is the sixth Commodity Derivatives Exchange / deemed stock exchange to exit after the merger of Forward Markets Commission (FMC) with SEBI. SEBI, vide its Circular dated January 11, 2016, had issued Guidelines for the exit of Commodity Derivatives Exchanges. The circular prescribed, inter alia, various conditions for compliance covering various aspects including treatment of assets of non-operational stock exchanges, complete discharge of pending statutory liabilities, outstanding liability towards brokers and clients, redressal of all pending investors’ disputes / complaints, etc, on compliance of which, the exit order was issued to UCX. Further, the Income Tax Authorities, Ministry of Finance, Ministry of Corporate Affairs and the State Government of Maharashtra are being intimated about the exit of UCX, for appropriate action, at their end.
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📺 *Updates*

➡1. No reassessment to disallow sec. 80-IA deduction if it was duly allowed by CIT(A) in appellate proceedings
Gujarat Enviro Protection & Infrastructure Ltd. v. Deputy Commissioner of Income-tax*

➡2. ALP of royalty paid to AE in pursuance of technology collaboration agreement to be determined by CUP
Johnson Matthey India (P.) Ltd. v. Deputy Commissioner of Income-tax, Circle- 4 (1), New Delhi

➡3. Foreign Exchange Gains/losses under Ind AS and AS
https://accountsandaudit.taxmann.com/topstories/105010000000015328/foreign-exchange-gainslosses-under-ind-as-and-as.aspx

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