Post-Budget Memorandum 2023-24 of Bombay Chamber (Direct Tax)

Mr. Kamlesh C. Varshney, I.R.S.
Joint Secretary – TPL (I)

Central Board of Direct Taxes

Ministry of Finance

Government of India

North Block

New Delhi – 110 0011

Sir,

Post-Budget Memorandum 2023-24 of Bombay Chamber [Direct Tax]

The Honourable Finance Minister Smt. Nirmala Sitharaman presented the first Budget of the Amrit Kaal on 1 February 2023 seeking to lay down a blueprint for India@100. The Bombay Chamber deeply appreciates the policy framework laid out in the Budget with a clear focus on prosperity, inclusivity and public partnership to firmly establish India on the growth path. From a tax policy perspective, the Bombay Chamber welcomes the personal tax reform by making the concessional tax regime more attractive to the middle-class in the backdrop of global economic headwinds and rising inflation. The Budget proposals also include various taxpayer friendly measures such as extension of relief available to start-ups in carrying forward and setting off of losses, introduction of concessional tax rate regime for new manufacturing cooperatives, promotion of conversion of physical gold holdings into Electronic Gold Receipts, further rationalisation of foreign investment in IFSC, and other measures intended to spur investment and improve ‘ease of doing business’.

However, certain direct tax proposals in the Budget have raised concerns amongst the industry members who desire reconsideration of the proposals and/or better clarity with a view to reduce uncertainty for the industry and reduce potential for litigation.

On the basis of the responses received from our Members, a Memorandum containing suggestions of Bombay Chamber [Direct Tax] on the issues related to the Finance Bill 2023 is attached for your kind consideration. These include request to refrain from taking any steps which may diminish the attractiveness of India as an investment destination, extension of various sunset dates for claim of concessional tax/ withholding rates, relaxing angel taxation norms in respect of investment from non-residents, withdrawal of the proposal to enhance TCS Rates on LRS remittances, addressing the anomalies in proposed provisions on taxation of business trusts, roll-back/ rationalisation of provisions regarding withholding of determined refunds by tax authority, etc.

Our representatives would deem it a privilege to participate in the meetings organised by the Department of Revenue for post-budget discussions and provide any further clarifications, if required, with regard to our suggestions.

Thanking you,

Yours faithfully,

Sandeep Khosla

Director General