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Shri Sanjay Malhotra, I.A.S.
Revenue Secretary
Department of Revenue
Ministry of Finance
Government of India
Room No.128-B, North Block
New Delhi – 110 001
Sir,
Post-Budget Memorandum 2024-25 of Bombay Chamber [Direct Tax]
The Bombay Chamber congratulates the Hon’ble Finance Minister for presenting the first budget of the third term of this government and a record breaking 7th consecutive budget on 23rd July 2024. The Bombay Chamber deeply appreciates the policy framework laid out in the Budget with a clear focus on nine budget priorities to firmly establish India on the growth path to achieve the ambition of Viksit Bharat by 2047. From a tax policy perspective, the Bombay Chamber welcomes the capital gains tax reform by rationalising the period of holding, long term and short term capital gains rates for different classes of assets. The Budget proposals also include various taxpayer friendly measures such as reduction of tax rate for foreign companies, removal of angel tax, removal of e-commerce Equalisation Levy, reduction of TDS rates, making concessional tax rates for individuals more attractive, increasing de minimis threshold for penalty under Black Money Act for non-disclosure of foreign movable assets, permitting employers to consider other TDS/TCS while doing Salary TDS compliance, further rationalisation of foreign investment in IFSC, simplification of charity tax regime, reintroduction of Vivaad Se Vishwas scheme, increase in monetary limits for filing appeals by Tax Department and other measures intended to spur investment, reduce litigation 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 (No. 2) Bill 2024 is attached for your kind consideration. These include request to provide clarity on house property taxation of letting out of residential accommodation, further reduction in tax rate for foreign companies (with introduction of Branch Profits Tax), provide option between old regime (with indexation) and new regime for capital gains, address unintended anomalies in capital gains, Salary TDS, block assessment for search, Vivaad Se Vishwas, Black Money Act, provide for repeal of section 2 of Finance Act, 2024 (Interim Budget) 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
