Detailed representations on (a) amending definition of ‘demerger’ u/s. 2(19AA) to cover hive off of business through divestment of shares of operating subsidiary (b) expanding scope of s.72A to cover service sector and (c) further clarifications on TDS u/s. 194R on business perquisites

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 – 110 001

Dear Sir,

We are grateful to you for having granted an audience to representatives of our Direct Tax Committee on 24th August 2022 to highlight some key pre-budget issues for your kind consideration. We thank you for expressing your views on various industry issues which help us to understand the Government’s perspectives on such issues. In this background, as discussed at the meeting, please find attached detailed representations on following key issues for your kind consideration :-

(a) amending definition of ‘demerger’ u/s. 2(19AA) to cover hive off of business through divestment of shares of operating subsidiary

(b) expanding scope of s.72A to cover service sector; and

(c) further clarifications required on TDS u/s. 194R on business perquisites

We trust the above will help the Government to take more informed decisions to address the industry issues. We shall be glad to provide any further clarifications as may be required by you.

Thanking you