Clarification regarding taxation of ‘Alternate Investment Funds’ having status of Non-Charitable Trusts

Circular No. 13/2014, F.No.225/78/2014-ITA.II, dated 28th July, 2014

Clarification regarding taxation of ‘Alternate Investment Funds’ having status of Non-Charitable Trusts under the Income Tax Act, 1961 – regarding.

1. The SEBI (Alterative Investment Funds) Regulations, 2012 (‘AIF Regulations’) vide Regulation No.4 issued in May 2012 aims at regulating all forms of private pool of funds in India. The said Regulations divide the Alternative Investment Funds (‘AIFs’) into three broad categories – Category-I, Category-II and Category-III Alternative Investment Funds, depending upon the operational strategies, objectives and fund structure. A large number of AIFs registered with SEBI have been set up in the form of non-charitable trusts.

2. While the AIFs, being Venture Capital Funds, making investment in the Venture ‘Capital Undertakings have been accorded ‘tax pass through’ status under section 10(23FB) read with section 115U of the Income tax Act, 1961 (‘Act’) (whereby income arising in the hands of such Fund would be treated as tax-exempt, while investors of such funds would become liable to tax liability on as if the investors have made the investments directly in the Venture Capital Undertaking), clarification has been sought about tax-treatment in cases of AIFs being non-charitable trusts where the investors name and beneficial interest are not explicitly known on the date of its creation – such information becoming available only when the funds starts accepting contributions from the investors.

3. Board has been requested to clarify whether the income of such funds would be taxable in the hands of the Trustees of the AIF in the capacity of a ‘Representative Assessee’ (as defined u/s- 160(i)(iv) of the Act) or in the hands of investors (i.e. contributors of funds).

4. The matter has been examined. In the situation where the trust deed either does not name the investors or does not specify their beneficial interests, provisions of sub-section (1) of section 164 would) come into play and the entire income of the Fund shall become liable to be taxed at the Maximum Marginal Rate of income-tax in the hands of the trustees of such AIFs in their capacity as ‘Representative Assessee’. It is also clarified that in such cases, provisions of section 166 of the Act need not be invoked in the hands of the investor, as corresponding income has already been taxed in the hands of the ‘Representative Assessee’ in accordance with sub-section (1) of section 164 of the Act.

5. However, in cases of funds where names of the beneficiaries and their interests in the Fund are determined i.e. stated in the trust deed, the tax on whole of the income of the Fund – consisting of or including profits and gains of business, would be leviable upon the Trustees of such AIF, being ‘Representative Assessee’ at the Maximum Marginal Rate in accordance with sub-section (1A) of section 161 of the Act.

6. The clarification given above shall not be operative in the area falling in the jurisdiction of a High Court which has taken or takes a contrary decision on the issue.

7. The contents of this Circular may be brought to the notice of all concerned.

8. Hindi version to follow.

Source: Income Tax - India.

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Clarification - Treatment - Expenditure incurred for development of roads/highways in BOT Agreements under Income Tax Act, 1961

Circular No. 09/2014, F.No. 225/182/2013/ITA.II, dated 23rd April, 2014

Clarification regarding treatment of expenditure incurred for development of roads/highways in BOT agreements under Income Tax Act, 1961-regarding.

1. It has come to the notice of the Board that disputes have arisen as to whether the expenditure incurred on development and construction of infrastructural facilities like roads/highways on Build-Operate-Transfer (‘BOT’) basis with right to collect toll is entitled for depreciation under Section 32(1)(ii) of the Act or the same can be amortized by treating it as an allowable business expenditure under the relevant provision of the Income Tax Act, 1961 (‘Act’).

2. In such project, the developer (hereinafter referred to as ‘assessee’), in terms of concessionaire agreement with the Government or its agencies is required to construct, develop and maintain the infrastructural facility of roads/highways which, inter-alia, includes laying of roads bridges, highways, approach roads, culverts, public amenities etc. at its own cost and its utilization thereof for a specified period. In lieu of consideration of the expenditure incurred on construction, operation and maintenance of the infrastructure facility covered by the period of agreement, the assessee is accorded a right to collect toll from user of such facility. The expenditure incurred by such assessee on development and construction of such infrastructural facility are capitalized in the accounts. It is seen that in returns-of-income, assessee are generally claiming depreciation on such capitalized expenditure treating it as an ‘intangible asset’ in terms of section 32(1)(ii) of the Act while in assessments, such claims are being disallowed by the Assessing Officer on the grounds that such infrastructural facility is not owned, wholly or partly, by the taxpayer which is an essential condition for claiming depreciation and further right to collect toll does not fall in any of the categories of ‘intangible assets’ specified in sub clause(ii) of sub-section (1) of Section 32 of the Act.

3. In BOT arrangement for development of roads/highways, as a matter of general practice, possession of land is handed over to the assessee by the Government/notified authority for the purposes of construction of the project without any actual transfer of ownership and such assessee has only a right to develop and maintain such asset. It also enjoys the benefits arising from use of asset through collection of toll for a specified period without having actual ownership over such asset. Therefore, the rights in the land remain vested with the Government or its agencies. Thus, as assessee does not hold any rights in the project except recovery of toll fee to recoup the expenditure incurred, it cannot therefore be treated as an owner of the property, either wholly or partly, for purposes of allowability of depreciation under section 32(1)(ii) of the Act. Thus present provisions of the Act do not allow claim of depreciation on Toll ways due to non fulfillment of ownership criteria in such cases.

4. There is no doubt that where the assessee incurs expenditure on a project for development of roads/highways, he is entitled to recover cost incurred by him towards development of such facility (comprising of construction cost and other pre-operative expenses) during the construction period. Further, expenditure incurred by the assessee on such BOT projects brings to it an enduring benefit in the form of right to collect the toll during the period of the agreement. Hon’ble Supreme Court in the case of Madras Industrial Investment Corporation Ltd. vs. CIT in 225 ITR 802 allowed spreading over of liability over a number of years on the ground that there was continuing benefit to the company over a period. Therefore, analogously, expenditure incurred on an infrastructure project for development of roads/highways under BOT agreement may be treated as having been made/incurred for the purposes of business or profession of the assessee and same may be allowed to be spread during the tenure of concessionaire agreement.

5. In view of above, Central Board of Direct Taxes, in exercise of the powers conferred under Section 119 of the Act hereby clarifies that the cost of construction on development of infrastructure facility of roads/highways under BOT projects may be amortized and claimed as allowable business expenditure under the Act.

6. The amortization allowable may be computed at the rate which ensures that the whole of the cost incurred in creation of infrastructural facility of road/highway is amortized evenly over the period of concessionaire agreement after excluding the time taken for creation of such facility.

7. In the case where an assessee has claimed any deduction out of initial cost of development of infrastructure facility of roads/highways under BOT projects in earlier year, the total deduction so claimed for the Assessment Years prior to the Assessment Year under consideration maybe deducted from the initial cost of infrastructure facility of roads/highways and the cost ‘so reduced’ shall be amortized equally over the remaining period of toll concessionaire agreement.

8. It is hereby clarified that this circular is applicable only to those infrastructure projects for development of road/highways on BOT basis where ownership is not vested with the assessee under the concessionaire agreement.

9. This may be brought to the notice of all concerned.

10. Hindi version to follow.

Source: Income Tax.

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Clarification regarding - Interpretation of Provisions of Section 10(2A) of the Income tax Act, 1961 in cases where income of the firm is exempt.

Circular No. 8/2014, F.No.173/99/2013-ITA-1, dated 30th March, 2014

Interpretation of Provisions of Section 10(2A) of the Income tax Act, 1961 in cases where income of the firm is exempt - Clarification Regarding.

A reference has been received in the Board in connection with the interpretation of provision of Section 10(2A) of the Income tax Act, 1961 (‘Act’) seeking clarification as to what will be the amount exempt in the hands of the partners of a partnership firm in cases where the firm has claimed exemption / deduction under Chapter III or VI A of the Act.

2. The matter has been examined. Sub Section (2A) of Section 10 was inserted by the Finance Act, 1992 w.e.f. 1.4.1993 due to a change in the scheme of taxation of partnership firms. Since assessment year 1993-94, a firm is assessed as such and is liable to pay tax on its total income. A partner is not liable to tax once again on his share in the said total income.

3. It is clarified that ‘total income’ of the firm for sub section (2A) of Section 10 of the Act, as interpreted contextually, includes income which is exempt or deductible under various provisions of the Act. It is, therefore, further clarified that the income of a firm is to be taxed in the hands of the firm only and the same can under no circumstances be taxed in the hands of its partners. Accordingly, the entire profit credited to the partners accounts in the firm would be exempt from tax in the hands of such partners, even if the income chargeable to tax becomes NIL in the hands of the firm on account of any exemption or deduction as per the provisions of the Act.

4. This may be brought to the notice of all concerned.

5. Hind version to follow.

Source: Income Tax - India.

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Income Tax – Regarding Ex-post facto extension of due date for filing TDS/TCS statements for FYs 2012-13 and 2013-14

Circular No. 07/2014, F. No. 275/27/2013-IT(B), dated 4th March, 2014

Ex-post facto extension of due date for filing TDS/TCS statements for FYs 2012-13 and 2013-14 – regarding.

The Central Board of Direct Taxes (‘the Board’) has received several petitions from deductors/collectors, being an office of the Government (‘Government deductors’), regarding delay in filing of TDS/TCS statements due to late furnishing of the Book Identification Number (BIN) by the Principal Accounts Officers (PAO) / District Treasury Office (DTO) / Cheque Drawing and Disbursing Office (CDDO). This has resulted in consequential levy of fees under section 234E of the Income-Tax Act, 1961(‘the Act’).

2. The matter has been examined. In case of Government deductors, if TDS/TCS is paid without production of challan, TDS/TCS quarterly statement is to be filed after obtaining the BIN from the PAOs / DTOs / CDDOs who are required to file Form 24G (TDS/TCS Book Adjustment Statement) and intimate the BIN generated to each of the Government deductors in respect of whom the sum deducted has been credited. The mandatory quoting of BIN in the TDS/TCS statements, in the case of Government deductors was applicable from 01-04-2010.

However, the allotment of Accounts Officers Identification Numbers (AIN) to the PAOs/ DTOs/CDDOs (a pre-requisite for filing Form 24G and generation of BIN) was completed in F.Y. 2012-13. This has resulted in delay in filing of TDS/TCS statements by a large number of Government deductors.

3. In exercise of the powers conferred under section 119 of the Act, the Board has decided to, ex-post facto, extend the due date of filing of the TDS/TCS statement prescribed under subsection

(3) of section 200 /proviso to sub-section (3) of section 206C of the Act read with rule 31A/31AA of the Income-tax Rules, 1962. The due date is hereby extended to 31.03.2014 for a

Government deductor and mapped to a valid AIN for –

(i) FY 2012-13 - 2nd to 4th Quarter

(ii) FY 2013-14 - 1st to 3rd Quarter

4. However, any fee under section 234E of the Act already paid by a Government deductor shall not be refunded.

5. Timely filing of TDS/TCS statements is essential to ensure timely reconciliation of Government accounts and for providing tax credit to the assessees while processing their Income-tax Returns. Therefore, it is clarified that the above extension is a one time exception in view of the special circumstances referred to above. Since the Government deductor and the associated PAO/ DTO/ CDDO belong to the same administrative setup that regulates the clearance of expenditure, the deductors/collectors may be advised to co-ordinate with the respective PAO/DTO/CDDO to ensure timely receipt of BIN/filing of TDS/TCS statements.

6. This circular may be brought to the notice of all officers for compliance.

7. Hindi version shall follow.

Source: Income Tax - India.

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Income Tax - Clarification regarding scope of Additional Income-Tax on Distributed Income under Section 115R of the Income Tax Act

Circular No. 06/2014, F.No. 225/182/2013-ITA.II, dated 11th February, 2014

Clarification regarding scope of Additional Income-Tax on Distributed Income under Section 115R of the Income-tax Act –regarding

Section 115R of the Income-tax Act, 1961 (‘Act’) provides for levy of additional income-tax on distributed income to unit holders (hereinafter referred to as ‘additional income-tax’).

2. It has been reported that some field authorities are taking a view that mutual funds/specified companies are required to pay additional income tax under sub-section (2) to section 115R of the Act not only on income distributed by way of dividend but also on payments made at the time of redemption/repurchase of units as well as at the time of allotment of bonus units to existing investors.

3. The matter has been examined by the Board. Section 115R is placed under Chapter XII-E of the Act, which is titled as “SPECIFIC PROVISIONS RELATING TO TAX ON DISTRIBUTED INCOME” and prescribes special provisions for taxing ‘distributed income’, which is not taxed under any other provisions of the Act.

4. Sub-section (2) of section 115R of the Act provides that any amount of income distributed by (i) a specified company, or (ii) a mutual fund to its unit holders shall be chargeable to tax and such entities shall be liable to pay additional income tax on such distributed income at the rates prescribed therein. The income so distributed by such entities is the dividend paid to the unit holders and is liable to tax under this section. However, redemption of units or repurchase of units would not attract levy of tax under sub-section (2) to section 115R of the Act as such income is not of the nature of income ‘distributed” to the unit holders and hence lies outside the purview of this section.

5. Further, the income so distributed by the mutual fund or specified company in the hands of the recipient unit holder is specifically exempt from tax under section 10(35) of the Act. Proviso to section 10(35) of the Act stipulates that exemption of income under this section is not applicable to those cases where transfer of units takes place. The recipient of such income is liable to pay capital gains tax, if applicable, on transfer of such units as per relevant provisions of the Act and shall not be subject to additional income tax under section 115R of the Act.

6. Similarly, bonus units at the time of issue would not be subjected to additional income tax under section 115R of the Act since issue of bonus units is not akin to distribution of income by way of dividend. This may be inferred from provisions of section 55 of the Act which prescribes that ‘cost of acquisition’ of bonus units shall he treated as nil for purposes of computation of capital gains tax.

7. In view of above position, Central Board of Direct Taxes, in exercise of its powers under section 119 of the Act hereby clarifies that additional income-tax under sub-section (2) of section 115R of the Act is to be levied on income distributed by way of dividend to unit-holders of mutual funds or specified companies and receipts from redemption/repurchase of units or allotment of additional units by way of bonus units would not be subjected to levy of additional income tax under that section.

8. This may be brought to the notice of all concerned.

9. Hindi version to follow.

Source: Income Tax - India.

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Income Tax – Clarification regarding disallowance of expenses under section 14A of the Income-tax Act

Circular No. 5/2014, F.No. 225/182/2013-ITA.II, dated 11th February, 2014

Clarification regarding disallowance of expenses under section 14A of the Income-tax Act in cases where corresponding exempt income has not been earned during the FY –regarding

Section 14A of the Income-tax Act, 1961 (`Act’) provides for disallowance of expenditure in relation to income not “includible” in total income.

2. A controversy has arisen in certain cases as to whether disallowance can be made by invoking section 14A of the Act even in those cases where no income has been earned by an assessee which has been claimed as exempt during the financial-year.

3. The matter has been examined in the Board. It is pertinent to mention that section 14A of the Act was introduced by the Finance Act, 2001 with retrospective effect from 01.04.1962. The purpose for introduction of section 14A with retrospective effect since inception of the Act was clarified vide Circular No. 14 of 2001 as under:

“Certain incomes are not includible while computing the total income, as these are exempt under various provisions of the Act. There have been cases where deductions have been claimed in respect of such exempt income. This in effect means that the tax incentive given by way of exemptions to certain categories of income is being used to reduce also the tax payable on the non-exempt income by debiting the expenses incurred to earn the exempt income against taxable income. This is against the basic principles of taxation whereby only the net income, i.e., gross income minus the expenditure, is taxed. On the same analogy, the exemption is also in respect of the net income. Expenses incurred can be allowed only to the extent they are relatable to the earning of taxable income”.

Thus, legislative intent is to allow only that expenditure which is relatable to earning of income and it therefore follows that the expenses which are relatable to earning of exempt income have to be considered for disallowance, irrespective of the fact whether any such income has been earned during the financial-year or not.

4. The above position is further clarified by the usage of term ‘includible’ in the Heading to section 14A of the Act and also the Heading to Rule 8D of I.T.Rules, 1962 which indicates that it is not necessary that exempt income should necessarily be included in a particular year’s income, for disallowance to be triggered. Also, section 14A of the Act does not use the word “income of the year” but “income under the Act”. This also indicates that for invoking disallowance under section 14A, it is not material that assessee should have earned such exempt income during the financial year under consideration.

5. The above position is further substantiated by the language used in Rule 8D (2(ii) & 8D (2)(iii) of I.T.Rules which are extracted below:

“(ii) in a case where the assessee has incurred expenditure by way of interest during the previous year which is not directly attributable to any particular income or receipt an amount computed in accordance with the following formula, namely:-

 A*B/C

Where……….

B= the average of value of investment, income from which does not or shall not form part of total income as appearing in the balance sheet of the assessee, on the first and last day of the previous year :

(iii) an amount equal to one-half percent of the average of the value of investment, income from which does not or shall not form part of the total income, as appearing in the balance-sheet of the assessee, on the first day and the last day of the previous year.”

(Emphasis added)

6. Thus, in light of above, Central Board of Direct Taxes, in exercise of its powers under section 119 of the Act hereby clarifies that Rule 8D read with section 14A of the Act provides for disallowance of the expenditure even where taxpayer in a particular year has not earned any exempt income.

7.  This may be brought to the notice of all concerned.

8. Hindi version to follow.

Source: Income Tax - India.

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Income Tax – Regarding Non-Filing of ITR-V in returns with refund claims - relaxation of time- limit for filing ITR-V and processing of such returns

Circular No. 04/2014, F.No. 225/198/2013-ITA.II, dated 10th February, 2014

Non-Filing of ITR-V in returns with refund claims-relaxation of time- limit for filing ITR-V and processing of such returns -regarding.

Several instances of grievances have come to the notice of the Board stating that a large number of returns-of-income for Assessment Year (‘AY’) 2009-2010, which were electronically filed without a digital signature in accordance with procedure laid down under the Income-tax Act, 1961(‘Act’), were not processed as such returns became non-est in law in view of Circular No. 3 of 2009 of CBDT dated 21.05.09. Paragraphs 9 and 10 of the said Circular laid down that ITR-V had to be furnished to the (Centralised Processing Centre (‘CPC’), Bengaluru by post within 30 days from the date of transmitting the data electronically and in case, ITR-V was furnished after the stipulated period or not furnished, it was deemed that such a return was never furnished. It was claimed by some of the taxpayers that despite sending ITR-V through post to CPC within prescribed time-frame, the same probably could not reach CPC and thus such returns became non-est. Since ITR-V was required to be sent through (ordinary) post at a ‘post box’ address, there were no despatch receipts with the concerned senders in support of their claim of having furnished ITR-V to CPC within prescribed time limit.

2. Subsequently CBDT extended the time-limit for filing ITR-V (relating to Income-tax returns filed electronically without digital signature for AY 2009-2010) upto 31.12.2010 or 120 days from the date of filing, whichever was later. It also permitted sending of ITR-V either by ordinary or speed post to the CPC. However, for the AY 2009-10, some cases were still reported where return was declared non-est due to non-receipt of ITR-V by CPC even within such extended time-frame and consequently the refund so arising continue to remain held up.

3. Likewise, for AY’s 2010-11, and 2011-12, though relaxation of time for furnishing ITR-V was granted by Director General of Income Tax (systems), it has been noticed that a large number of such electronically filed returns still remain pending with Income-tax Department for want of receipt of valid ITR-V Certificate at CPC.

4. The matter has been examined. In order to mitigate the grievances of the taxpayers pertaining to non-receipt of tax refunds, Central Board of Direct Taxes, in exercise of powers under section 119(2)(a) of the Act, hereby further relaxes and extends the date for filing ITR-V Form for Assessment years 2009-10, 2010-11 and 2011-12 till 31.03.2014 for returns e-Filed with refund claims within the time allowed under section 139 of the Act The taxpayer concerned may send a duly signed copy of ITR-V to the CPC by this date by Speed post. In such cases, central Board of Direct Taxes also relaxes the time-frame of issuing the intimation as provided in second proviso to sub section (1) of section 143 of the Act and directs that such returns shall be processed within a period of six months from end of the month in which ITR-V is received and the intimation of processing of such returns shall be sent to the assessee concerned as per laid down procedure.

5. Provision of sub-section (2) of section 244A of the Act would apply while determining the interest on such refunds.

6. The taxpayer concerned may ascertain whether ITR-V has been received in the CPC, Bengaluru or not by logging on the website of Income-tax Department – http://incometaxefiling.gov.in/e-Filing/Services/ITR-VReceipt Status.html by entering PAN No. and Assessment year or e-Filing Acknowledgement Number. Alternatively’ status of ITR-V could also be ascertained at the above website under ‘Click to view Returns/Forms’ after logging in with registered e-Filing account. In case ITR-V has not been received within the prescribed time’ status will not be displayed and further steps would be required to be taken as mentioned above.

7. Hindi version to follow.

Source: Income Tax - India.

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Explanatory Notes to the provisions of the Finance Act, 2013

Circular No.03/2014, F. No. 142/24/2013-TPL, dated 24.01.2014

Explanatory Notes to the provisions of the Finance Act, 2013

            Amendments at a Glance:

Section/Schedule		Particulars/Paragraph number
Finance Act, 2013
First Schedule		Rate Structure, 3.1 - 3.4
Income-Tax Act, 1961
2	Change in the definition of capital asset, 4.1-4.5
10	·         Change in the definition of keyman insurance policy, 5.1 – 5.5; ·         exemption to income of investor Protection Fund of depositors, 6.1-6.3 ; ·         pass through status to certain Alternative Investment Funds, 7.1 – 7.4; ·         exemption of income received in India in Indian currency by a foreign company, 8.1 – 8.4; ·         Exemption to National Financial Holdings Company Limited, 9.1 – 9.3.
Insertion of new section 32AC	Incentive for acquisition and installation of new plant or machinery by manufacturing company, 10.1-10.4.
36	Clarification for amount to be eligible for deduction as bad debts in case of banks, 11.1 - 11.8.
40	Disallowance of certain fee, charge, etc. in case of State Government Undertakings, 12.1 - 12.3.
Insertion of new section 43CA	Computation of income under the head “profits and gains of business or profession” for transfer of immovable property in certain cases, 13.1 – 13.4.
56	Taxability of immovable property received for inadequate consideration, 14.1 – 14.4.
80C	Raising of limit of percentage of eligible premium for life insurance policies of persons with disability or disease, 15.1 – 15.6.
80CCG	Expanding the scope and deduction and its eligibility under the section, 16.1 - 16.5.
80D	Deduction for contribution to Health Schemes similar to Central Government Health Scheme (CGHS), 17.1 -17.3.
Insertion of new section 80EE	Deduction in respect of interest on loan sanctioned during financial year 2013-14 for acquiring residential house property, 18.1 – 18.4.
80G	One hundred per cent deduction for donation to National Children‘s Fund, 19.1- 19.4.
80GGB & 80GGC	Contribution not to be in cash for deduction under section 80GGB & 80GGC, 20.1 – 20.3.
80-IA	Extension of the sunset date under the section for the power sector, 21.1 – 21.3.
80JJAA	Deduction for additional wages in certain cases, 22.1 – 22.6.
87 and Insertion of new section 87A	Rebate of 2000 for individuals having total income up to Rs. 5 lakh, 23.1 – 23.4.
90 and 90A	Tax Residency Certificate, 24.1-24.5.
Omission of Chapter X-A relating to general Anti Avoidance Rule and Insertion of new Chapter X-A, omission of section 144BA and insertion of new section 144BA, amendment of sections 144C, 153D, 245N, 245R, 246A, 253 and 295	General Anti Avoidance Rule (GAAR), 25.1-25.5.
115A	Taxation of income by way of Royalty or fees for technical services, 26.1 - 26.4.
115BBD	Lower rate of tax on dividends received from foreign companies, 27.1 – 27.3.
115-O	Removal of the cascading effect of Dividend Distribution Tax (DDT), 28.1 – 28.5.
Insertion of new Chapter XII-DA	Additional income-tax on distributed income by company for buy-back of unlisted shares, 29.1 – 29.4.
115R	Rationalisation of tax on distributed income by the Mutual Funds, 30.1 – 30.5.
Insertion of new Chapter XII-EA	Taxation of securitisation trusts, 31.1 - 31.4.
132B	Application of seized assets, 32.1 – 32.3.
138	Replacement of terms “Foreign Exchange Regulation Act, 1947” and “Foreign Exchange Regulation Act, 1973” with “Foreign Exchange Management Act, 1999”, 33.1 – 33.4.
139	Return of income filed without payment of self-assessment tax to be treated as defective return, 34.1- 34.3.
142	Direction of special audit under sub-section (2A) of the section, 35.1 – 35.3.
153 and 153B	·         Exclusion of time I computing the period of limitation for completion of assessments and reassessments, 36.1 – 36.6; ·         Time limit for completion of assessment or reassessment where reference is made to the transfer pricing officer, 37.1 – 37.6.
167C and 179	Clarification of the phrase “tax due” for the purposes of recovery in certain cases, 38.1 – 38.3.
Insertion of new section 194-IA	Tax Deduction at Source (TDS) on transfer of certain immovable properties (other than agricultural land), 39.1-39.6.
Insertion of new section 194LD, amendment of sections 115AD, 195 and 196D	Income by way of interest on certain bonds and Government securities, 40.1 – 40.2.
204	Meaning of person “responsible for paying” under Chapter XVII, 41.1 – 41.4.
206AA	Exemption from requirement of furnishing PAN under section 206AA to certain non-resident bond holder, 42.1 -42.3.
206C	Removal of exemption from levy of Tax Collection at Source (TCS) to cash sale of any coin or any other article weighing 10 grams or less, 43.1 – 43.2.
252	Appointment of President of the Appellate Tribunal, 44.1 – 44.4.
Substitution of new section for section 271FA	Penalty under section 271FA for non-filing of Annual Information Return, 45.1 – 45.5.
Fourth Schedule	Extension of time for approval, 46.1 – 46.5.
Wealth-tax Act, 1957
2	Change in the definition of capital asset; exemption from wealth tax to agricultural land situated in urban area, 47.1 – 47.3.
Insertions of new sections 14A and 14B and amendment of section 46	Enabling provisions for facilitating electronic filing of annexure-less return of net wealth, 48.1 - 48.4.
Finance (No.2) Act, 2004
Section 98 of the Finance (No.2) Act, 2004	Rationalisation of securities transaction tax rates, 49.1 – 49.3.
Chapter VII, Finance Act, 2013
Chapter VII of the Finance Act, 2013 and amendment in sections 36 and 43 of the Income-tax Act, 1961	Commodities Transaction Tax, 50.1 – 50.6.2.

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Click hereto view the complete text of above Circular - Circular No.03/2014, dated 24.01.2014.

Source: Income Tax Department- India.

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