ACCOUNTING, REGULATORY & Vol 36

January, 2020
www.bdo.in
TAX NEWSLETTER

TABLE OF CONTENTS

Accounting Updates 01

Regulatory Updates 03

Tax Updates

Direct Tax 07

Transfer Pricing 09

Indirect Tax 10

BDO India Newsletter

01 BDO India Newsletter
ACCOUNTING UPDATES
INSTITUTE OF CHARTERED ACCOUNTANTS OF INDIA (“ICAI”)
EAC Opinion – Accounting Treatment of Expenditure
Relating to Employee Benefits Expenses, Rent Expenses,
Travelling Expenses and House-keeping Expenses which are
Compulsorily Required to be Incurred for Construction of
the Project
Facts of the case
The querist has sought the opinion of the Expert Advisory
Committee of the Institute of Chartered Accountants of
India (ICAI) on accounting treatment of expenditure for
construction of Highspeed Rail project by the company,
which as per the querist, are directly related expenditure
and without incurrence of which construction of rail
project cannot take place.
The matter under discussion is the accounting treatment of
expenditure related to the following expenses –
▪ Employee benefits expenses
▪ Rent expenses
▪ Travelling expenses
▪ Housekeeping expenses
On approval of the construction project by the Cabinet, a
public limited company was incorporated in India under the
provisions of the Companies Act, 2013 with the objective to
plan, design, develop build, commission, maintain, operate
and finance high speed rail services between the state of
Maharashtra and state of Gujarat. The company is engaged
in the one and only activity of creation of self-constructed
assets i.e. i.e., Bullet Train Project between the State of
Maharashtra and State of Gujarat.
During the financial year 2017-18, the registered
office/head office of company at New Delhi and site offices
in the states of Gujarat and Maharashtra have been taken
on rent; and all the project executing team including
directors are sitting at the head office and site offices and
executing their work from respective locations.
All the details data about the expenses mentioned above
has been provided by the company which includes the
amount, nature and extent.
The querist has further informed that the company has
capitalised the expenses as incidental project expenditure
under the head capital work in progress (CWIP) in line with
its accounting policy as follows.
“Expenditure which can be directly identified with the
Project undertaken by the company is debited to ‘Capital
Work in Progress’ under ‘Direct Project Expenditure’.
Indirect expenditure in the nature of employee benefits
and indirect expenditure directly related to the project has
been charged to project.”
Observations were raised that CWIP should not include
administrative costs and other general overhead costs.
These should be expensed out in profit and loss statement
instead the same has been capitalised resulting in
overstatement of CWIP.
The management responded to the observation with
reference to Ind AS 16 “Property Plant and Equipment”
(INDAS 16), stating that the same is applicable to a
company already operating and going for expansion
either by a new product/Service or business in new
location by new facility. In these three situations para
19(d) of IND AS 16 becomes relevant that does not allow
administrative cost and general overhead cost to be
added to CWIP.
Management responded that as per Para 17 of the IND AS
16, cost of employee benefits arising directly from the
construction or acquisition of the item of PPE is a direct
cost. Other expenses like rent, maintenance of head
office, travels, training all are only for one project, i.e.,
bullet train project; there are no other activities of the
company. These expenses would not have been incurred
if bullet train project was not the objective of the
company. Therefore, in view of the requirements of
paragraph 22 of Ind AS 16, the company has rightly
charged general and administrative overheads to the
CWIP.
The Company stated that it would refer the accounting
treatment to Expert Advisory Committee and also raised
the following points for consideration of the Expert
Advisory Committee
▪ Rail Project is the only project, the company is
presently executing and all the functions of the
company at corporate office /site offices are related
to this single project only.
▪ These are the expenditure without incurrence of
which the construction of the rail project cannot take
place and the project cannot be brought to its
working condition.
▪ These expenses are directly attributable to rail
project and are required to be incurred only for
execution of the rail project and not otherwise.
Query:
Whether the accounting treatment of the said employee
benefits expenses, rent expenses, travelling expenses
and housekeeping expenses which are incurred for the
rail project, as disclosed by the company is correct. If
not, what should be the treatment in the opinion of the
committee as per the Ind AS 16, Property, Plant and
equipment and other applicable INDAS.
Points taken into consideration:
The Committee notes that the basic principle to be
applied while capitalising an item of cost to a property,
plant and equipment (PPE) is that it is directly
attributable to bringing the asset to the location and
condition necessary for it to be capable of operating in
02 BDO India Newsletter

ACCOUNTING UPDATES
the manner intended by management.
The Committee pointed out that the contention of the
querist relating to applicability of paragraph 19(d) of Ind AS
16 is not correct. Paragraph 19 (d) is applicable to all the
entities irrespective of whether it is a new one or an
existing one.
Accordingly, the Committee is of the view that the
expenditure on employee benefits, rent expenses,
travelling expenses and house-keeping expenses incurred by
the company can be capitalised only if these can be
considered as directly attributable cost to bringing the
bullet train project or the related asset(s) to the location
and condition necessary for it (them) to be capable of
operating in the manner intended by the management.
Opinion:
Basis the points discussed above, the committee is of the
following opinion on the issues raised –
• The employee benefit expenses in respect of project
associated departments are apparently directly
attributable costs and therefore can be capitalised with
the cost of project. In respect of employee benefit
expense of finance dept, normally they are not
considered as direct cost, but are considered as
administrative and general overheads and therefore
should not be capitalised. In certain exceptional
circumstances, where the finance dept is engaged in the
construction activity, the cost will be considered as
directly attributable cost and will be capitalised. The
same would apply for the cost of Managing Director as
well. Further, the employee benefit expenses of HR
department and company law department cannot be
considered as directly attributable cost.
• The rent expenses related to the site offices is
considered as direct cost and can be capitalized to CWIP
till the time the item of PPE is in the location and
condition necessary for it to be capable of operating.
The rent expense of head office should not be
considered as cost of the project. However, if the
project execution related activity are also being
performed at head office resulting into directly
attributable cost and these can be ascertained on a
reasonable and reliable basis, then only to that extent,
rent should be capitalized as the cost of the project.
• The travelling expense is required to be treated basis
the nature and purpose of such expenses and the extent
to which these expenses are directly attributable to the
construction of the train project.
• The housekeeping expenses are purely in the nature of
administration expenses as given in para 19(d) of Ind AS
16, which cannot be considered as directly attributable
cost of construction of the rail project and therefor,
these cannot be capitalized as cost of an item of PPE.
03 BDO India Newsletter

REGULATORY UPDATES

SECURITIES AND EXCHANGE BOARD OF INDIA (SEBI)

Circular dated 16th December 2019: Management and
advisory services by AMCs to Foreign Portfolio Investors
(‘FPI’)
SEBI Mutual Fund (MF) Regulations and the notification of
FPI Regulations pertaining to “restrictions on business
activities of the asset management company” was amended
and notified in the Gazette dated 23rd September 2019.
Consequent to the same, it was decided that AMCs may
provide management and advisory services to FPIs falling
under the following categories of FPIs as specified in FPI
Regulations:
▪ Government and Government related investors such as
central banks, sovereign wealth funds, international or
multilateral organizations or agencies including entities
controlled or at least 75% directly or indirectly owned
by such Government and Government related
investor(s);
▪ Appropriately regulated entities such as pension funds,
insurance or reinsurance entities, banks and mutual
funds;
▪ Appropriately regulated FPIs wherein (a) or (b) above
hold more than 50% of shares/ units.
Further, for agreements entered into by the AMCs on or
before the date of this Circular, to provide management
and advisory services to such FPIs which are not falling
under the above categories, the AMCs may continue to
provide the services, for the period as mentioned in the
agreement or one year from the date of this Circular,
whichever is earlier.
The provision stating that AMC shall appoint separate fund
manager for each separate fund managed by it unless the
investment objectives and asset allocation are same and
the portfolio is replicated across all the funds managed by
the fund manager, within a period of six months from the
date of notification of Securities and Exchange Board of
India (Mutual Funds) (Amendment) Regulations, 2011, shall
be applicable for the categories of FPIs as mentioned
above.
Circular dated 24th December 2019: Format on Statement
of Deviation or Variation for proceeds of public issue, rights
issue, preferential issue, Qualified Institutions Placement
(‘QIP’) etc.
This circular is applicable to all entities who have their
specified securities listed and to all recognized stock
exchanges.
SEBI has prescribed the format for Statement of Deviation
or Variation for proceeds of public issue, rights issue,
preferential issue, Qualified Institutions Placement (QIP)
etc., as required under Regulations 32 of SEBI (Listing
Obligations and Disclosure Requirements) Regulations, 2015
(‘SEBI LODR Regulations’).
Regulation 32 of SEBI LODR Regulations mandates every listed
entity to submit a statement of deviation or variation, on
quarterly basis, on the use of proceeds raised from the public
issue, rights issue, preferential issue, Qualified Institutions
Placement (QIP) etc., as against the objects as stated in the
offer document or explanatory statement to the notice for the
general meeting, as applicable.
However, ever since the applicability of SEBI LODR Regulations,
no format for the said statement of deviation was specified in
any of the provisions. All the listed entities were making
disclosure under Regulation 32 in different formats on
quarterly basis. Hence all the listed entities are now required
to adhere to the format as specified in this circular.
Below are the salient features of the common format for
statement of deviation and variation:
▪ Applicability: The format shall be applicable for funds
raised by listed entities through public issue, rights issue,
preferential issue, QIPs etc from the quarter ending 31st
December 2019 and subsequent quarters
▪ Frequency of Disclosure: The disclosure shall be made on
quarterly basis along with the declaration of financial
results (within 45 days of end of each quarter / 60 days
from the end of the last quarter of the financial year)
▪ Role of the Audit Committee: The statement of deviation
report shall be placed before audit committee of the listed
entity for review on quarterly basis and after such review,
the comments of audit committee along with the report
shall be disclosed/submitted to the stock exchange, as part
of the format
Further, in cases where the listed entity is not required to have
an audit committee under the provisions of SEBI LODR
Regulations or Companies Act, 2013, the word ‘Audit
Committee’ shall be replaced with ‘Board of Directors’.
04 BDO India Newsletter
REGULATORY UPDATES
Circular dated 24th December 2019: Guidelines for filing of
placement memorandum – Infrastructure Investment Trusts
(InvITs)
SEBI vide its circular has issued guidelines to the InvITs
which are issuing units on private placement basis that are
proposed to be listed, which are as follows:
The units of InvITs which are issued by way of private
placement and are proposed to be listed, shall file a draft
placement memorandum with the Board and stock
exchange(s) through a merchant banker registered with the
Board, not less than thirty days prior to opening of the
issue.
The draft placement memorandum shall contain specified
disclosures and the merchant banker shall submit a due
diligence certificate as prescribed along with the draft
placement memorandum.
SEBI may issue observations, if any, on the draft placement
memorandum within fifteen working days from the date on
which the last of the following event occurs:
▪ the date of receipt of the draft placement
memorandum by the Board; or
▪ the date of receipt of satisfactory reply from the issuer
and/or merchant banker to the issue; or
▪ the date of receipt of clarification or information from
any regulator or agency; or
▪ the date of receipt of a copy of in-principle approval
letter issued by the stock exchange(s)
The merchant banker to the issue, shall ensure that all
comments are suitably incorporated prior to filing, in terms
of InvIT Regulations along with a due diligence certificate
as prescribed.
The Circular shall come into effect from January 15, 2020
MINISTRY OF CORPORATE AFFAIRS (“MCA”)
Extension of last date of filing Form PAS-6
MCA vide its circular dated 28th November 2019 has
extended the last date of filing of Form PAS-6 (Filing of
Private Placement Offer Letter) without any additional fees
for the half-year ended on 30th September 2019. The
extended due date will be sixty days from the date of
deployment of form PAS-6 on the website of the Ministry
Extension of last day of filling Form NFRA-2
MCA vide its circular dated November 27, 2019 has
extended the last date for filling Form NFRA -2, which is
required to be filed under rule 5 of the National Financial
Reporting Authority Rules, 2018. The time limit for filling
Form NFRA-2 is 90 days from the date of deployment of the
from on the website of the National Financial Reporting
Authority (NFRA). Form NFRA-2 was deployed on the website
of NFRA on December 9, 2019. Hence, the last date for
filling Form NFRA-2 will be March 8, 2020.
INSURANCE REGULATORY AND DEVELOPMENT AUTHORITY
Guidelines for investment in Debt ETFs with CPSE Bonds as
Underlying
The IRDA (Investment) Regulations, 2016 read along with
investments – Master Circular dated 3rd May 2017 issued
thereunder, permits insurers to invest in various exhaustive
Asset categories. In this regard, the IRDA vide its circular
dated 11th December 2019, has permitted Debt ETFs with
underlying Debt Securities of Central Public Sector
Enterprises (CPSEs) [herein after referred to as Debt ETFs]
proposed to be launched in India, as an eligible class of
Investment by insurers to be classified under "Mutual Fund"
exposure.
All exposure and prudential norms applicable for
investments in mutual funds covered under Para 1.3 of the
Master Circular – Investment shall apply for the investment
made in Debt ETF’s in addition to the following conditions.
▪ The debt ETFs shall be issued by the Mutual Fund
registered with SEBI and governed by SEBI (Mutual Fund)
regulations, 1996, as amended from time to time.
▪ The debt ETF shall invest in a basket of securities issued
by CPSEs which are part of constituents of a publicly
available index.
▪ The Minimum investment by the Insurer shall not be less
than Creation Unit Size and it shall not be reduced to
below Creation Unit Size.
▪ All Securities in the Index shall be complied with the
rating criteria as per Regulation 3 of IRDAI (Investments)
Regulation, 2016 for it to be a part of “Approved
Investment”. If any of the underlying securities gets
downgraded below “AA”, the debt ETF shall be
automatically reclassified under “Other Investments”.
INSTITUTE OF CHARTERED ACCOUNTANT OF INDIA
Advisory on SEBI Circular
SEBI has issued a circular dated 29th March 2019 regarding
procedures and formats for limited review/ Audit report of
the listed entity and those entities whose accounts are to
be consolidated with the listed entity.
Exhibit B3 of the circular pertains to “Independent Auditor’s
Review Report on review of Consolidated Unaudited
05 BDO India Newsletter
REGULATORY UPDATES
Quarterly and year to date Financial results for Banks.”.
Exhibit B3 requires quantification of the following items
with respect to branches of banks –
▪ Total Assets
▪ Total Revenue
▪ Total Net Profit/(Loss) after tax
▪ Cash flow (Net)
Due to implementation challenges faced by the members,
as per the advisory issued by ICAI on Exhibit B3 of SEBI
Circular dated 29th March 2019, reporting on net
profit/(loss) after tax and cash flows of branches need not
be made if such details are not contained in the financial
statements received from the branches
This advisory will come into force from immediate effect.
INSOLVENCY AND BANKRUPTCY CODE (“IBC”)
The Insolvency and Bankruptcy Code (Amendment)
Ordinance, 2019
IBBI pursuant to its order dated 28th December 2019 has
amended the Insolvency and Bankruptcy Code (Amendment)
Ordinance, 2019
The key amendments are as stated below:
▪ The provision to determine the insolvency
commencement date as the date on which the interim
resolution professional is appointed by the adjudicating
authority in case the interim resolution professional is
not appointed in the order admitting application, has
been removed
▪ Application for initiation of corporate insolvency
resolution process against the corporate debtor by the
following financial creditors:
− Trustee or agent acting as authorized representative
of financial creditor or class of creditor exceeding
the specified number
− allottees under a real estate project shall be filed
jointly by not less than one hundred of such
creditors in the same class or not less than ten per
cent of the total number of such creditors in the
same class, whichever is less. All such applications
not yet been admitted by the adjudicating authority
before commencement of this ordinance shall
comply with the above conditions within 30 days to
avoid its withdrawal
▪ Clarification has been provided about persons not
entitled to make an application that a corporate debtor
can initiate corporate insolvency resolution process
against another corporate debtor
▪ A license, permit, registration, quota, concession,
clearance or a similar grant or right given by the Central
Government, State Government, local authority, sectoral
regulator or any other authority constituted under any
other law for the time being in force, shall not be
suspended or terminated on the grounds of insolvency,
subject to the condition that there is no default in
payment of current dues arising for the use or
continuation of the license or a similar grant or right
during moratorium period
▪ Where the interim resolution professional or resolution
professional, as the case may be, considers the supply of
goods or services critical to protect and preserve the
value of the corporate debtor and manage the
operations of such corporate debtor as a going concern,
then the supply of such goods or services shall not be
terminated, suspended or interrupted during the period
of moratorium, except where such corporate debtor has
not paid dues arising from such supply during the
moratorium period or in such circumstances as may be
specified
▪ Condition to appoint an interim resolution professional
by the Adjudicating Authority within 14 days from the
insolvency commencement date has been deleted
▪ Provision for the resolution professional to manage the
operations of the corporate debtor after the expiry of
the corporate insolvency resolution process period, until
an order approving the resolution plan appointing a
liquidator is passed by the Adjudicating Authority has
been inserted
▪ The liability of a corporate debtor for an offence
committed prior to the commencement of the corporate
insolvency resolution process shall cease and the
corporate debtor shall not be prosecuted for such an
offence from the date the resolution plan approved by
the Adjudicating Authority, also no action shall be taken
against the property of the corporate debtor in relation
to an offence committed prior to the commencement of
the corporate insolvency resolution process of the
corporate debtor, which results in change in the
management or control of the corporate debtor or sale
of liquidation assets under the provisions of IBC to a
person who was not:
− a promoter or in the management or control of the
corporate debtor or a related party of such a person;
or
06 BDO India Newsletter

REGULATORY UPDATES
− a person with regard to whom the relevant
investigating authority has, on the basis of material in
its possession, reason to believe that he had abetted or
conspired for the commission of the offence, and has
submitted or filed a report or a complaint to the
relevant statutory authority or Court
▪ If a prosecution had been instituted during the corporate
resolution process against such corporate debtor, it shall
stand discharged from the date of approval of the
resolution plan subject to fulfillment of specified
requirements
▪ However, every person who was a “designated partner” as
defined in Limited Liability Partnership Act, 2008 or an
“officer who is in default”, as defined under Companies
Act, 2013, or was in any manner in-charge of, or
responsible to the corporate debtor for the conduct of its
business or associated with the corporate debtor in any
manner and who was directly or indirectly involved in the
commission of such offence as per the report submitted or
complaint filed by the investigating authority, shall
continue to be liable to be prosecuted and punished for
such an offence committed by the corporate debtor
notwithstanding that the corporate debtor’s liability has
ceased
▪ The insolvency and liquidation proceedings for financial
service providers or categories of financial service
providers may be conducted with such modifications and
in such manner as may be prescribed
07 BDO India Newsletter

TAX UPDATES
Direct Tax
CIRCULARS/ NOTIFICATIONS/PRESS RELEASE
Extension of deadline for Aadhaar-PAN linking
The Central Government has further extended the deadline
for linking Aadhaar Number with Permanent Account
Number (PAN) from 31 December 2019 to 31 March 2020.
[Notification No. S.O. 4708(E) [NO.107/2019
[F.NO.225/75/2019-ITA.II), dated 30 December 2019]
Extension of due date for payment of tax under Income
Declaration Scheme, 2016 (IDS)
The Central Government has extended the due date upto
31 January 2020 for payment of taxes, surcharge and
penalty in respect of the persons who have made a
declaration of undisclosed income under IDS but have not
made a payment of tax, surcharge and penalty on the
undisclosed income. However, such persons are liable to
pay interest computed at the rate of one percent for every 10DA (CA report) along with the tax return. In line with the
month or part of a month for the period commencing on amended provisions, the Central Board of Direct Taxes (CBDT)
the date immediately following the prescribed due dates1 has revised Form 10DA which shall now require following
and ending on the date of actual payment of tax, surcharge additional information:
and penalty. ▪ Data on number additional eligible employees employed in
[Notification No. S.O. 4455(E) [NO. 103/2019 (F.NO. the immediately preceding previous year (this is in light of
370149/159/2019-TPL), dated 13 December 2019] of second proviso to explanation (ii) to section 80JJAA)
Electronic modes for acceptance of payments prescribed. ▪ Amount of emoluments paid or payable to additional
With an intent to encourage electronic payments, section eligible employees as prescribed by point (a) above.
269SU was inserted by the Finance (No.2) Act 2019 ▪ Amount of deduction eligible under section 80JJAA in
(Finance Act). As per this section, every person having a
respect of payments of the emoluments to the additional
business turnover of more than INR 500 million is
mandatorily required to provide facilities for accepting employee in respect of:
payments through prescribed electronic modes. In case a − The immediately preceding year to the fiscal year; and
person fails to provide such facilities, a penalty of INR − The year prior to the immediately preceding fiscal
5,000 per day of default could be levied. Recently, Rule
year.
119AA has been inserted in the Income Tax Rules, 1962 (IT
Rules) with effect from 1 January 2020 to provide that [Notification No. 104/2019 (G.S.R. 937(E), (F.NO.
following type of payments as the prescribed electronic 370142/28/2019-TPL), dated 18 December 2019]
modes of payment: Framing of rules with respect to fund manager regime under
▪ Debit Card powered by Rupay; section 9A of the IT Act.
▪ Unified Payments Interface (UPI) (BHIM-UPI); and Section 9A of the IT Act provides for a special taxation regime
in respect of certain offshore funds in context of their fund
▪ Unified Payments Interface Quick Response Code (UPI
managers being located in India. These provisions provide
QR Code) (BHIM-UPI QR Code). that in case of an eligible investment fund, the fund
[Notification No. 105/2019 (G.S.R. 960(E), (F.NO. management activity carried out through an eligible fund
370142/35/2019-TPL) read with Circular No. 32/2019, manager acting on behalf of such fund shall not constitute
business connection in India of the said fund. Further, it is
(F.NO. 370142/35/2019-TPL), dated 30 December 2019]
provided that an eligible investment fund shall not be said to
Amendment of Rule 19AB under section 80JJAA of the IT be resident in India merely because the eligible fund manager
Act. undertaking fund management activities on its behalf is
located in India subject to the conditions mentioned in
Section 80JJAA of the IT Act provides for deduction in section 9A(3), one of which [clause (m) of said sub-section]
respect of additional workforce. For claiming this provides that the remuneration paid by the fund to an eligible
deduction, the taxpayer is required to submit Form No. fund manager in respect of fund management activity

1As notified vide Notification No. S.O. 2476(E) [No.59/2016, F.No.142/8/2016-TPL]

08 BDO India Newsletter
TAX UPDATES
Direct Tax
undertaken by him on its behalf is not less than the arm's
length price of the said activity. Finance Act with effect
from 1st April, 2019, inter alia, amended clause (m) of
section 9A(3) so as to provide that the remuneration paid
by the fund to an eligible fund manager in respect of fund
management activity undertaken by him on its behalf shall
not be less than the amount calculated in a prescribed
manner. CBDT has issued a draft notification to amend Rule
10V to Rule 10VB of the IT Rules for public consultation.
The various computational mechanism proposed are as
under
▪ where the fund is such Category-I foreign portfolio
investor as is referred to in item (i), item (ii) or item
(iii), and sub-item III of item (iv) of clause (a) of section
5 of the Securities and Exchange Board of India (Foreign
Portfolio Investors) Regulations, 2019, made under the
Securities and Exchange Board of India Act, 1992 (15 of
1992) - 0.1 per cent, of the assets under management of
said fund which is managed by the fund manager.
▪ in any other case, the amount shall be,
− 0.30 per cent of the assets under management of
said fund which is managed by the fund manager, or
− 10 per cent of the profits derived by the fund in
excess of the specified hurdle rate from the fund
management activity, where the fund manager is
entitled to remuneration linked to profits derived by
the Fund; or
− 50 per cent of the net management fee (i.e.
management fee as reduced by the amount incurred
towards operational expenses including distribution
expenses, if any)
The draft notification has also suggested for making an
application to Central Board of Direct Taxes for seeking
approval in case of remuneration lower than the above
prescribed mechanism for the purposes of section 9A(3)(m).
Appropriate new forms / changes in the Forms are also
proposed.
[CBDT Press Release (F.NO.142/15/2015-TPL), dated 5
December 2019]
JUDICIAL UPDATES
Exemption of interest in respect of foreign currency
borrowing is extended to indirect utilization.
Taxpayer, a private limited company, had taken a foreign
currency loan (FC loan) from a foreign company. The said
loan was used to repay working capital loan taken by the
Taxpayer from a domestic lender. Taxpayer had not deducted
withholding tax on the interest payment for FC loan on
account of specific exemption under section 10(15)(iv)(f) of
the IT Act. During the revenue audit, the Tax Officer
disallowed the interest on FC Loan under section 40(a) of the
IT Act on the ground that the Taxpayer had not withheld tax
on such interest. The Taxpayer’s contention of exemption
under section 10(15)(iv)(f) of the IT Act in respect of interest
payable by an industrial undertaking on moneys borrowed (for
industrial development in India) in foreign currency from
sources outside India under a loan agreement approved by the
Central Government was rejected by the Tax Officer. On an
appeal before the Hon’ble High Court(‘HC’) , , after hearing
contention of Tax Officer as well as Taxpayer, it was held
that the words in section 10(15)(iv)(f) of the IT Act are not
"for industrial development", but the words "having regard to
the need for industrial development in India", which are
wider in nature. These words are wide enough to cover within
its ambit and include even the indirect utilisation of the
funds for industrial development in India. Therefore, even if
the loan taken as working capital loan from domestic lender
earlier and employed by the Taxpayer for such industrial
development and thereafter the FC loan was availed to repay
such earlier loan, the exemption given in section 10(15)(iv)(f)
of the IT Act in favour of the Taxpayer cannot be said to have
cease to exists.
[Commissioner of Income Tax-Chennai vs M/s Seven Seas
Distillery (Pvt) Ltd, Tax Case (Appeal) No.2025 of 2008
(High Court)]
09 BDO India Newsletter

TAX UPDATES
Transfer Pricing
JUDICIAL UPDATES
Income covered by tonnage tax scheme is not covered under
Deletion of TP-adjustment for interest accrued on loan
TP-provisions
The taxpayer is engaged in the business of production of
The taxpayer is a company engaged in the business of
software products and provision of software development
executing dredging contracts and its parent company is
services for the communication industry. The Chinese law
incorporated in Netherlands. The taxpayer had filed a return
prohibits accrual of any interest on loan once the application
of income under Tonnage Tax Scheme. During the course of
has been made with the Chinese authorities for the repayment
the assessment, the assessing officer (AO) made a reference
of loan. Accordingly, the taxpayer did not accrue and charge
to the transfer pricing officer (TPO), to compute arm’s length
any interest on foreign currency loan provided to its AE in
price of the international transaction. The TPO made an
China. The lower tax authority disregarded the taxpayer’s
adjustment for head office expenses paid by the taxpayer to
plea and subsequently made an upward adjustment. The issue
its associated enterprise. The lower tax authority upheld this
under consideration is whether any interest must be accrued
adjustment. The tax tribunal while referring to its earlier
on loan till the application for repayment of loan is sanctioned
order for the same taxpayer, held that Section 115JB is a code
by the Chinese authorities. The Tax Tribunal opines that once
in itself and provides its own method of computation which
the law of China provides for no accrual of interest in the
does not depend on actual receipts or expense. Hence, it is a
contracting state then there is no merit in holding the accrual
presumptive scheme of taxation. The Tax Tribunal also held
of income in the hands of the taxpayer and hence the
that, the AO had made an error as Section 92 is not a charging
adjustment of the lower tax authority must be reversed.
section in itself but merely a mechanism for computing tax
Aricent Technologies Holdings Ltd [TS-1132-ITAT- and no reference to the transfer pricing officer should have
2019(DEL)-TP] been made under section 92 CA in the first place. Considering
Sub licensed royalty considered as valid internal cup for all the above facts, the tax tribunal held that transfer pricing
royalty benchmarking provisions would not apply to the taxpayer.
Van Oord India Private Limited [TS-1105-ITAT-2019
The taxpayer, a wholly owned subsidiary, is engaged in the
(Mum)-TP]
business of running a research and development center to
identify potential drug development candidates and in
preliminary testing of the same. The taxpayer is also engaged
in licensing and sub licensing of drugs, drug design and
maintenance of IT infrastructure. The taxpayer has made
royalty payments to its AE during the year under consideration
although there was no written agreement between the
taxpayer and its AE for the same. The lower tax authorities
contended that in the absence of any formal written
agreement between the taxpayer and the AE, Nil royalty
payment must be considered as the arm’s length price of the
transaction. On appeal against the said order of the lower tax
authority, the first appellate authority held that since the
taxpayer has also sub - licensed the right of commercial
exploitation of drugs to third parties, the payment made by
the third parties to the tax payer can be used to benchmark
the transaction of royalty payment between taxpayer and its
AE. The Tax Tribunal upheld the decision of the first appellate
authority that internal CUP can be used to benchmark the
royalty payment made to its AE and also accepted that there
is no need for written agreement as per rule 10B (2) of the
Rules and hence royalty can be paid to AE even if there was
no written agreement.
Nycomed Pharma Pvt Ltd [TS-1139-2019-(Mum)-TP]
10 BDO India Newsletter
TAX UPDATES
Indirect Tax
GOODS & SERVICE TAX
Judicial Updates
The concept of a composite supply would not be attracted in
cases where there was more than one supplier
Facts of the case
▪ Abbott Healthcare Private Limited (‘Taxpayer’) is engaged
in the sale of pharmaceutical products, diagnostic kits etc.
The taxpayer is in the practise of placing the diagnostic
instruments at the premises of unrelated hospitals,
laboratories etc. for their use for a specified period,
without any consideration.
▪ The taxpayer also enters into ‘Reagent Supply and
Instrument Use’ agreements with various hospitals,
laboratories etc., for the supply of medical instruments to
the hospital/laboratory for their use, without any
consideration for a specified period.
▪ Also, the taxpayer supplies, on principal to principal basis,
specified quantities of reagents, calibrators, disposables
etc. at agreed prices to its distributors on payment of
applicable GST. When the distributor supplies the
reagents, calibrators and disposables to the
hospitals/laboratories concerned, the distributor
discharges applicable GST on the price charged for supply
of the said products.
▪ The agreement between the parties also contains a clause
which provides that if the hospital fails to purchase
specified minimum quantum of reagents, calibrators,
disposables, etc., the taxpayer is entitled to recover from
the hospital an amount equal to the deficit in the actual
purchases, vis-a-vis, the minimum purchase stipulated
under the contract.
▪ During the course of transport of instruments to a
laboratory, on which no consideration is payable, it was
seized by the Assistant State Tax Officer, Kozhikode,
alleging that the goods were not accompanied by a tax
invoice, but were transported under a delivery challan
(DC).
▪ Although the detained goods were subsequently released,
consequent to the taxpayer furnishing a bank guarantee
and a bond as provided under the CGST Act and Rules, the
taxpayer preferred to obtain an Advance Ruling from the
Authority for Advance Ruling (AAR).
Order by AAR
▪ The AAR held that the placement of diagnostic
instruments to unrelated customers like hospitals,
laboratories etc., for their use without any consideration,
▪ on the basis of an agreement mandating minimum
purchase obligation of products for a specified period,
constituted as "composite supply".
▪ The principal supply being transfer of right to use goods
for any purpose, the entire supply is taxable at a higher
rate of 18%, as against 5% chargeable on the reagents,
calibrators, disposables, etc.
Order by the Appellate Authority for Advance Ruling
(‘AAAR’)
▪ The taxpayer, aggrieved by the order of the AAR, field as
appeal before the AAAR. However, the same was
rejected by the Appellate Authority, confirming the
order of the AAR.
▪ The taxpayer filed a Writ petition before the Hon’ble
High Court of Kerala.
Submissions of the Taxpayer
▪ The taxpayer submitted that AAR and AAAR acted
without jurisdiction in rendering their findings on the
issue relating to composite supply.
▪ The assumption of the AAR and AAAR in holding that the
supplies made by the taxpayer constituted a ‘composite
supply’ of medical equipment together with reagents,
calibrators and disposables, is not raised in the
Application for Advance Ruling, thus could not have been
adverted to comment upon by the Advance Ruling
Authorities.
▪ The supply of an instrument is independent and distinct
that of the supply of reagents, calibrators and
disposables by the distributor, and hence it is not a
‘composite supply’.
▪ Irrespective of above, the supply of the instrument
cannot be considered as the principal supply, since the
value of the instrument supplied constitute only about
20% of the value of the reagents/ calibrators/disposables
supplied during the same contract period.
11 BDO India Newsletter
TAX UPDATES
Indirect Tax
Submissions of the tax authorities
▪ The tax authorities submitted that the instrument
supplied by the taxpayer cannot function without the
reagent/calibrator/disposables supplied by the
distributors of the taxpayer. Hence, the supplies
effected by both persons had to be clubbed to ascertain
the real "Supply" that was made by the taxpayer.
▪ When both the supplies are taken together as envisaged
under the contract, the supply effected by the
taxpayer, has to be seen as a ‘composite supply’, with
the instrument being the principal supply, and the
reagents constituting the incidental supply.
Observations and Ruling by the Hon’ble High Court
▪ The Court observed that it is apparent that the AAR
went beyond the terms of reference in embarking upon
an enquiry as to whether the supplies effected the by
taxpayer to hospitals/laboratories, constituted a
‘composite supply’ or not. As a consequence, the AAR
did not go into the real issue of whether the supply of
instruments per-se constituted a taxable supply under
the CGST Act.
▪ Further, the High Court stated that the findings of the
AAR on the said issue are at any rate legally untenable.
The concept of enhancement of utility of the instrument
through the supply of reagents/calibrators/disposables,
while relevant for the purposes of valuation of the
supply of instruments, cannot be imported into the
concept of ‘composite supply’ under the GST Act.
▪ Transactions has to be envisaged under the agreement
between the taxpayer and its customers, firstly the
supplies are made by two different taxable persons; the
supply of instrument being by the taxpayer and the
supply of the reagents, calibrators and disposables being
by his distributor, who purchases it from him on
principal to principal basis. The Court referred to the
decision in the case of Nell Gwynn House Maintenance
Fund Trustees v. Customs and Excise Commissioners
[(1999) Simon's Tax Cases 79 (HL)] and Telewest
Communications PLC v. Customs and Excise
Commissioners [(2005) Simon's Tax Cases 481 (CA)]
wherein it is mentioned that the concept of a
‘composite supply’ would not be attracted in cases,
where there was more than one supplier.
▪ Secondly, the two supplies do not fit-in to the
description of being "naturally bundled and supplied in
conjunction with each other in the ordinary course of
business" as they were in on fact were not bundled
together.
▪ With reference to composite supply, the Court observed
that it must take into account, supplies as effected at a
given point in time on "as is where is" basis. In particular
instances, where the same taxable person effects a
continuous supply of services coupled with periodic
supplies of goods/services to be used in conjunction
therewith, one could possibly view the periodic supply of
goods/services as composite supplies along with the
service that is continuously supplied over a period of
time.
▪ Consequently, the Hon’ble High Court allowed the Writ
petition laying down the above principle, and the matter
is remanded back to the AAR for a fresh decision on the
query raised by the taxpayer.
[Kerala High Court – Abbott Healthcare Private Limited-
Writ Petition No.17012 of 2019 (B) [2020-TIOL-40-HC-
Kerala-GST]
Taxpayer cannot suffer for system inefficiency, grants
partial Input Tax Credit (ITC) refund on exports
▪ Vision Distribution Private limited (‘Taxpayer’) is a
company engaged in the business of purchase and sale of
mobile phones. The taxpayer was registered under the
provisions of Delhi Value Added Tax, 2014 and was
eventually migrated in to Goods and Services Tax Act
w.e.f. July 01, 2017.
▪ The output supplies made by the taxpayer are also in the
course of exports out of India.
▪ The taxpayer submitted that it was entitled to carry
forward unutilized ITC of INR 31.31 Mn relating to pre-
GST period, under the head CGST in terms of Section 140
of the CGST Act, 2017.
▪ Such credit was to be carried forward in Form GST TRAN-
1 in terms of rule 117 of CGST Rules, 2017 within 90 days
of appointed date (i.e., 01-07-2017) which was
subsequently extended to December 27, 2017.
▪ It was admitted that the taxpayer could not upload Form
GST TRAN-1 either in the month of July 2017, or for most
part of August 2017 as the form was not made available
upto August 25, 2017.
▪ However, the taxpayer had made exports in the month
of July 2017 and August 2017 entailing deposit of tax in
cash amounting to INR 13.74 Mn., even though the
taxpayer was entitled to CGST credit of INR 31.31 Mn.
▪ The grievance of the taxpayer is that due to the inaction
of the tax authorities and their failure to allow smooth
 12 BDO India Newsletter
TAX UPDATES
Indirect Tax
migration of the credit standing in the taxpayer’s account of
unutilized input tax, the taxpayer could not use and exploit
the ITC while making exports in the months of July and
August 2017 and was forced to shell-out the tax, which
would not have been the case, had the taxpayer been able
to utilize its ITC which had accumulated even prior to the
enforcement of the GST regime.
▪ In view of the above, the taxpayer has claimed the refund of
the said amount of INR 13.74 Mn. and ITC availed on account
of zero-rated supplies made in the months of July 2017 and
August 2017, aggregating to INR 30.51 Mn.
Questions raised before the High Court
▪ Whether the taxpayer is eligible for refund of accumulated
ITC under pre-GST regime and ITC availed on account of
zero-rated supplies?
Submissions of the tax authorities
▪ The tax authorities submitted that the taxpayer has
uploaded Form GST TRAN-1 only in the month of December
2017 even though it was possible to upload from August 28,
2017 onwards.
▪ That the taxpayer has availed ITC from November 2017
onwards and there was no un-utilized credit lying in the
ledger account in the months of July 2017 and August 2017.
Accordingly, the same is not eligible for refund including the
amount which is paid in cash.
▪ The tax authorities also submitted that under rule 86 (3) of
the CGST Rules, where a registered person claims refund on
any un-utilized amount from the electronic credit ledger in
accordance with the provisions of Section 54, the amount to
the extent of the claim is required to be debited in the said
ledger. In case, a taxpayer claims refund for the months of
July and August 2017, there has to be unutilized ITC credit
lying in the electronic credit ledger of the assessee for the
said months, which is not the case.
Observations and ruling of Hon’ble High Court
▪ The taxpayer cannot be made to suffer on account of failure
on the part of the tax authorities in devising smooth
transition to GST regime w.e.f. July 01, 2017.
▪ Though the form was only made available on August 25,
2017, the business activity in the country could not be
expected to come to a standstill on account of GST system
not being workable.
▪ The rights of the parties cannot be subjugated to the poor
and inefficient software systems adopted by the tax
authorities.
▪ The system limitations cannot be a justification to deny
the relief, to which the taxpayer is legally entitled.
▪ That the tax authorities ought to refund the amount of
INR 13.71 Mn. to the taxpayer and it shall be open to
the tax authorities to debit such amount in the ITC
ledger of the taxpayer.
▪ So far as the taxpayer’s claim for the refund of the
remaining amount is concerned, the taxpayer has
already submitted the documents in that regard and
hence, the tax authorities are directed to pass a
reasoned order on the same within four weeks.
[Delhi High Court- Vision Distribution Private Limited vs
Commissioner, State GST & Ors.- TS-1164-HC-2019(DEL)-
NT]
Advance Rulings
Applicability of GST on issue of pre-paid Instruments by
jewellery manufacturers and traders
Facts of the case
▪ M/s. Kalyan Jewellers India Limited (‘Taxpayer’) is in
the business of manufacturing and trading of Jewellery
Products.
▪ As a part of sales promotion, the taxpayer introduced
the facility of different types of Pre-Paid Instruments
(PPI's) viz. closed system PPIs, semi closed system PPIs
through its retail outlets, third party PPI issuers and
online portals to their customers and these are generally
called "Gift Vouchers/Gift Cards" in trade practice.
The features of different PPIs are as following:
− Closed System of PPI: Transactions are between only
two parties. One party- issuer, issues PPIs to
customer. The PPIs holder/customer makes
purchases only from issuer. There is no cash
withdrawals. These PPIs cannot be utilized for third
party services/sales. The PPIs holder/customer
purchase jewels from the issuer only on redemption
of PPIs, here the taxpayer is an issuer of PPIs to
customers;
− Semi Closed system of PPIs: Transactions are
between more than two parties. The third party
issues PPIs to customers, who uses PPIs at a group of
clearly identified merchant locations. M/s.
Qwickcilver Solution (‘Third Party’) based out-of
Bangalore issues PPIs to customers who can redeem
the same with the taxpayer or any other outlets
identified by the taxpayer. Third party pays the
13 BDO India Newsletter
TAX UPDATES
Indirect Tax
taxpayer an upfront discounted price (lower than
face value) and sells the PPIs for face value to the
general customers, these customers redeems the
PPIs at the outlets of taxpayer against their
jewellery purchase. The difference between the
face value and discounted value is the incentive for
the third party issuers;
− Open System of PPIs: These PPIs are issued by banks
and are used at any merchant location for purchase
of goods and services including facilitation of cash
withdrawals at ATM/Point of Sales (POSs)/ Business
correspondents (BCs). This type of PPIs are not dealt
by the taxpayer.
Questions before Authority for Advance Ruling (AAR)
▪ Whether the issue of own closed PPIs by the taxpayer to
their customers be treated as supply of goods or supply
of service?
▪ If yes, is the time of issue of PPIs by the taxpayer to
their customers is the time of supply of goods or
services warranting tax liability?
▪ If yes, what is the applicable rate of tax for such supply
of goods or services?
▪ If yes, whether the issue of PPIs by the third-party PPI
Issuers subject to GST at the time of issue in their
hands?
▪ Whether the amount received by the taxpayer from
third Party PPI Issuers subject to GST?
▪ If No, GST collection at the time of sale of goods or
services on redemption of PPIs i.e., own and from third
Party will be a sufficient compliance of the provisions of
the Act?
▪ The treatment of discount (the difference between face
value and discounted value) in the hands of issuer of PPI
in case of third-party PPIs? Whether the taxpayer will be
liable to pay GST on this difference Value?
Taxpayer’s Submission
▪ Taxpayer issues closed PPIs as defined in the master
circular issued by RBI. They are sold to customers on
receiving the face value as per the requirement of the
customers.
▪ The customer can redeem these PPIs in any outlets of
the taxpayer across the country at the time of purchase
of jewellery.
▪ Further, as per accounts statements furnished, PPIs are
named as 'Gift Vouchers' and the amount received on
sale of the vouchers is accounted under 'Other Current
Liabilities'. Once they are redeemed, they are credited to the
revenue (sales) account.
▪ The taxpayer has claimed that PPIs are actionable claims
equivalent to money and issue of PPIs are not supply of goods
or services and as per clause 6 of schedule III of CGST Act,
GST is not liable to be paid at the time of supply of actionable
claims.
▪ Further, the taxpayer stated that PPIs are neither goods nor
services.
The taxpayer placed reliance on the below mentioned case laws:
▪ M/s. Sodexo SVC India Pvt ltd Vs. State of Maharashtra and
Others [2015 (12) TMI 1041 – Supreme Court], wherein the
Hon'ble Apex Court has treated Sodex Meal vouchers as
expenditure incurred by such employer and amenity in the
hands of employee, nothing but salary, as defined under
Section 17 of the Income Tax Act, 1961.
▪ Union of India vs. Delhi Chit Fund Association [2014 (3) TMI
306 - SC], it was held that in a mere transaction of money or
actionable claim, no service was involved, and no service tax
is leviable.
▪ H.Anraj Vs. Government of Tamil Nadu and Others [1985 (10)
TMI 258 – Supreme Court] the elements of actionable claims
are framed as under:-
− Any type of debt other than a debt secured by mortgage of
immovable or hypothecation or pledge.
− Any beneficial interest in movable property not in
possession.
▪ Martin Lottery Agencies Limited vs. Union of India [2007 (9)
TMI 39 – High Court, Sikkim, relying on M/s. Sunrise Associates
vs. Union of India 2006 (4) TMI 118 – Supreme Court) held that
lottery ticket is an Actionable Claim.
Observations & Ruling of the AAR
▪ The customer purchases the gift voucher and card by paying
the issuer. Whoever produces the voucher at their stores, they
will be allowed to redeem it. The voucher has both a value
and an ownership and is the property of whoever first
purchases it and later whoever redeems it and it is movable.
It is neither money nor actionable. Hence, these gift vouchers
cards issued by the taxpayer being vouchers' under the CGST
Act are "Goods" as per Section 2(52) of CGST Act.
▪ Further, when the vouchers are purchased by the customers
there is a consideration, the face value which is paid; it is for
the furtherance of business of the taxpayer as the customer or
bearer will in future definitely buy jewellery from the
taxpayer. Hence, supply of voucher qualifies as "supply" under
14 BDO India Newsletter

TAX UPDATES
Indirect Tax
Section 7 of the CGST Act, specifically as supply of goods.
▪ The time of supply of such gift vouchers/gift cards by the
taxpayer to the customers shall be the date of issue of
vouchers, if the vouchers are specific to any particular goods
specified against the voucher. If the gift vouchers/gift cards
are redeemable against any goods bought, the time of supply
is the date of redemption of voucher as per section 12(4) of
the CGST Act.
▪ The case of paper based gift vouchers is classifiable under
Customs Tariff Heading (CTH) 4911 and the applicable rate is
6% under CGST as per sl. no:132 of Schedule II of the
notification no.1/2017-C.T. (Rate) dated 28.06.2017 and 6%
under SGST as per sl. no:132 of Schedule II of notification Ms.
No. II (2)/CTR/532(d-4)/2017 vide G.O. (Ms) No. 62 dated
29.06.2017 as amended.
▪ The case of gift cards (other than paper based gift vouchers)
is classifiable under CTH 8523 and the applicable rate is 9%
under CGST as per sl. no:382 of Schedule III of the
notification no. 1/2017-C.T. (Rate) dated 28.06.2017 and 9%
under SGST as per SL.No. 382 of Schedule III of notification
Ms. no. II (2)/CTR/532 (d-4)/2017 vide G.O. (Ms) No. 62 dated
29.06.2017.
▪ The questions raised at SI.No. 4, 5, 6 and 7 are not answered
for the reason that the said questions are not admitted, as
this authority does not have jurisdiction.
[Authority for Advance Ruling-Tamil Nadu, Order No.
52/ARA/2019, dated November 25, 2019]
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