Tax rate and structural reforms clarified: residency, indirect transfer, REIT/InvIT, AIF pass through and fund manager rules updated.
The Finance Act, 2015 prescribes income tax rates and TDS mechanics for 2015 16 and enacts extensive amendments: company residency uses place of effective management; indirect transfer rules are restructured with value thresholds, valuation dates, proportional taxation and reporting obligations; banks' PE interest payments to head offices are taxable in India; REITs/InvITs and certain GDRs and AIFs receive specialised tax regimes; fund manager activities in India are generally not a business connection for eligible offshore funds subject to conditions; GAAR is deferred and wealth tax abolished.

Phasing out tax deductions: profit, investment and area incentives to be withdrawn and weighted deductions removed.
The Government will phase out profit linked, investment linked and area based deductions for corporate and non corporate taxpayers; existing sunset dates will not be altered; incentives without a terminal date will be given a sunset of 31.3.2017 for commencement or claim as appropriate; and weighted deductions will cease with effect from 01.04.2017, with further details published by the Income Tax Department and comments invited to Director (TPL III).

Online request protocol: all information exchanges must use the FINex system; paper submissions discontinued.
Requests for information to the financial intelligence unit must be submitted through the FINex online system; enhancements to the FINex module facilitate exchange and introduce new functionalities, and all future exchanges should use web or bulk online requests as paper requests will no longer be accepted.

Local committees for taxpayer grievances expedite review of high pitched scrutiny assessments and recommend administrative action to curb unreasonable additions.
Local Committees of senior field officers are to be constituted in each Pr. CCIT region to examine taxpayer grievances from high pitched scrutiny assessments, acknowledge petitions, maintain records and dispose of petitions within a short prescribed timeframe. Committees will determine if additions reflect unreasonable assessments, non application of mind, gross negligence or breaches of principles of natural justice, and will report findings to the Pr. CCIT/CCIT for possible administrative action and for presentation before appellate authorities to limit litigation.

Time limit for registration orders under section 12AA must be met; monitoring and administrative action required for noncompliance.
Orders granting or refusing registration under Section 12AA must be passed before the expiry of six months from the end of the month in which the application was received; the Commissioner of Income Tax (Exemptions) must adhere to this limit and the Chief Commissioner (Exemptions) is tasked with monitoring compliance and initiating administrative action for any laxity.

Interest from bank investments in non SLR securities treated as business income, department will not pursue or file appeals.
Interest on non SLR securities held by banks constitutes income attributable to the business of banking and therefore falls under Profits and Gains of Business and Profession, following the Supreme Court principle that bank investments are part of banking business. Consequently, the tax department directs that no appeals should be filed asserting such interest as income from other sources and that existing appeals on that ground may be withdrawn.

Sovereign Gold Bonds issuance terms govern investor eligibility, denomination, pricing, interest, redemption, tradability and tax treatment.
Issuance of Sovereign Gold Bonds prescribes resident individual eligibility, denomination in one gram units with specified minimum and maximum per fiscal year, Government of India Stock form with Holding Certificate and demat convertibility, pricing and redemption in rupees based on IBJA weekly average for 999 purity, fixed semiannual interest on initial investment, eight year maturity with premature redemption from year five, tradability upon RBI notification, transfer by prescribed instrument, SLR eligibility, use as loan collateral subject to RBI gold loan LTV rules, and tax treatment: taxable interest and capital gains like physical gold.

Due date extension for E filing audit reports clarified to align with the extended return filing deadline for specified assessees.
The Board confirms that taxpayers covered by Explanation Two clause (a) are granted an extended due date for both E filing their returns and for obtaining and E filing the statutory reports of audit; the corrigendum aligns the audit report procurement and submission deadline with the extended return filing deadline announced in the prior administrative order.

Advance ruling timelines: stricter departmental representation and complete reports to secure timely pronouncement and coordination.
Advance rulings under section 245R must be delivered within the prescribed timeframe; jurisdictional authorities are required to submit complete, approved reports addressing all issues, include supporting documents, and identify the field officer who will represent the case. Interim reports must be filed if full information is unavailable. Adjournments are limited to unavoidable circumstances and must be notified in advance, while paper books must be submitted per Board timelines. Senior officers must monitor compliance and escalate instances of non-cooperation.

PAN camp inauguration via video conference: officials requested to participate to facilitate PAN application reception at remote locations.
Inauguration of PAN camps for receipt of PAN applications at remote locations will be conducted via video conference by the Finance Minister; senior income tax officials are directed to attend at their respective offices and local Principal Commissioners/Commissioners (including appellate officers posted locally) may also participate to facilitate PAN application acceptance and outreach.

Email-based communication in income-tax assessments enables paperless correspondence and e-hearing with taxpayer consent in pilot.
A pilot will use email-based communication to conduct paperless assessment proceedings in five non-corporate charges, identifying up to 100 cases per charge selected on AIR/CIB leads or 26AS mismatches. Taxpayer consent is required before inclusion, and departmental officers will correspond via official e-mail IDs to taxpayers' e-mail addresses in returns. The project aims to handle most scrutiny processing electronically for smaller or limited-issue cases and necessitates a standardized user-friendly platform for seamless exchanges.

Arm's Length Price determination directs transfer pricing referrals to specialized officers, defining AO and TPO roles and procedures.
Guidance clarifies that determination of the Arm's Length Price for international transactions is made by the Transfer Pricing Officer upon reference by the Assessing Officer, who must compute total income in conformity with the ALP. The AO may rely on Form 3CEB to form a prima facie belief, must record satisfaction and afford a hearing in cases of non filing, non disclosure or contested applicability, obtain higher level approval before referral, and refrain from referrals based solely on transaction value when cases are selected on risk parameters.

Production and stock discrepancy detection: compare IBM annual returns with income-tax filings and take remedial action.
Scrutiny of mining assessees must include obtaining IBM Annual Returns and comparing them with Income-tax Returns to detect production and closing stock discrepancies and potential suppression; where significant divergences are found, remedial measures should be applied for all affected years.

Information sharing requirements: agencies must transmit REIC forum appraisal materials to CEIB and increase dossier submissions.
Investigation units must forward information shared with the regional intelligence forum to the central intelligence bureau within 15 days of Appraisal Report completion and are directed to increase and improve submission of case dossiers to the central bureau to enhance consolidated intelligence processing.

Mutual Agreement Procedure invoked to consider Nokia India's assessed tax demands, clarifying no fresh notice was issued.
No fresh income-tax notice was issued to Nokia India; an assessment order for AY2010-11 passed in August 2015 raised a demand based on earlier issues, and that demand, along with prior demands, is being considered under the Mutual Agreement Procedure of the India-Finland tax treaty by the Competent Authorities.

Appeal effect monitoring requires prompt implementation of appellate orders and mandatory reporting of delays for escalation.
Assessing Officers must give prompt appeal effect to appellate orders while range heads monitor correctness and timeliness; any pendency beyond one month must be reported to the CIT in the monthly DO report. A prescribed scrutiny report format is to be used to inform filing decisions at the next appellate level, with Part I of the pro forma recording receipt of the appellate order and date of appeal effect and full pro forma completion where required. Principal commissioners must ensure reporting, inquiry into delays, and expedited compliance.

Electronic Verification Code expansion allows electronic income-tax returns filed without digital signatures to be validated under specified conditions.
Validation of electronic returns is expanded to permit use of the Electronic Verification Code (EVC) for returns filed electronically without a digital signature. Returns filed on or after 01.04.2015, returns filed in response to statutory notices, and returns filed consequent to condonation of delay under section 119 may be validated through EVC, extending earlier EVC coverage and facilitating compliance.

Measurement of distance: shortest road distance governs pre-amendment cases, aerial measurement applies prospectively; appeals not to be pursued.
For purposes of section 2(14)(iii)(b), the Finance Act 2013's aerial measurement rule applies prospectively; for periods before that amendment the Nagpur Bench held distance is to be measured by the shortest road distance between municipal limit and agricultural land. The CBDT has accepted this position and directed that no appeals be filed, and existing appeals on this issue be withdrawn or not pressed.

Abandoned feature film costs treated as revenue expenditure under Section 37 rather than under Rule 9A, permitting deduction.
Rule 9A does not apply to abandoned feature films; production expenditure on such abandoned films is not capital expenditure but is to be treated as revenue expenditure and allowed under Section 37 of the Income-tax Act. The department accepts the judicial position and directs that no appeals be filed or pursued on this ground.

Extension of filing deadline: income tax returns and statutory audit reports may be e filed by 31 October 2015.
The revenue authority ordered that income tax returns and statutory audit reports due for e filing on 30 September 2015 may be filed by 31 October 2015, superseding an earlier instruction of 30 September 2015 and applying nationwide to the relevant filing obligations.