Concessional tax regime for new manufacturing co-operative societies, subject to eligibility conditions, irrevocable option and transfer pricing checks.
A new concessional tax regime permits resident new manufacturing co-operative societies to elect an irrevocable concessional tax rate, subject to prescribed conditions: total income must be computed without specified deductions or set off of earlier losses attributable to those deductions, depreciation must be claimed as prescribed, non manufacturing income and certain excess profits from related-party arrangements are taxed at higher fixed rates, and specified domestic transactions are subject to arm's length pricing; limited use of previously used machinery is permitted under conditions.

Strategic disinvestment: redefined to cover government or public sector share sales reducing majority shareholding and enabling loss carryforward on amalgamation.
Section 72A is amended to expand strategic disinvestment to include sale of shareholding by the Central Government, State Government or a Public Sector Company that reduces their shareholding below fifty-one per cent and transfers control to the buyer; transfer of control may be effected by any one or more of those entities. Section 72AA is amended to allow carry forward and set off of accumulated losses and unabsorbed depreciation where banking companies amalgamate with another banking institution or company within five years of such strategic disinvestment. The amendments take effect from 1 April 2023.

Exemption for statutory development authorities expanded to cover non-company bodies providing public services, subject to notification.
Income of a body or authority or Board or Trust or Commission, not being a company, established or constituted by Central or State Act for specified public purpose objects (housing, planning/development of settlements, regulating or developing activities for public benefit, or regulating matters arising from their object) is proposed to be exempted under a new clause, subject to Central Government notification in the Official Gazette; consequential statutory amendments follow and the change applies prospectively to the relevant assessment year.

Tax exemption for ODI distributions prevents double taxation, easing IFSC banking unit pass-through of taxed income.
Amendments extend the transfer period for original funds to resultant funds on relocation, exempt income distributed to non-resident holders of Offshore Derivative Instruments provided the income was charged to tax in the IFSC banking unit and will incorporate IFSCA (Fund Management) Regulations, 2022 into the definitions of specified, resultant and investment funds to align statutory definitions with the regulatory regime.

Conversion of Gold to Electronic Gold Receipt: excluded from transfer for capital gains; cost basis and holding period preserved.
Conversion between physical gold and an Electronic Gold Receipt issued by a Vault Manager is proposed to be excluded from the definition of transfer for capital gains. The cost of acquisition of an EGR will be deemed the cost of the underlying gold in the hands of the person in whose name the EGR is issued, and vice versa for gold released against an EGR. The holding period for capital gains will include periods during which the gold or the EGR was held prior to conversion.

Extension of start up incorporation cutoff expands section 80 IAC eligibility, applying from the stated effective assessment year onward.
The amendment extends the incorporation cutoff so that enterprises incorporated on or before 1st April 2024 qualify as eligible start ups for the three year full deduction under section 80 IAC, subject to the existing turnover ceiling, Inter Ministerial Board certification and other statutory conditions, and is to have effect from 1st April 2023 for the relevant assessment year and subsequent years.

Carry-forward loss relief extended for startups, easing shareholding continuity requirement to permit set-off of past losses.
Amendment extends the proviso to the carry forward and set off rule so that eligible start-ups may set off carried forward losses incurred within ten years of incorporation under the existing shareholders-continuity relaxation, aligning this period with the ten-year reference in the start-up incentive provision; the change applies from the assessment year 2023-24.

Cash transaction limit relief for primary co operatives raises the threshold before penalty for member transactions.
The amendments raise the electronic payment threshold for primary agricultural credit societies and primary co operative agricultural and rural development banks so that acceptance of loans or deposits from, or repayment to, their members will be required to be by account payee cheque, account payee bank draft or online bank transfer only where the amount equals or exceeds two lakh rupees; penalties will attach only above that threshold.

TDS threshold for co-operative societies increased, altering cash withdrawal TDS applicability and retaining higher deduction rates for non-filers.
The Finance Bill, 2023 amends Section 194N to treat co-operative societies as if the statutory cash-withdrawal TDS threshold were replaced by a higher threshold for the purpose of that section, effective from the start of the next financial year, while preserving the existing non-filer deduction rates and the statutory definition of non-filer.

Deductibility of sugarcane purchase price: recomputation permitted for co-operative mills where prices meet government-fixed approvals.
Confirms that payments by sugar co-operative mills for purchase of sugarcane at prices equal to or less than government-fixed or approved rates are allowable as a deduction for computing business income. Where such deductions were previously claimed and disallowed, an assessee may apply to the tax authority for recomputation of total income for the relevant previous year; the authority must allow the deduction to the extent the expenditure meets the qualifying price condition and apply rectification provisions and the prescribed processing period.

Agniveer Corpus Fund tax exemption: contributions and Seva Nidhi receipts exempt, government contribution treated as salary with deduction.
The Agnipath Scheme creates a non-lapsable Agniveer Corpus Fund holding Agniveer contributions, matching Government contributions and interest; Seva Nidhi is the one-time terminal package payable on completion of engagement. The Finance Bill proposes to exempt Seva Nidhi receipts from income tax and to permit deduction from total income of both the Agniveer's deposits and the Government's matching contributions, while treating the Government contribution as salary with a corresponding deduction and extending a similar deduction in the new tax regime.

Payment timing for micro and small enterprises: tax deduction allowed only on actual payment when MSMED timelines are missed.
An amendment to Section 43B inserts a clause disallowing accrual-based deduction for sums payable to micro and small enterprises when payment is made after the time limits prescribed by the MSMED Act; the proviso to Section 43B will not apply to such payments, and only payments made within the MSMED timelines qualify for accrual-based deduction.

Retrospective GST exemptions and reclassifications bar refunds on tax already collected despite prior tax treatment.
Two retrospective GST amendments reclassify past tax treatments and bar refunds: unintended waste from fish meal production (excluding fish oil) is retrospectively exempted for the earlier period but collected tax is non refundable; and grant of alcoholic liquor licences is retrospectively treated as neither supply of goods nor supply of services, with tax already collected likewise not refundable.

Interest rate under section 50(3) CGST Act set retrospectively to a prescribed statutory rate affecting tax interest liability.
Notification No. 10/2017 (Union Territory Tax) is amended retrospectively from 1 July 2017 to prescribe the rate of interest under sub-section (3) of section 50 of the CGST Act as 18%, thereby fixing the statutory interest chargeable under that CGST provision for the retrospective period.

Interest rate under CGST Act fixed retrospectively, establishing a statutory uniform rate effective from July 2017.
A retrospective amendment to Notification No. 6/2017 fixes the statutory interest rate applicable under the CGST interest provision, with effect from 1 July 2017, by specifying the rate of interest under subsection (3) of the relevant CGST provision.

Input tax credit restrictions clarified: availment conditioned on communication and extended rectification windows provided.
Amendments condition availment of input tax credit on absence of restrictions in communications to recipients and extend the claim and rectification window to the thirtieth day of November of the following financial year; they remove two way return communication, replace it with prescribed one way auto generated communication of inward supplies and credits, require tax period sequential filing of outward supplies, substitute provisional credit claims with self assessed credit subject to conditions, limit utilisation and transfer of electronic ledgers, restate interest on wrongly availed credit retrospectively, and clarify refund claim procedures and withholding scope.

Retail sale price valuation provisions superseded to align central excise valuation with the post GST legal framework under new notification.
Notification No. 49/2008 set out retail sale price based valuation and abatements under section 4A of the Central Excise Act; it has been superseded by Notification No. 01/2022 dated 1 February 2022 to align excise valuation and abatement treatment with the post GST legal framework.

NCCD schedule amendment: reclassification of petroleum crude tariff item to a designated central excise heading changes levy application.
Amendment substitutes Central Excise tariff item 2709 20 00 with 2709 00 10, classifying the entry as petroleum crude in the Seventh Schedule to the Finance Act, 2001, via the Finance Bill, 2022, thereby reclassifying the tariff heading for NCCD schedule purposes.

Additional excise duty on unblended fuel imposed to promote blending from October, affecting petrol and diesel sales.
An additional Basic Excise Duty of Rs. 2 per litre will be levied on petrol and high speed diesel sold to retail consumers without blending, effective from 1 October 2022, to promote petrol blending with ethanol/methanol and diesel blending with bio-diesel by creating a tax differential between blended and unblended fuels.

Ethanol blend tariff classification updated; new excise tariff entries align Fourth Schedule with Customs Tariff provisions.
Insertion of two new tariff items into the Fourth Schedule to the Central Excise Act, 1944 establishes excise classifications for ethanol-blended petrol conforming to BIS IS 17586 and aligns those Fourth Schedule entries with the proposed corresponding amendment in the First Schedule to the Customs Tariff Act, 1975; amendments take effect on enactment unless otherwise specified.