ICAI submits Pre-Budget Memorandum to 2024 CBDT – Recommends Major Tax Reforms

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Final Budget 2024 will be announced after Lok Sabha Elections in the month of July 2024, There may be major announcements related to Tax reforms. Government ask stakeholders for pre budget memorandums and here is the memo of ICAI.




The Institute of Chartered Accountants of India (ICAI) submitted its Pre-Budget Memorandum 2024 to the Central Board of Direct Taxes (CBDT) on April 30, 2024. The memorandum proposes a range of tax reforms aimed at promoting economic growth, environmental sustainability, and social welfare.

Key Highlights of the ICAI Recommendations:

  • Incentives for Green Initiatives: The ICAI proposes tax breaks for businesses engaged in environmentally friendly projects and for entities focused solely on skill development programs. Additionally, they suggest exempting or offering a concessional tax rate on interest earned from green bonds.
  • Promoting Education and Healthcare: Aligning with the government’s push for girl child education, the memorandum recommends a separate tax deduction for expenses related to their education under both tax regimes (default and alternative). It also suggests allowing deductions for medical insurance premiums (Mediclaim) under the default tax regime.
  • Individual Taxpayer Relief: The ICAI proposes a regular increase in the standard deduction and the option of joint taxation for married couples – measures that would provide relief to individual taxpayers.

President’s Remarks:

CA. Ranjeet Kumar Agarwal, ICAI President, emphasized the institute’s role in shaping the country’s environmental, social, and governance (ESG) reporting landscape. He stated that the proposed tax incentives for green projects and green bond subscribers aim to promote green finance and encourage environmentally conscious business practices.

Business Taxation Reforms:

  • Aligning tax audit provisions with the presumptive income scheme.
  • Further simplifying the presumptive income regime.
  • Raising the threshold for calculating allowable partner remuneration.
  • Seeking clarification on specific tax code sections.
  • Streamlining tax regulations for charitable trusts.

Return Filing:

  • Allowing updated return filing in case of reduced losses.
  • Enabling updated return filing even after assessment proceedings are completed.

Other Recommendations:

  • Rationalizing tax rates for deemed income under specific sections, considering the discretionary application of these provisions by tax authorities.
  • Avoiding prosecution solely for delays in tax remittance.

Overall Goal:

The ICAI’s Pre-Budget Memorandum 2024 underscores the importance of streamlining direct tax laws, minimizing tax-related disputes, and improving tax collection mechanisms. These proposed reforms aim to create a more favorable fiscal environment for the upcoming financial year (2024-25).

Detailed Press Release

Public Relations Committee
The Institute of Chartered Accountants of India
30th April, 2024
PRESS RELEASE

ICAI submits Pre-Budget Memorandum to CBDT advocating Tax Reforms
ICAI seeks tax incentives for entities engaged in Green Projects and Skill Development.Separate provision for deduction of expenses relating to education of girl child and Mediclaim premium.The Institute of Chartered Accountants of India (ICAI) presented its Pre-Budget Memorandum 2024 to the Central Board of Direct Taxes (CBDT). The comprehensive document encapsulates a spectrum of recommendations aimed at fostering economic growth, encouraging environmental sustainability, and enhancing social welfare through prudent tax reforms. Below are some key highlights from the memorandum.

In the Pre-budget Memorandum, ICAI seeks tax incentives for entities engaged in green projects that impact environment positively and entities exclusively engaged in skill development programmes, considering their contemporary relevance and importance. Further, it has been suggested that interest income earned by the subscribers of green bonds may be exempt or, in the alternative, be subject to a concessional rate of tax.

In line with the Government’s campaign to promote education of the girl child, a separate provision for deduction of expenses relating to education of girl child both under the default tax regime and alternative tax regime has been suggested in the Memorandum. The significant suggestions relating to the Personal Taxation regime include provision of deduction for Mediclaim premium paid under the default tax regime, regular enhancement of standard deduction and option of joint taxation for married couples.

On this occasion CA. Ranjeet Kumar Agarwal, President, ICAI, said, “ICAI has pioneered formulating Standards on Sustainability Reporting, shaping the ESG reporting landscape in the country. In order to enhance green finance and encourage green projects, we have advocate for special incentives to entities undertaking Green Projects and propose exemption for interest income of subscribers of green bonds issued by such entities”

On the business taxation front, the suggestions include alignment of the provisions of tax audit with the presumptive income provisions, further simplification of presumptive income regime and increase in threshold for computation of allowable remuneration of partners. In addition, clarifications were sought on the provisions of section 43B(h). The Memorandum also contains suggestions for rationalization of the provisions relating to taxation of charitable trusts. Allowing filing of updated return in case of reduction in losses and permitting filing of such return where assessment proceedings are completed are some important suggestions in relation to return filing.

Rationalization of the tax rate under section 115BBE (as well as the surcharge thereon) on deemed income under sections 68 to 69D has been suggested, considering that these provisions can be invoked at the discretion of the Assessing Officer; and non-initiation of prosecution proceedings where there is only a delay in remittance of tax are the other significant suggestions in the Memorandum.

The Pre-Budget Memorandum 2024 emphasizes the importance of rationalizing direct tax laws, minimizing litigation, and enhancing tax collection mechanisms, all geared towards fostering a conducive fiscal environment for the year 2024-25.

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Pooja Gupta

CA Pooja Gupta (CA, ISA, M.com) having 15 years of experience. Educator and Digital Creator

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CA Pooja Gupta (CA, ISA, M.com) having 15 years of experience. Educator and Digital Creator

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