Taxmann's Taxation of Loans Gifts & Cash Credits

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Frequently Asked Questions (FAQs)

I-9

CHAPTER 1 :

SCHEME OF TAXATION OF UNDISCLOSED INCOME COVERED BY SECTIONS 68 TO 69D

3

CHAPTER 2 :

VOLUNTARY DISCLOSURE OF UNDISCLOSED INCOME

17

CHAPTER 3 :

DETECTION OF UNDISCLOSED INCOME BY DEPARTMENT

30

CHAPTER 4 :

CASH CREDITS UNDER SECTION 68

33

CHAPTER 5 :

LOANS, BORROWINGS, DEPOSITS AND SUCH OTHER AMOUNTS - WHETHER AND WHEN TREATED AS UNEXPLAINED CASH CREDITS

106

CHAPTER 6 :

SHARE APPLICATION MONEY/SHARE CAPITAL/ SHARE PREMIUM IN CASE OF CLOSELY-HELD COMPANIES - WHEN UNEXPLAINED CASH CREDIT

141

SHARE APPLICATION MONEY/SHARE CAPITAL/ SHARE PREMIUM IN CASE OF WIDELY-HELD COMPANIES - WHEN UNEXPLAINED CASH CREDIT

180

CHAPTER 8 :

WHETHER CAPITAL GAINS FROM SHARES TAXABLE U/S 68?

183

CHAPTER 9 :

DEPOSITS FROM TENANTS - WHETHER AND WHEN UNEXPLAINED CASH CREDITS

188

CHAPTER 10 :

CREDITS IN FIRM’S BOOKS - WHEN UNEXPLAINED CASH CREDITS

190

CHAPTER 11 :

SUNDRY CREDITORS/TRADE CREDITORS - WHEN UNEXPLAINED CASH CREDITS

198

CHAPTER 12 :

UNEXPLAINED INVESTMENTS UNDER SECTION 69

201

CHAPTER 13 :

UNEXPLAINED INVESTMENT IN LOTTERY TICKETS

273

CHAPTER 7 :

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CONTENTS

I-6 PAGE

CHAPTER 14 :

ADDITIONS U/S 69 ON THE BASIS OF STOCK STATEMENTS SUBMITTED TO BANKS

275

CHAPTER 15 :

UNEXPLAINED MONEY, BULLION, ETC. - SECTION 69A

281

CHAPTER 16 :

AMOUNT OF INVESTMENTS ETC. NOT FULLY DISCLOSED IN BOOKS - SECTION 69B

303

CHAPTER 17 :

UNEXPLAINED EXPENDITURE ETC. - SECTION 69C

314

CHAPTER 18 :

AMOUNT BORROWED OR REPAID ON HUNDI SECTION 69D

317

CHAPTER 19 :

DONEE-BASED TAXATION OF GIFTS

327

CHAPTER 20 :

TAXABILITY OF GIFTS OF SUMS OF MONEY RECEIVED

362

CHAPTER 21 :

RECEIPT OF SUMS OF MONEY

367

CHAPTER 22 :

SUM OF MONEY RECEIVED WITHOUT CONSIDERATION

373

CHAPTER 23 :

HOW TO COMPUTE THE LIMIT OF 50,000

396

CHAPTER 24 :

TAX-EXEMPT GIFTS

402

CHAPTER 25 :

ANY PERSON OR PERSONS

450

CHAPTER 26 :

IMMOVABLE PROPERTY - SCOPE OF THIS TERM

455

CHAPTER 27 :

CONDITIONS FOR TAXABILITY OF GIFTS RECEIVED OF IMMOVABLE PROPERTIES

461

CHAPTER 28 :

DATE OF RECEIPT OF IMMOVABLE PROPERTY

469

CHAPTER 29 :

RECEIVED WITHOUT CONSIDERATION OR FOR A CONSIDERATION LESS THAN SDV

472

CHAPTER 30 :

VALUATION OF THE IMMOVABLE PROPERTY RECEIVED

485

CHAPTER 31 :

HOW TO COMPUTE THE LIMIT OF 50,000 FOR GIFTS OF IMMOVABLE PROPERTY RECEIVED

487

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CONTENTS PAGE

CHAPTER 32 :

COMPUTATION OF CAPITAL GAINS ON TRANSFER OF IMMOVABLE PROPERTY TAXED AS GIFT

491

CHAPTER 33 :

‘PROPERTY’ (OTHER THAN IMMOVABLE PROPERTY) (i.e. MOVABLE PROPERTY)

497

CHAPTER 34 :

CONDITIONS FOR TAXABILITY OF MOVABLE PROPERTY RECEIVED WITHOUT CONSIDERATION OR FOR CONSIDERATION BELOW FMV

508

CHAPTER 35 :

DATE OF RECEIPT OF SHARES AND SECURITIES, JEWELLERY, ETC.

510

CHAPTER 36 :

MOVABLE PROPERTY RECEIVED WITHOUT CONSIDERATION/FOR CONSIDERATION LESS THAN FMV

512

CHAPTER 37 :

DETERMINATION OF FAIR MARKET VALUE

519

CHAPTER 38 :

TAXATION OF SHARES AND SECURITIES RECEIVED

520

CHAPTER 39 :

VALUATION OF JEWELLERY

546

CHAPTER 40 :

VALUATION OF ARTISTIC WORK

549

CHAPTER 41 :

VALUATION OF BULLION

552

CHAPTER 42 :

HOW TO COMPUTE THE LIMIT OF 50,000 FOR MOVABLE PROPERTY GIFTS

553

APPENDICES APPENDIX 1 :

RELEVANT PROVISIONS OF INCOME-TAX ACT, 1961

559

APPENDIX 2 :

RELEVANT PROVISIONS OF INCOME-TAX RULES, 1962

580

APPENDIX 3 :

GUIDELINES FOR SEIZURE OF JEWELLERY AND ORNAMENTS IN COURSE OF SEARCH

586

APPENDIX 4 :

RELEVANT PROVISIONS OF SECURITIES CONTRACTS (REGULATION) ACT, 1956

587

Para 1.0

SCHEME OF TAXATION OF UNDISCLOSED INCOME

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If undisclosed income is covered under The Black Money (Undisclosed Income & Assets) Imposition of Tax Act, 2015 (BM Act), the same will be taxed under that Act and not u/s 115BBE(1) and hence can’t be disclosed in ITR in Schedule OS

Voluntary disclosure u/s 115BBE(1) and paying 78% tax will not provide immunity from the Prohibition of Benami Property Transactions Act, 1988 (PBPT Act) or any other law such as Prevention of Corruption Act, 1988

Tax evaders do not disclose their income to tax authorities. They tend to hold it in those forms which can escape the notice of tax authorities.

Secreting cash, jewellery, bullion, gold bars etc. in false ceilings, floors etc. in one’s own premises is the obvious but a very crude method of evasion. Income thus concealed cannot be brought to tax by scrutinizing books as these are kept off-books. These can be detected and taxed only by:

finding out investments, bullion, jewellery, cash etc. possessed by a tax evader or huge expenditure incurred by him on education of children, marriage of family members etc.

then tallying these investments, expenditure etc. with disclosed/ reported income to find out if these are disproportionate to disclosed income.

The tax authorities come to know of assets and expenditure through searches, surveys and other mechanisms like Annual Information Returns and then tally/check with income/wealth reported to the tax authorities. If assets/expenditure exceed reported/disclosed income and no satisfactory explanation for the source of the excess assets/ expenditure is forthcoming, the excess is taxed as undisclosed income.

Sections 69 to 69C deal with these measures of tallying assets and expenditure of tax evader with reported/disclosed income and seeking explanation of the tax evader for discrepancies.

Keeping money as bundles of cash in false ceilings or in idle assets like gold, bullion etc. is not without its costs either not to mention the risks that go with it. As the Panchtantra rightly says : ‘Money, even if hoarded in common place fashion, is likely to go in a flash, the hindrances being many. Money unemployed when opportunities arise is the same

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TAXATION OF UNEXPLAINED AMOUNTS

Para 1.1

as money unpossessed. Therefore, money once acquired should be guarded, increased, employed.’ Moreover, however hard a citizen tries to conceal his income, he cannot do so as he will make investments and incur expenditure. So, that is where the practice of money laundering comes in to cloth unaccounted or black money with a legitimate taxfree colour.

The cleverer and sophisticated tax evaders realize that it is hard to conceal income for a long time and concealment is an outright offence.

Instead of outright concealment or suppression, they will try and disclose their income as capital receipts such as loans, gifts, trade credits or deposits or capital contributions even from persons who lack means or creditworthiness. Section 68 seeks to deal with this book-keeping sophistry.

Section 69D targets borrowings/repayments on hundis.

All these undisclosed incomes are taxed under section 115BBE at flat effective rate of 78%.

Then there is the issue of unaccounted/undisclosed money being invested the names of benamidars. This issue is addressed by the Prohibition of Benami Prohibition Transactions Act,1988 which provides for confiscation of Benami properties.

Section 115BBE was first inserted into the Act by Finance Act, 2012.

Section 115BBE(1) was substituted by the Taxation Laws (Second Amendment) Act, 2016 with effect from assessment year 2017-18.

The following points are noteworthy : The Finance Act, 2012 inserted section 115BBE in the Act to tax unaccounted money represented by the additions covered by sections 68, 69, 69A, 69B, 69C and 69D at flat 30% without any deductions or basic threshold exemption limit.

Section 115BBE was enacted ‘In order to curb the practice of laundering of unaccounted money by taking advantage of basic exemption limit’.

Section 115BBE, as originally inserted in the Act had the following lacunae :

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(i) The tax rate was ridiculously low rate of 30% given that the income was not offered to tax but had to be detected and brought to tax. (ii) There was no penalty for amounts of income detected and brought to tax under this head. (iii) Further, section 115BBE nowhere envisaged a voluntary disclosure scheme where past unaccounted income can be declared by assessee in current ITR by paying flat tax. Also, the ITR forms had no provision for such voluntary disclosure.

The Taxation Laws (Second Amendment) Act, 2017 has cured the above lacunae by putting in place a new section 115BBE regime by substituting sub-section (1) of section 115BBE, inserting new section 271AAC and by inserting new sub-section (1A) in section 271AAB. Section 115BBE(2) was amended retrospectively w.e.f. 2017-18 by the Finance Act, 2018.

Section 115BBE(1), as applicable w.e.f. assessment year 2017-18, provides that where the total income of an assessee, (a) includes any income referred to in section 68, section 69, section 69A, section 69B, section 69C or section 69D and reflected in the return of income furnished under section 139; (b) determined by the Assessing Officer includes any income referred to in section 68, section 69, section 69A, section 69B, section 69C or section 69D, if such income is not reflected in Income-tax return as per (a) above, the income-tax payable shall be the aggregate of (i) the amount of income-tax calculated on the income referred to in clause (a) and clause (b), at the rate of sixty per cent; and (ii) the amount of income-tax with which the assessee would have been chargeable had his total income been reduced by the amount of income referred to in clause (i).

A Surcharge of 25% and education cess of 4% are applicable on the 60% tax rate in section 115BBE taking the effective tax rate to 78%.

Section 115BBE(2), as amended by the Finance Act, 2018, provides that notwithstanding anything contained in the Act, no deduction in respect of any expenditure or allowance or set-off of any loss shall be allowed to the assessee under any provisions of the Act in computing income under section 115BBE(1). Since the term ‘or set off of any loss’ was specifically inserted in section 115BBE(2) only vide the Finance Act, 2016, w.e.f.

01.04.2017, an assessee is entitled to claim set-off of loss against income determined under section 115BBE of the Act till the assessment year 2016-17.-CBDT Circular No.11/2019 dated 19.06.2019.

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Sub-section (1A) of section 271AAB provides that Assessing Officer may, notwithstanding anything contained in any other provisions of this Act, direct that, in a case where search has been initiated under section 132 on or after 15-12-2016, the assessee shall pay : (a) a penalty at the rate of 30% of the undisclosed income of the specified previous year, if the assessee— (i) in the course of the search, in a statement under sub-section (4) of section 132, admits the undisclosed income and specifies the manner in which such income has been derived; (ii) substantiates the manner in which the undisclosed income was derived; and (iii) on or before the specified date— (A) pays the tax, together with interest, if any, in respect of the undisclosed income; and (B) furnishes the return of income for the specified previous year declaring such undisclosed income therein; (b) a penalty at the rate of 60% of the undisclosed income of the specified previous year, if it is not covered under the provisions of clause (a); The above penalty shall be in addition to tax, if any, payable by him.

Section 271AAC provides that: (i) The Assessing Officer may direct that, in a case where the income determined includes any income referred to in section 68, section 69, section 69A, section 69B, section 69C or section 69D for any previous year, the assessee shall pay by way of penalty, in addition to tax payable under section 115BBE, a sum computed at the rate of 10% of the tax payable under clause (i) of sub-section (1) of section 115BBE. (ii) However, such penalty shall not be imposed in respect of income referred to in section 68, section 69, section 69A, section 69B, section 69C or section 69D to the extent such income has been included by the assessee in the return of income furnished under section 139 and the tax in accordance with the provisions of clause (i) of sub-section (1) of section 115BBE has been paid on or before the end of the relevant previous year. (iii) No penalty under section 270A shall be leviable in respect of any income referred to in section 68, section 69, section 69A, section 69B, section 69C or section 69D.

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(iv) Provisions of sections 274 and 275 shall apply to penalty under section 271AAC.

Thus, the features of the section 115BBE regime applicable from AY 2017-18, are as under: (i) Voluntary disclosure of undisclosed income by assessee enabled by disclosure in a return filed under section 139. All Income-Tax Return forms for AY2017-18 except ITR-1 and ITR-4 Sugam form envisage disclosure of ‘Deemed income chargeable to tax u/s 115BBE’ in Schedule OS and its break-up as:

Cash credits u/s 68

Unexplained investments u/s 69

Unexplained money etc. u/s 69A

Undisclosed investments etc. u/s 69B

Unexplained expenditure etc. u/s 69C

Amount borrowed or repaid on hundi etc. u/s 69D

(ii) Tax rate increased from 30% to 60% w.e.f. AY 2017-18. Surcharge of 25% introduced. The effective tax rate with effect from AY 201920 (inclusive of 25% surcharge and Health and Education Cess of 4%) shall be 78%. (iii) Voluntary disclosure scheme under section 115BBE has no expiry date. It will be ‘open on-tap’ from AY 2017-18 unless in future section 115BBE is amended again to prohibit voluntary disclosure. (iv) Voluntary disclosure must be accompanied by deposit of 77.25% (78% w.e.f. previous year 2018-19) of the undisclosed income on or before the end of the relevant previous year. Relevant previous year means previous year in return of which voluntary disclosure is intended to be made. (v) Voluntary disclosure should be made before any notice is issued by the Department or before any search or seizure is carried out.

This is important as disclosure has to be in a return filed under section 139-be it original return or revised return or belated return. (vi) If voluntary disclosure not made and undisclosed income is detected in scrutiny assessment or reassessment or through survey (i.e. any manner other than search), then 10% penalty will apply

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under proposed new section 271AAC taking the effective burden to 84.975% (85.8% with effect from assessment year 2019-20) of the undisclosed income. Filing of return in response to notice under section 142 or after survey is conducted will not be regarded as voluntary disclosure. Nor will disclosure in any return filed under section 148 be regarded as voluntary disclosure. (vii) If undisclosed income is detected in any search which takes place on or after 15-12-2016, then in addition to the 10% penalty under section 271AAC, further penalty of 30% or 60% will be levied under new sub-section (1A) of section 271AAB. (viii) No penalty is imposable under section 270A. In Fakir Mohmed Haji Hasan v. CIT [2002] 120 Taxman 11 (Guj.), the Gujarat High Court laid down the following propositions:

The scheme of sections 69, 69A, 69B and 69C of the Act would show that in cases where the nature and source of investments made by the assessee or the nature and source of acquisition of money, bullion, etc., owned by the assessee or the source of expenditure incurred by the assessee are not explained at all, or not satisfactorily explained, then the value of such investments and money, or value of articles not recorded in the books of account or the unexplained expenditure may be deemed to be the income of such assessee.

It follows that the moment a satisfactory explanation is given about such nature and source by the assessee, then the source would stand disclosed and will, therefore, be known and the income would be treated under the appropriate head of income for assessment as per the provisions of the Act.

However, when these provisions apply because no source is disclosed at all on the basis of which the income can be classified under one of the heads of income under section 14 of the Act, it would not be possible to classify such deemed income under any of these heads including ‘Income from other sources’ which have to be sources known or explained.

When the income cannot be so classified under any one of the heads of income under section 14, it follows that the question of giving any deductions under the provisions which correspond to such heads of income will not arise.

If it is possible to peg the income under any one of those heads by virtue of a satisfactory explanation being given, then these provi-

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sions of sections 69, 69A, 69B and 69C will not apply, in which event the provisions regarding deductions, etc., applicable to the relevant head of income under which such income falls will automatically be attracted.

The opening words of section 14 ‘Save as otherwise provided by this Act’ clearly leave scope for ‘deemed income’ of the nature covered under the scheme of sections 69, 69A, 69B and 69C being treated separately, because such deemed income is not income from salary, house property, profits and gains of business or profession, or capital gains, nor is it income from ‘other sources’ because the provisions of sections 69, 69A, 69B, and 69C treat unexplained investments, unexplained money, bullion, etc., and unexplained expenditure as deemed income where the nature and source of investment, acquisition or expenditure, as the case may be, have not been explained or satisfactorily explained. Therefore, in these cases, the source not being known, such deemed income will not fall even under the head ‘Income from other sources’.

Therefore, the corresponding deductions, which are applicable to the incomes under any of these various heads, will not be attracted in case of deemed incomes which are covered under the provisions of sections 69, 69A, 69B and 69C in view of the scheme of those provisions.

In the case of ACT Central Circle-13 Mumbai v. Rahil Agencies, order dated 23 November, 2016 the Tribunal held that section 115BBE does not apply to business receipts/business turnover. The Tribunal observed as under: “19. We have considered rival contentions and found that by applying provisions of section 115BBE the AO has declined set off of business loss against income declared during the course of survey/search. The provisions of section 115BE are applicable on the income taxable under section 68, 69, 69A, 69B, 69C or 69D of the Act. The income declared by the assessee is unrecorded stock of diamond found during the course of search. The assessee is in the business of diamond trade and such stock was part of the business affair of the company. Therefore, since income declared is in the nature of business income, the same is not taxable under any of the section referred above and accordingly section 115BBE has no application in case.”

Section 115BBE does not apply to business receipts/business turnover.

Where AO had accepted after confronting the assessee with facts that

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undisclosed amount of assessee in his bank account was undisclosed business receipts/turnover and made additions applying @ 4% net profit margin on the amount, section 115BBE would not be attracted and revisionary order under section 263 directing AO to apply section 115BBE cannot be sustained. Only probability and likelihood to find error in assessment order is not permitted under section 263, Commissioner ought to find out specific error in assessment order [Abdul Hamid v. Income-tax Officer [2020] 117 taxmann.com 986 (Gauhati - Trib.)]

In Principal Commissioner of Income Tax, 20, Delhi v. Akshit Kumar [2021] 124 taxmann.com 123 (Delhi), it was held that where quantum figure and opening stock was accepted in previous years during scrutiny assessments, receipt from sales made by assessee proprietary concern out of its opening stock could not be treated as unexplained income to be taxed as ‘income from other sources’.

Where nature and source of excess stock found during search was not specifically identifiable from profits which had accumulated from earlier years, AO was justified in holding that said excess stock was not undisclosed investment of assessee and no case of perversity or lack of enquiry on part of Assessing Officer was made out so as to render his decision erroneous under Explanation 2 to section 263. In the present cases, explanations have been offered by the assessees that excess stock was a result of suppression of profits from business over the years and is a part of the overall stock found. In ITA Nos. 9 & 14 of 2021, the assessees concerned gave further clarification that the excess stock had been admitted in Schedule ‘L’ under the heading, ‘other operating income’ under the head “Profits and Gains of the Business” in Part A of the Return filed for the relevant Assessment Year. Hence, the excess stock could not have been treated as ‘undisclosed investment’ under section 69 of the Act. [PCIT v. Deccan Jewellers (P.) Ltd. [2021] 132 taxmann.com 73 (AP)] AO can’t make additions u/s 69A on a hypothetical basis without carrying out enquiry to find out more details. Where assessee sold several flats during year and pursuant to search, a letter addressed to one DS showed that DS paid Rs. 57.73 lakhs towards purchase of flat, whereas agreement value with reference to same was Rs. 49.18 lakhs and Assessing Officer multiplied difference in sale price to number of flats sold and made additions under section 69A, Tribunal having accepted assessee’s explanation that initially said flat was negotiated for a sum of Rs. 59.34 lakhs, however, later booking was cancelled and thereafter it was sold at Rs. 49.18 lakhs to DS, entire additions having been made

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by Assessing Officer without enquiry on hypothetical basis, Tribunal had not committed any perversity or applied incorrect principles to given facts to set aside additions so made [PCIT v. Nexus Builders and Developers (P.) Ltd. [2022] 134 taxmann.com 82 (Bom.)] Where AO made addition under section 68 on account of huge cash amount deposited by assessee-jeweller in its bank account post demonetization, since assessee had explained source of said cash deposits as sales of jewellery, produced sale bills and admitted same as revenue receipt as well as offered it to tax and assessee also represented outgo of stocks which was matching with sales, impugned addition was to be deleted [ACIT v. Hirapanna Jewellers [2021] 128 taxmann.com 291 (Visakhapatnam - Trib.)]

Where assessee-builder received certain on-money receipts from buyers of flats, since nature and source of same being duly accepted by Assessing Officer in remand report, same would construe only as business receipt and not as cash credit under section 68 [Dy. CIT v. Adarsh Industrial Estate (P.) Ltd. [2021] 130 taxmann.com 142 (Mum. - Trib.)]

Where while completing assessment under section 143(3), Assessing Officer did not invoke provisions of section 69 as regards stock surrendered by assessee during survey as undisclosed investment and completed assessment by applying slab rate to it, provisions of section 115BBE which were contingent on satisfaction of requirements of section 69 could not be independently applied by invoking provisions of section 154 [Assistant Commissioner of Income-tax, Circle-2 v. Sudesh Kumar Gupta [2020] 117 taxmann.com 178 (Jaipur - Trib.)]. It would be different matter if AO had called explanation as regards source and nature of undisclosed investment in stock under section 69 but had overlooked it and inadvertently omitted to apply section 115BBE though he was not convinced with the explanation.

In Hari Narain Gattani v. Deputy Commissioner of Income Tax, Circle-04, Jaipur [2021] 123 taxmann.com 8 (Jaipur - Trib.), it was held that there was nothing stated in either pre-amended or post-amended provisions of section 115BBE that where assessee surrenders undisclosed income during search action for relevant year, tax rate has to be charged as per

Taxation of Loans Gifts & Cash Credits AUTHOR PUBLISHER DATE OF PUBLICATION EDITION ISBN NO NO. OF PAGES BINDING TYPE

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Taxmann TAXMANN MAY 2022 11th Edition 9789356220515 604 PAPERBACK

Rs. : 1495 | USD : 54

Description This book provides a comprehensive analysis of the provisions relating to undisclosed income, gifts of money & movable/immovable property, along with relevant case laws.

The relevant provisions of the Black Money (Undisclosed Income & Assets) Imposition of Tax Act 2015 and the Prohibition of Benami Property Transactions Act 1988 are also discussed.

In other words, it analyses the taxability arising from the following: · Undisclosed Income; In light of the Income-tax Act 1961 & Black Money Act provisions. This section also includes: o Case Laws

o Ready Reckoner for legal consequences of investments under various laws, depending on the source & nature of income invested and the manner of investment of income · Donee-based Taxation of Gifts of Money received by any Person. This section also includes: o Ready Referencer for relatives to whom gifts may be made without attracting tax in the hands of the recipient

· Taxation of Gifts of Immovable Property received by any Person, i.e., the property received without consideration or received for consideration less than stamp duty value. This section also includes: o Ready Reckoner for summarising the tax implications for transfer-

or/donor and recipient/donee of transfers of immovable property

· Taxation of Gifts of Specified Movable Property (including jewellery, shares & securities, bullion, work of art, virtual digital assets, etc.) received by any Person.

This section also includes: o Ready reckoner for the tax implications for transferor/donor and recipient/donee of transfers of specified movable property

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