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SERIES
  • 7/2/2025
Transcript
00:00:30Income from units, especially income from units. Purchased in foreign currency.
00:00:48In the same time, it is taxable.
00:00:51That is income, even capital gains.
00:00:54Dividend income and capital gains.
00:00:56Applicability is offshore fund.
00:01:00Overseas financial organization is offshore fund.
00:01:03Offshore fund, in the foreign land, India invest in offshore funds.
00:01:08Overseas financial organization.
00:01:10Income from units purchased in foreign currency.
00:01:15Long term capital gains on transfer of such units.
00:01:18Income of 10% long term capital gains.
00:01:2123 July, 10% and 12.5% will be allowable.
00:01:26Detections.
00:01:27Where is the claim?
00:01:30Section 28 to 44C.
00:01:34Income from other sources.
00:01:36Detection to Section 57.
00:01:38Detection chapter 80 series.
00:01:40Detections claim.
00:01:41In the case, Section 48.
00:01:43Second provision.
00:01:44Forex exchange losses adjust provisions.
00:01:45You understand.
00:01:46Not applicable to long term capital gains.
00:01:47So, Overseas financial organization.
00:01:49Foreign entity with SEBI approved investment India.
00:01:50That will come here.
00:01:51Units of mutual fund.
00:01:52Unit trust of India.
00:01:53Foreign currency.
00:01:54Femma will NSO.
00:01:55Okay.
00:01:56Special notes.
00:01:57Tax computation.
00:01:58Pannam.
00:01:59Overseas financial organization.
00:02:00Foreign entity.
00:02:01With SEBI approved investment.
00:02:02India.
00:02:03That will come here.
00:02:04Units of mutual fund.
00:02:05Unit trust of India.
00:02:06Foreign currency.
00:02:07Femma will NSO.
00:02:08Okay.
00:02:09Special notes.
00:02:10Tax computation.
00:02:11Pannam.
00:02:12Pannam.
00:02:13Pannam.
00:02:14Pannam.
00:02:15Pannam.
00:02:16Pannam.
00:02:17Pannam.
00:02:18Pannam.
00:02:19Okay.
00:02:20Special notes.
00:02:22Units of debt.
00:02:23Tax computation.
00:02:24Pannam.
00:02:25Unit in income.
00:02:26Capital gains.
00:02:27Okay.
00:02:28Remove for the deduction chapter.
00:02:316A.
00:02:32That's the unit income.
00:02:34Capital gains.
00:02:36This is 5 lakhs.
00:02:39This is 10 lakhs.
00:02:40Other income.
00:02:413 lakhs.
00:02:42You can claim on this amount.
00:02:43Not this amount.
00:02:45You can claim only on this amount, not this amount, either claim.
00:02:54And TDS was similar, so no need to file the return of income here.
00:03:01Section 115 AB, clear, the income tax, 10 lakhs being long term capital gain received
00:03:10by an overseas financial organization and transfer of unit purchased in foreign currency.
00:03:1523rd July 24th, 100 year before, 10 lakhs, that is 10% on the tax, 1 lakh, health and education
00:03:25says 4% will be on this.
00:03:29So 1.04 lakhs will be the overall amount payable.
00:03:32On or after 23rd July, 12.5% will be levyable.
00:03:38So AB patho, then now we will move on to the AC.
00:03:47Section 115 AC, tax and income from bond, ithila varam poodhu namak yenna patho, foreign
00:03:55karanis ila vahanga kude units, especially UTA units or other units, notified units.
00:04:00115 AC varam poodhu bondu varudu, bondu global deposited resets purchased using foreign currency.
00:04:09Bono illustration maari thang foreign currency used pundi vainge kudpaar.
00:04:12Bondu'm GDR um in the 115 AC yelavarudu.
00:04:16Yaur kaik applicable lepdi cvoknakka non resident?
00:04:18Bond arundhah unggelik interest varulaaam, alladha GDR arundhah dividend varulaaam.
00:04:22GDRR is a dividend, but if you have long term capital, you will have 3% income.
00:04:30GDRR is a dividend. Global Depositor Resists.
00:04:35So, if you share stock market in India, you will have a list of American Depositor Resists.
00:04:51So, when you compare stock market in India, you will have a list of shares.
00:04:55If you compare stock market in India, you will have a list of shares in India.
00:05:03So, if you compare stock market in India, you can compare stock market.
00:05:09and the GDR one thing is that you invest in the amount of the GDR one thing is that you invest in the amount
00:05:15and the dividend is that the shares are equal to the shares
00:05:20tax rate and interest and dividend is 10% long term capital gain
00:05:24this is not the same rules
00:05:28conditions one thing is that no deductions under these sections will be available
00:05:33PGBP deductions claim to be able to claim, the loan of PGDP deductions claim to be able to claim, the benefits of the loan.
00:05:50.
00:06:07.
00:06:11.
00:06:18.
00:06:19.
00:06:19.
00:06:19.
00:06:19.
00:06:19.
00:06:20.
00:06:20.
00:06:20You can see that the TDS is fully detected in the case of the TDS.
00:06:25This is applicable to bond and GDR.
00:06:30Applied to bonds and GDR received during the amalgamation demerger cases under bond and GDR
00:06:35you can transfer the provisions applicable.
00:06:38Okay, and this is approved intermediary, this definition is as per section 115 AC.
00:06:48Main concepts are over AC that.
00:06:52Then we will move on to the ACA.
00:06:55It is a logical one.
00:06:57It is the tax on income from GDR purchased in foreign currency.
00:07:03Okay, it is GDR purchased in foreign currency.
00:07:06Especially, it is a foreign currency.
00:07:11Resident employees of Indian company.
00:07:14So, it is non-resident required.
00:07:18Okay, 115 ACA, resident employees of Indian companies or subsidies in specific knowledge-based industries.
00:07:25IT, Pharma, Biotechnology.
00:07:28That's the same thing that you invest in Indian company.
00:07:31You invest in GDR as well.
00:07:33You invest in GDR as well.
00:07:35Okay, you purchase in foreign currency, but you are being the resident employee.
00:07:40Okay, so in the company, you are resident.
00:07:43Earning dividend as well as long term capital gain.
00:07:45Dividend on the 10% long term capital gain.
00:07:48Addition, 10 and 12.5%.
00:07:50What about the deductions, sir?
00:07:52There are no deductions allowable under any sections for dividend and long term capital gain.
00:07:58PGV claims claim claim claim claim claim claim claim claim claim claim claim claim claim claim claim profitability.
00:08:00Now, the 1-1-5 ACA, the Indian resident, Indian company, GDRY,
00:08:30in the professions will be applicable. Then, special, specific knowledge-based industries
00:08:37are called Pharma, IT, IT services, entertainment, biotech, etc.
00:08:42GDR, again, instruments issued against shares of the Indian and public companies or convertible bonds listed in recognized exchanges or IFSC.
00:08:53Okay, so, India will have infosys, US list list, where are you?
00:08:59ADRs are. That is the IFSC. Okay, so, gift is set in Gujarat, Gandhi, Gujarat, Gujarat, Gujarat,
00:09:08Gujarat, and IFSC, you can invest through that.
00:09:11That is rooted through that. BSC, NSC, IFSC. Otherwise, any recognized exchange.
00:09:16And, of course, filing exemptions, full TDS detected.
00:09:22Income includes only such a dividend long-term capital gain.
00:09:26Where income will not be taxable. Is that clear?
00:09:31Now, let's move on to the next one.
00:09:351, 1, 1, 5, AD. 1, 1, 5, AD. Okay.
00:09:41So, 1, 1, 5, AD.
00:09:43Tax on income of foreign institutional investors and specified fund from specified securities and capital gains. Okay.
00:09:51Foreign institution. Okay. Foreign institution investors.
00:09:55And, specified funds are invested. Our securities and capital gains are capital gains. Okay.
00:10:03So, eligible entities are foreign institution investors and specified funds are available.
00:10:10Specified funds are available. Trusting chapter.
00:10:13You can study specific funds.
00:10:16Investment trust and specific funds.
00:10:20So, foreign institutional investors are available. Okay.
00:10:49The two to share funds, which is very few of the investments.
00:10:50So, when you pay, you and you buy a dividend, you buy a dividend or any interest.
00:10:54You buy a revenue price.
00:10:59Whatever it may be.
00:11:00You understand now.
00:11:01So, this will be the case.
00:11:03That means, specific funds that are available from India.
00:11:08In India, there are specific funds.
00:11:16Investment trust.
00:11:17investment trust or the fund could have collected from various investors.
00:11:26Mutual fund to begin with.
00:11:28Third party to collect the third party.
00:11:31If you want to repatriate this,
00:11:38this is applicable in the component.
00:11:41So, one foreign institution is completely applicable.
00:11:44Specified funds could have collected the money from Indian investors or outside India investors.
00:11:50To the extent of income, attributable to non-resident unit folders.
00:11:55Units, mutual funds, mutual funds.
00:11:57Offshore banking units.
00:12:00Offshore banking units.
00:12:02Attribute funding income.
00:12:05That is applicable.
00:12:08Securities.
00:12:11Securities.
00:12:15Excluding section 115 AB units.
00:12:17115 AB units.
00:12:19115 AB units.
00:12:20Okay.
00:12:21So, let's see.
00:12:22115 AB units.
00:12:24Foreign currency.
00:12:25Purchase units.
00:12:27Especially overseas financial organization.
00:12:29Eligible assisi.
00:12:30If you don't understand.
00:12:31You would have to estimate of that asset,
00:12:33then you would have to estimate the money.
00:12:34You would have to estimate the money.
00:12:36You would look at capital gains.
00:12:38Capital gains.
00:12:40When it becomes吉利,
00:12:41If you are a certain money,
00:12:42$10 million and $11 million.
00:12:43Income from securities,
00:12:44all you have to be paying for the $10 million.
00:12:46If you go to an income from $11 million,
00:12:49will be taxed rate and specific fund 10% will be there and interest under section 194LD
00:12:57around the TDS 5% will be applicable 5% TDS this is all about TDS so foreign
00:13:05institution investors received in that 20% where are the specific fund 10% or interest
00:13:12under section 194LD TDS will also be applicable it will be income from securities short term
00:13:18capital gain and interest in general 30% if you have 111A and interest in 20th July 150
00:13:24normal long term capital gain and interest in 20 long term capital gain and interest in general 10% especially
00:13:32112A and interest in 12.5% so this will also be getting changed
00:13:41now now let us see if a 112A were in this one 112A would a provision set the club see 23rd July 24
00:14:03in this case 12.5% of the long term capital gain in excess of 1.25 lakhs is that okay normal long term capital gain
00:14:09on or after 23rd July 24 in this case 12.5% of the long term capital gain in excess of 1.25 lakhs is that okay normal long term capital gain
00:14:15out of prova patient sou
00:14:31what about the dections from the PGB play in the directions are pure from other sourcesBuilder
00:14:41and chapter 6 CLE you will need to claim any deductions.
00:14:45Indexation benefit enjoy.
00:14:49In the attribution rule, for specific funds income is taxable only to the extent it is
00:14:54attributable to the eligible unit holders or offshore banking units. Attributable rules
00:15:01in the trust path you will learn clarity. No need to worry about that.
00:15:06That's the information that we can do. Investment trust, business trust.
00:15:11Trust is a purpose. Trust is a fund or business trust.
00:15:15What do you want to do with various investors?
00:15:19Units sale and collection. Money might have come.
00:15:26This is why you want to do a business or a portal industry or very very infrastructure related industry.
00:15:34If you invest in the hotel industry, that will be capital gains.
00:15:38If you invest in the hotel rental, you will be PGBP income.
00:15:42If you invest in the hotel industry, you will be able to pay the income from house property.
00:15:46What's the mode of the industry?
00:15:48That will distribute you.
00:15:50That will be automatically.
00:15:52What do you distribute this infrastructure?
00:15:55It will be the unit holders.
00:15:58The unit holders are not only foreign to the investment.
00:16:01Who invest in the foreign?
00:16:03Non-resident or offshore banking units.
00:16:06The only extent to this.
00:16:10If you invest in the local investors, you will get 40% of the capital gains.
00:16:15If you invest in the capital gains, you will get 60,000 and 40%.
00:16:20We are talking about this component only, not this component, attributable rules.
00:16:26For specified funds, income is taxable only to the extent it is attributable to the eligible
00:16:32unit folders or offshore banking. Income of non-resident sportsmen, sports association,
00:16:42entertainment, entertainers. So, 194, 194 TDS is also applicable here.
00:16:55Now, let us see here. In the non-resident report, TDS part, we will go to the chapter, 194 E,
00:17:25okay, I think also be included, yes. 194 E is also included, okay.
00:17:32So, now, three, non-resident sportsmen, sports association, entertainers.
00:17:38Income of 20 more than that, non-resident sportsmen are participation in games,
00:17:46but in India, any publications article related to the games and sports published.
00:17:51And in the games level, 115 BB level games are included. Excluding games taxable section 115 BB,
00:18:00online games are included. Advertisement representative
00:18:06that will also be included here. That will also be included. Is that clear?
00:18:10All right.
00:18:14All right.
00:18:53Yeah, I think there is slight hiccup, hope now it got cleared.
00:19:03Yes, so 115 BBA, non-resident sportsmen, sports association entertainers, non-resident
00:19:14sportsmen including athletes, the income from games or sports participate in India,
00:19:22advertisement in the brand ambassador, they act as a payment.
00:19:27Any Indian publications, games and sports related articles publishes because of the remuneration.
00:19:32In the 3 income taxable, but 115 BBA, BB is not available.
00:19:36This is online gaming, so online gaming is not available.
00:19:41Now, non-resident sports association institutions,
00:19:46they have guaranteed income related to the games and sports in India.
00:19:51India will be contacted, they have income.
00:19:54Okay, some sports association, India will have a joint event in India,
00:20:01that is guaranteed.
00:20:02Guaranteed amount.
00:20:03Foreign in India, sports association, that is called guaranteed income.
00:20:09Entertainers.
00:20:10Entertainers, income from performances in India.
00:20:14Any performances, entertainment event.
00:20:16are they offered.
00:20:17They offered professional players, the senior actors, the fundraising program,
00:20:26they used to join and they returned to the mary.
00:20:28So, that would be non-resident entertainers,
00:20:34The tax rate is 20% of filing is no return required under section 139 class 1.
00:20:41This is save and done.
00:20:43Provided tax has been detected at source under section 194E.
00:20:50Detects you will save.
00:20:52Especially if you don't have any income,
00:20:55you don't have filing of return to 139 class 1.
00:20:59Now, how many detections you will claim?
00:21:04As well as detection under section 80 series claim?
00:21:09Capital gains is applicable to you.
00:21:13Where it is,
00:21:16tax rates and rules are compulsory.
00:21:20Tax rates and rules are compulsory.
00:21:24Basic exemption is a basic exemption.
00:21:270-3 lakhs, no tax.
00:21:30It is applicable to you.
00:21:32Calcutta HC, High Code ruling,
00:21:35income of a non-resident of umpires and referees is taxable in India.
00:21:40Umpires and referees are taxable in India.
00:21:43That is also falling into this.
00:21:46But not under section 115BBA.
00:21:48It is 115BBA.
00:21:49It is 115BBA.
00:21:50It is 115BBA.
00:21:51So, umpire and referee are sports persons.
00:21:53So, if you are applying section 195,
00:21:56TTS will be applicable at the rate specified under section 195.
00:22:01So, whenever you are making any payment outside India,
00:22:04automatically majority cases, 195 section will be applicable.
00:22:07So, that is how 195 is.
00:22:09But in case of sports person,
00:22:11194E will be applicable.
00:22:13So, we will see all these things right in subsequent lecture.
00:22:16So, 115BBA is over.
00:22:19Maximum with alone the rate on the 20 percentage.
00:22:22Let us see.
00:22:24Roger Federer, a tennis professional and non-Indian citizen,
00:22:28participated in India in a tennis tournament and won the prize money of his 15 lakhs.
00:22:34Okay.
00:22:35So, price money from 10 news tournament, 15 lakhs.
00:22:43He contributed article on the tournament in a local newspaper for which he was paid 1 lakh.
00:22:48Okay.
00:22:49Article 11 of the newspaper.
00:22:51He was also paid 4 lakhs by a software company for appearances in TV advertisement.
00:22:58So, brand ambassador and advertisement to the advertisement,
00:23:01he participated in another 4 lakhs.
00:23:04Although his expenses in India were maybe by the sponsorer,
00:23:08he had incurred 1 lakh 30,000 twice as his travel cost to India.
00:23:11Not detectable.
00:23:12Any expenses you can detect?
00:23:13He was a non-resident for the purpose of eating India.
00:23:16What would be his tax liability and reception for the Assessments in 25-26?
00:23:21Is he required to file his return of income?
00:23:23If you have 4 lakhs, it is 20 lakhs.
00:23:26You will have to file 1-15 BBA will be applicable.
00:23:30As per that provision,
00:23:3120% tax will be leviable.
00:23:33So, that is 4 lakhs.
00:23:35And health and education says,
00:23:37will always be applicable to the rate of 4 percentage.
00:23:394 percentage being 0.16 lakhs.
00:23:41So, 4.16 lakhs will be the amount payable.
00:23:45END ORI Detections,
00:23:47NEED CLAIMPANNAM MUDIYADU?
00:23:49ROA THEEVAY YAH?
00:23:50APPLYNCZEVA YAH?
00:23:51APPLYNCZEVA YAH?
00:23:52APPLYNCZEVA YAH?
00:23:53EPDCZEVA YAH?
00:23:54EPDCZEVA YAH?
00:23:55EPDCZEVA YAH?
00:23:56EPDCZVA YAH?
00:23:58EPDCZVA YAH?
00:24:00okay clear up a pannhi yurundhal roi namakthu teba illa okay
00:24:05you there were other payment to the non-resident arnal 195 will be applicable so 194 e enjoy
00:24:12adhaathu velandri day or sambadhi kera arphinga tha he is a mind lo chikathu enjoy and chul
00:24:16irukkarein sports persons iku tedious piti kathu non-resident arnal 194 e will be applicable
00:24:21and the rate on the 20 plus 4 percent health and education is an applicable surcharge will
00:24:26be applicable right so the same logic will be applicable so ibarrikkapodutharikim tax
00:24:30card of India was similar and the player good tax card of India was similar next question
00:24:36sumit a foreign national and cricketer came to India as a member of australian cricket team in
00:24:44the year ended 31st march 25 he received five lakhs for the participation in match so match
00:24:49the participate 100 match fee five lakhs he also received one lakh for an advertisement of the
00:24:59product on tv of your product on tv tv advertisementu kagha your brand ambassador
00:25:06participate pannar adhu kore oor lakshirva kakaracchiririkku he contributed article in the newspaper which he received 10,000 rupes article
00:25:13adhu kagha over kore 10,000 rupes fee vondirikku when he stayed in India he also won a price of rupes 10,000 rupes from horse race in Mumbai horse race in Mumbai
00:25:25so horse race that is special income pa adhu 115 BB level casual income BB as well as online gaming
00:25:32so in the future this will be taxable 30% so these are the flat rate 30 % will be taxable in the 30,000 rupes in the 30,000 rupes in the US will be separate tax
00:25:42ignore the provisions of section 115 b se 115 b se that the default tax regime and complete the tax tax
00:25:536.1 lakhs and this is another 10,000 rupees, it is special income, it is a horse race
00:25:59in the last 10,000 rupees, that is 6.2 lakhs, it is the total income, okay, now in the total
00:26:11income, 6.1 lakhs balance 0.10 lakhs, it is the 115 BB income, casual income, so in the
00:26:22casual income, you know, 30 percentage tax cut down which is 3,000, it is 20 percentage
00:26:27tax cut down, 20 percentage in general, 1 lakhs 22,000 rupees, so the overall value being
00:26:331 lakhs 25,000 rupees, you have to add health and education says at the rate of 4 percentage,
00:26:38so 4 percentage being 5,000 rupees, so 1 lakhs 30,000 rupees is the ultimate tax payment here,
00:26:45clear, what about the TDS sir, in the amount of TDS, in the amount of TDS, sports
00:26:51nalavarambadhu, 194 ee padhi, 194 ee padhi, you will get TDS on the, TDS all up to
00:26:57chanakka, 1 lakhs 22,000, it is 4 percentage putting na, 122 into 4 percentage, 4,000 880,
00:27:071 lakhs 26,000, 1 lakhs 26,000 880 will be that TDS may be directed, right, now the question being,
00:27:18complete the tax liability of smith and co, and are the income specified above subject
00:27:24to the deduction of tax at source art, yes 194 ee will be applicable, is he liable to file
00:27:31his return of income, the next question, of course other income under Dalya, other return
00:27:36of income, what would have been his tax liability, here he been, had he been a math referee instead
00:27:49of cricketer, cricket level referee and the referee, in the provision 115 BAA provision will not be
00:27:56applicable, okay, 115 BBA provision is applicable only for the sports person, 115 BBA is not applicable,
00:28:08not applicable, not applicable to the regular tax, you can calculate it, okay, regular tax
00:28:14for them both, you can calculate it when you get casual income in the direction similar
00:28:20level, more than 30 percent is taxable, okay, either were both our regular income, every
00:28:26tax for a month, money tax protocol, so I think, 0 in the 3 lakhs where I come, 115 BAC went on
00:28:36and then, ignoring the provision, 0 to 2.5 lakhs where I come, no tax, 2.5 lakhs where I come,
00:28:475 percentage, 10 lakhs where I come, 5 lakhs where I come, 10 lakhs where I come, 6.1
00:28:541st, right?
00:28:55Thriller at 1.1 and that's 20 percent page range okay 22 thousand then 34, 500 , 34,500 for
00:29:08this income, okay, okay and 4 one one five biscuits cash kingdom come, oh, the tax in the mid
00:29:20the maryland park company a flat rate 30 percentage will be tax amount 37 500 of course you have to
00:29:27had a health and education says with this on this four percentage will be taxable 37 500
00:29:33into four percentage 1500 then overall value being 39 000 overall value being 39 000
00:29:45now
00:29:50let's move on to the next one
00:30:11section 115c
00:30:13foreign exchange
00:30:20foreign exchange considered
00:30:24convertible by rba under fema act okay
00:30:27It may have been clearly defined under the section under the FEMA Act but it is out of
00:30:45scope.
00:30:46Foreign exchange assets where assets acquired are purchased in foreign exchange, foreign
00:30:54currency, probably shares in Indian company, debentures of Indian company, deposits of Indian
00:31:02company not being the private company, central government securities and other assets notified
00:31:06by the central government.
00:31:07Over cases, taxable.
00:31:09Investment income, foreign exchange assets, long term capital gains, it may be short term
00:31:17as well as long term.
00:31:19Capital gains are long term, short term is not long term capital gains.
00:31:23Indian citizen or person of Indian origin who is not a resident.
00:31:28Indian citizen is not a resident.
00:31:30Indian citizen is not resident Indian.
00:31:32Non resident term is not resident Indian.
00:31:35Indian born and brought up but he is not being resident for Indian taxation calculations.
00:31:42We need to know the rats and to know the defendants and their parents or grandparents who were
00:31:48born in undivided India.
00:31:50Our parents have served here with the population.
00:31:51The notion of the financial loans in Indian is not easy to find the estate.
00:31:53But the notion of the trial has allowed us to know.
00:31:54Now, if you are not eligible for claiming any deductions, you are not eligible for claiming any deductions.
00:32:14This is the 115D. No deductions for investment income, you cannot claim any deductions.
00:32:26Gross income consisting only of investment or long term capital gain. Investment to income or long term capital gain is not available.
00:32:34So, chapter 6A in the deductions are not available and indexation benefit is also not available.
00:32:45Mixed income, you may have including investment or long term capital gain. Investment income includes interest or dividend.
00:32:54The income includes investment income, long term capital gain. Such income will be excluded from gross total income for chapter 6A.
00:33:02If you are not available in chapter 6A, you are not available in chapter 6A. You are not available in chapter 6A.
00:33:08You are not available in two income. If you are not available in investment income or long term capital gain, others are available in section 6A.
00:33:16That is the deduction into section 80 series. So, this is the general provisions under section 115E.
00:33:23Now, 115E. Tax and investment income and long term capital gains for NRIs. NRI case.
00:33:33This is applicable for non-design in Indians.
00:33:37That is the investment income, long term capital gain from assets other than specified assets.
00:33:43This is the investment income, capital gains long term capital gain from any other assets.
00:33:47This is the investment income, capital gains long term 10% or 12.5% usual date in mind check.
00:33:55And remaining income is the regular tax.
00:33:57The tax is the 115E. So, specified income is the special tax date.
00:34:03Investment income is the 20% long term capital gains.
00:34:07And long term capital gains are finished 10% or 12.5%. Remaining income is the regular tax.
00:34:15Now, section 115F. Capital gains and transfer of foreign exchange assets.
00:34:21NRI would be foreign exchange assets you can transfer.
00:34:25Okay. Non-resident income. Okay.
00:34:27Now,
00:34:31Now,
00:34:35If you look at the non-resident income, you are confused by the non-resident income.
00:34:42The non-resident income is not born and brought up.
00:34:49If you look at the non-resident income, you will see the non-resident income.
00:34:53Indian citizen or person of Indian origin.
00:34:56But who's status is not resident.
00:34:59Even there is a non-resident income in India and life remains where the non-resident income.
00:35:08It has been recently Hari's case so we will see the non-resident income.
00:35:14Recently, it records as a non-resident income, then hold down the bottom.
00:35:19We will see for buying as an independent insurance company in the bottom of thegend筆.
00:35:24using the foreign exchange, but the debenture, deposits, central government securities,
00:35:28that are foreign exchange assets. And the foreign exchange assets, you have capital gains on transfer.
00:35:35Okay, capital gains on the transfer of foreign exchange assets are exempt from tax. If the
00:35:40proceeds are reinvested in new specified assets within six months, if you have foreign exchange
00:35:45assets within six months, you have exemption from India within six months. And the exemption
00:35:52on the proportion exemptions, you have capital gains on the section 54F and the deductions
00:35:58regarding the proportionate deductions will be available. That is the sale consideration. Expenses
00:36:04on transfer is 595. This is the net sale consideration. In the net sale consideration,
00:36:11the cost of acquisition is 50 less than 45 being long term capital gains. In the 54F,
00:36:18if you have invested in 60 rupees, you invest in 50 rupees, if you have invested in 50 rupees,
00:36:2450 rupees, 50 rupees You have invested in 50 rupees . Now, in 50
00:36:27rupees is taxable. But, 50 rupees is a cost of pick and $50. Okay,
00:36:31the investment is long term capital gains , but the investment is not
00:36:38In the extent we have deductions claim. Long-term capital gain is 45, but we have to invest.
00:36:45And the net sale consideration is 95. So, 45 into 40 by 95, only 19 rupees we have deductions claim.
00:36:57In this concept, we have 115F NRA. Long-term capital gain into cost of new assets divided by net conservation can be deductible.
00:37:06In this case, you hold the assets for minimum 3 years. This is similar to section 54F.
00:37:12If the new assets are transferred or converted into money within 3 years, the uncharged capital gain is taxed as the income under the capital gain.
00:37:18Uncharged amount in the 19 lakhs. In this case, the 19 lakhs will be taxable.
00:37:24If you have exemptions claim, the exempted amount will be taxable. 115F.
00:37:29Now, if you look at the case, the NRA has filed in the case of tax returns, the NRA has filed in the case of tax returns.
00:37:41The TDS will be found that the investment income, long-term capital gains, or two.
00:37:47In this case, the NRA has filed in the case of tax returns, the return of income file is filed in the case of tax returns.
00:37:53Is that clear?
00:37:54If we apply this, we will apply this section.
00:37:57In this case, we will apply this section in the section series.
00:37:59That is the alphabet itself to the PTA
00:38:11that is found throughout the other year.
00:38:13you have a simple answer. Now, if 115H, NRI are required to make benefits, later on
00:38:29our resident are married. So, foreign exchange asset, foreign assets, foreign assets, in the
00:38:40foreign assets, NRI are required to make benefits. Now, our residential status is finished.
00:38:48Will he be able to enjoy the same status what he has already enjoyed? Of course, he can enjoy.
00:38:53Proportionate detection salami claim. Provided NRI are required to make assets,
00:39:01you have to declare to the assessing officer along with the return of income.
00:39:16In the declaration, investment income for foreign exchange assets, you have to give a policy
00:39:21to the country. If you want to give a country, you have to give the assets to the country.
00:39:27So, this provision applies for the assessment year in which the declaration is made.
00:39:33So, what is the case of the foreign exchange assets? Suppose, 24, 25.
00:39:40You have to be NRI are required to make assets. NRI are required to make assets.
00:39:44Foreign exchange assets. You have to be resident. Resident to be resident.
00:39:50You have to be resident. You have to follow up to the same provisions.
00:39:54So, 115 E provision. In the provisions, you follow up on the one and then exemption also
00:40:01be available under section 115 F. Enjoy it, but you have to declare.
00:40:06If you declare it, you can use the assets and cash. For all subsequent years until the
00:40:16asset is transferred or converted into money. So, eligibility continue for continued benefits.
00:40:22Non-Resident India, who becomes resident in India, can continue to avoid the benefits under
00:40:28the same chapter, even after becoming the resident. So, in the case of return of income,
00:40:34you can declare the foreign exchange assets in the form of income, and you can enjoy the
00:40:40tax. But in the compulsory regard, the optional. So, around the section 115, the above provisions
00:40:46are optional. Means any ASSEE can pay normal tax long-term capital gain as well as investment
00:40:51income instead of this one. Around the 10, above the 12.5 euro. It is well in your regular
00:40:55tax. 10 percentage are 12.5 percent. Is that clear? Okay. And the 23rd July
00:41:05is that, if you have a 10, above the 10, above the 10, above the 10, above the 10, above the
00:41:09percentage. That is clear. Section 115 J. G. Now, especially Indian branch of a foreign company
00:41:23as well as a foreign company as well as a foreign company. It is completely under their control. Sometimes
00:41:25later, the branch of foreign company as well as a subsidiary of the foreign company as well as a
00:41:42company as well as a subsidiary of the foreign company as well as a subsidiary of the foreign company. Okay.
00:41:54At other countries, the foreign company as well as a subsidiary of assets and
00:41:57liabilities. planet of the foreign company in property and at set of corporate
00:42:08company as well as a subsidiary of the foreign company, supply and demand federal
00:42:13debt of the funds and贏. However, the broad and couple half of the foreign company
00:42:15the assets and liabilities of branch of foreign company becomes assets and liabilities of subsidiary
00:42:24company in liya.
00:42:25Aparadhe transfer abding chunnak section 47 transfer yudhu.
00:42:29Section 47 transactions are not considered as a transfer abding chunnak section 47 transactions
00:42:32are not considered as a transfer abding chunnak section 47 transactions are not considered
00:42:35as a transfer abding chunnak case le ith taxable laga varahadhu.
00:42:38Is that clear?
00:42:39Now, section 47, capital gains tax exemption conversion of Indian branch, especially in
00:42:45the applicable on the foreign bank into Indian subsidiary company is not taxable under capital
00:42:50gain provisions in if certain condition, but the conditions fall upon here.
00:42:55Amalgamation branch amalgamates with an Indian subsidiary as per the approved scheme.
00:43:00Okay, Indian subsidiary company should be amalgamated with Indian company.
00:43:12holders are not considered as a transfer of all assets and liabilities should be happen at book value,
00:43:15independent value.
00:43:16And shareholding.
00:43:17And shareholding.
00:43:18I think more than a percentage of these other companies are not considered as a transfer
00:43:23You can hold 100% shareholding here.
00:43:27But if you have a new company, it is a new shareholding.
00:43:31If you have a new shareholding, you can hold 100 shareholding.
00:43:40If you have a new shareholding, you can hold 51% for at least 5 years.
00:43:52In the same case, the existing ab attempt to be a new shareholding.
00:43:57If you have a new shareholding, it is a new shareholding.
00:44:00If you have a new shareholding your assets, you can trust your assets.
00:44:06Also, you can hold 50% shareholding.
00:44:09No other consideration.
00:44:17The Indian subsidiary must not receive any consideration.
00:44:20Indian subsidiary, Indian subsidiary as well as shares model.
00:44:24If you have inter-level section 47 amalgamation demerger chapter,
00:44:29it will be more or less similar to section 47 as well as section 48.
00:44:34That's why I tell you, if you just finish off inter-levels,
00:44:37means 100% sure, then final will be pretty simple.
00:44:41Now, let's see here, revaluation restrictions.
00:44:45Okay, so if the assets you need to transfer,
00:44:50any revaluation assets during the transfer will not be considered.
00:44:53Transfer is done. Transfer is done.
00:44:55Transfer is done. Revaluation is done.
00:44:57Foreign company branch, branch of foreign company.
00:45:03Then, later on, subsidiary company, India is foreign company.
00:45:10Plus, Indian company, investors, and investors.
00:45:13Okay.
00:45:14Then, if you want to transfer assets to land and building,
00:45:18probably 100 lakhs,
00:45:20if you want to land and building value,
00:45:22150 lakhs, no.
00:45:24150 lakhs can be done.
00:45:26Why?
00:45:27If you want to transfer assets to the company,
00:45:29cost is 150,
00:45:31less than 50 rupees gain.
00:45:35But if you want to transfer,
00:45:37if you want to transfer,
00:45:38if you want to transfer,
00:45:39if you want to transfer,
00:45:40if you want to transfer,
00:45:41if you want to transfer,
00:45:42then the cost of the previous owner will be taken.
00:45:44100 rupees.
00:45:45Then,
00:45:46if you want to transfer,
00:45:47if you want to transfer,
00:45:48there may be chances of violation.
00:45:49You have to consider only the book value,
00:45:50while transferring the assets from foreign branch.
00:45:52in the subsidiary company.
00:45:53Right.
00:45:54Some modification.
00:45:55Depreciation.
00:45:56Depreciation.
00:45:57In the previous year,
00:45:581st July,
00:45:5924th,
00:46:00that is foreign branch.
00:46:02You have to commit a complete calculation for the following year.
00:46:04Queue your full year depreciation.
00:46:05If you want to defer to the previous year,
00:46:06First of July,
00:46:0724th,
00:46:08that is foreign branch,
00:46:10which is complete and became an international company.
00:46:12You want to defer to the full year depreciation.
00:46:14From the previous year,
00:46:15you have to debit a full year depreciation.
00:46:17If you would have to debit,
00:46:18for this year's period you have to debit for some branch to a branch.
00:46:20For this year,
00:46:22if you did bonds of foreign company,
00:46:23they were out to debit that.
00:46:24Unlike the Inter,
00:46:25if you would learn the proportionate depreciation,
00:46:26if you wanted to pay for the year,
00:46:27if we saw a division from the Inter.
00:46:28Suppose, one of the 1st year depreciation, opening WDV being 1 lakh.
00:46:35The 15th year depreciation is null.
00:46:37Up to this period, the 4,000 is subtracted.
00:46:426,000 will be the WDV value.
00:46:451 lakh 4,000 is 96,000.
00:46:51This 96,000 is the WDV value for the company.
00:46:55Now, this is another 6,000.
00:46:58This is the company's depreciation.
00:47:00Closing WDV, 90,000 comes in.
00:47:03Is that okay?
00:47:04So, up portion based on the usage by Indian branch and surgery for the conversion year.
00:47:09Okay.
00:47:10This is the WDV of the assets.
00:47:14Surgery assets block value equals the branch's WDV on the date of conversion date.
00:47:20That was 1 lakh day, 90 day, 96 will be the WDV value here.
00:47:24And the WDV value in the 6,000 less 0.18, closing value will be 90,000 rupees.
00:47:29That is how you can show.
00:47:30And what about the set-off carry forward, sir?
00:47:32Yeah, of course, set-off carry forward you can do.
00:47:34Losses can be carried forward for 8 more years.
00:47:37Further 8 years.
00:47:38Here we go.
00:47:39Now, the previous year loss was 4 years carried forward.
00:47:44You are aware about that you still have another 4 years to be carried forward.
00:47:47But at the subsidy company has finished, you will be getting a fresh 80 years to be carried forward from this date.
00:47:53Okay.
00:47:54That is why, accumulator PGVP losses and unabsorbed depreciation are transferred to the subsidy company.
00:47:59If you have any number of years, you can carry forward and amortize.
00:48:03PGVP loss was the fresh 80 years.
00:48:05Substrategic company would be the profit.
00:48:07You can subtract and set-off.
00:48:08In the capital assets, period of holding as well as the cost.
00:48:12As well as the cost.
00:48:13Including the previous holder.
00:48:16That will be a point here.
00:48:18And in case of MAT.
00:48:20Usually MAT carry forward.
00:48:2215 years.
00:48:24No need to worry about that.
00:48:25Some MAT chapter will be paharung.
00:48:26Company over taxation calculations.
00:48:28The MAT over.
00:48:30And the MAT credit over.
00:48:32As well as the cost.
00:48:34As well as the cost.
00:48:36For the 15 years you carry forward.
00:48:38And if you can carry forward with 15 years.
00:48:40Any 4 years you have into the subsidy company.
00:48:41And the MAT credit over.
00:48:43And if you carry forward with 15 years.
00:48:45And you're doing the subsidy company in the last year.
00:48:47And when they have a subsidy company.
00:48:49So the subsidy company can carry forward another 15 years.
00:48:53For the adjustments.
00:48:54And if you feel ready for that,
00:48:55it's a fresh 80 years.
00:48:57This'll also have to replace the subsidy company.
00:48:59So the subsidy company can carry forward anything in that.
00:49:01It's a fresh afterwards.
00:49:02In case of VRS amortization.
00:49:05Amortization, Voluntary Retirement Amortization, Section 35 DD, okay, DDA. As per this provision,
00:49:13you can pay the VRS compensation for 5 years to amortize. If 2 years amortize, balance
00:49:183 years in the remaining subsidiary company. And in case of provision for bad debt, okay,
00:49:24so provision for bad debt, it will be applicable only for banking company. Of course, this
00:49:33is suitable for the foreign bank. Foreign bank currently, provision for doubtful debts
00:49:37also be created. As per section 36 class 1 subclass 7A, okay, 7 on the bad debt, 7A on the provision
00:49:52for doubtful debts. And the provision on the update, you can pay the credit money claim,
00:49:56and the balance sheet, you can use money claim. Deemed as a credit balance in the subsidiary
00:49:59books. Balance sheet law, provision for doubtful debts. Okay, it can be used for adjusting
00:50:05the bad debt subsequent period. And if you have a share, in the partner branch,
00:50:12one of the subsidiary company, one of the shares is free. Share free, one of the prices
00:50:17already below. You can use the gift card. But it is also non-applicable, no tax on shares.
00:50:27This is also not taxable. So, in the case, these are the conditions you have to maintain.
00:50:35one hundred percent shareholders, even after conversion, 51% voting rates, this year of violation is taxable.
00:50:50Actual convert date will be taxable.
00:50:54So, with that section 115, JG conversion of a branch into foreign subsidiary of Indian, subsidiary
00:51:13Indian company and the case is for the part of, clear for any small small operation purposes.
00:51:21Okay, they have to submit a statement regarding their activities in India.
00:51:29They have to submit a statement regarding their activities in India.
00:51:33Deadline, within 60 days from the end of the financial year.
00:51:36Financial year has been completed.
00:51:39Formant and content, details, definitions.
00:51:44Okay, must be delivered to the relevant assessing officer with jurisdiction.
00:51:50In the jurisdiction, they have to submit.
00:51:52That is the one period of complications.
00:51:54That is the furnishing report in respect of international group.
00:52:00So, there are many countries.
00:52:03That is India.
00:52:04India is also associated with B, C and D.
00:52:09Probably substrate relationship program, parent relationship program,
00:52:12permanent establishment relationship program.
00:52:14But all the four entities are a group company.
00:52:18That is India.
00:52:22India will, A career ROI file.
00:52:25And the financial year has been completed.
00:52:26And the financial year has been completed.
00:52:28That comes under section 286.
00:52:35Notification by constituent entities in India.
00:52:38Must notify if part of an international group.
00:52:41If the international group is a partner, notify you with details on parent or alternate reporting entity.
00:52:47Okay.
00:52:48That is the case of the partnership company, the parent or the company,
00:52:51and the permanent establishment of the company.
00:52:53So, we will tell you who is a company or who does it.
00:52:54Then, who does it report?
00:52:56Why does it report?
00:52:58And why does it report?
00:52:59And how does it report?
00:53:00If I tell the situation, India will say,
00:53:01the parent reports from the country.
00:53:03I will tell you.
00:53:05So, we will tell you.
00:53:06If you do the report,
00:53:07we will tell you.
00:53:08You can do it by the parent or the alternate reporting.
00:53:10You can do it by the parent or the alternate reporting.
00:53:12You can do it by the parent.
00:53:14You can do it by the intimate reporting.
00:53:16Report by parent or alternate reporting entity.
00:53:20What do you do?
00:53:22According to your account, you can submit it.
00:53:24The financial information like revenue, profit, tax paid,
00:53:28and employees, per jurisdiction,
00:53:32India, this country, this country.
00:53:36Also, provides details about each entity, business activity,
00:53:40other prescribed info.
00:53:42Over entity, activities,
00:53:44and intimate.
00:53:46Report submission by other entities.
00:53:50Parent is in a country
00:53:52with no report obligation
00:53:54or lack exchange agreement with India.
00:53:56Suppose, parent,
00:53:58I have to report
00:54:00in India,
00:54:02the exchange agreement
00:54:04in India.
00:54:06In the country, there is an exchange agreement.
00:54:08If you learn DTAA,
00:54:10Double Taxation Abidance Agreement,
00:54:12Indian government,
00:54:14that government will change the agreement.
00:54:16Assessively,
00:54:18we will change the agreement.
00:54:20We will change the agreement.
00:54:22After the agreement,
00:54:24we will change the agreement.
00:54:26We will change the agreement.
00:54:28We will change the agreement.
00:54:30We will change the agreement.
00:54:32We will change the agreement.
00:54:34If parent is a country
00:54:36with no report obligation
00:54:38or lack of exchange agreement with India,
00:54:42other entities must report.
00:54:44Your parent report
00:54:46will change the agreement.
00:54:48If you are a parent,
00:54:50if you are a country
00:54:52who will change the agreement.
00:54:54Exceptions,
00:54:56if an alternate reporting entity
00:54:58in another country
00:55:00submits a report.
00:55:02That is the parent
00:55:04that is Indian company.
00:55:06If you are an alternate reporting entity,
00:55:08you will change the agreement.
00:55:10If you are a parent,
00:55:12you will change the agreement.
00:55:14If you are a parent,
00:55:16if you are a parent
00:55:18or a parent,
00:55:20you will change the agreement.
00:55:22Tax authority can request
00:55:24the document for verification
00:55:26within 30 days.
00:55:28If you are a trustful exemption,
00:55:30it is a trustful exemption.
00:55:32The trustful exemption is
00:55:34that every group of companies
00:55:36that is the definition of
00:55:38accounting year,
00:55:39parent entity,
00:55:40group entity,
00:55:41reporting entity
00:55:42are clearly defined.
00:55:44You will report.
00:55:45According year,
00:55:46India will be different.
00:55:48In the first April,
00:55:4931 March,
00:55:50the US,
00:55:5131 January,
00:55:5231 December.
00:55:53The different countries
00:55:54are different.
00:55:56The international group
00:55:58includes entities from different countries.
00:56:00Not only that,
00:56:02having their permanent establishment
00:56:04in different countries.
00:56:05group companies
00:56:07So,
00:56:08rent wish
00:56:091,
00:56:10285,
00:56:11reporting,
00:56:12license office
00:56:13286,
00:56:14international group
00:56:15company
00:56:16reporting
00:56:18285,
00:56:19286.
00:56:20This is
00:56:21TDS.
00:56:22TDS
00:56:23you may have studied
00:56:24at your
00:56:25inter-level,
00:56:26final level
00:56:27exclusive for non-resident
00:56:28Indian
00:56:29TDS
00:56:30cases
00:56:31one-on-one
00:56:32to see.
00:56:33194E
00:56:34Enjoy
00:56:35Sportsmen
00:56:36associations
00:56:37refer to
00:56:39income
00:56:40under section
00:56:41115BBA
00:56:42Okay.
00:56:43Non-resident
00:56:44sportsmen
00:56:45and athletes
00:56:46entertainers
00:56:47who are not Indian citizens
00:56:48non-resident
00:56:49non-resident
00:56:50sportsmen
00:56:51and associations.
00:56:52So,
00:56:53applicable income
00:56:54under section
00:56:55115BBA
00:56:56Now,
00:56:57115BBA
00:56:58we will see
00:56:59on the
00:57:00non-resident
00:57:01sportsmen
00:57:02and athletes
00:57:03refer to
00:57:04income
00:57:05under section
00:57:06115BBA
00:57:07Okay.
00:57:08Non-resident
00:57:09sportsmen
00:57:10and athletes
00:57:11entertainers
00:57:12who are not Indian citizens
00:57:13non-resident
00:57:14sports association
00:57:15institution
00:57:16on the
00:57:17income
00:57:18Okay.
00:57:19Income
00:57:20referred
00:57:21under section
00:57:22115BBA
00:57:23Now,
00:57:24115BBA
00:57:25TDS
00:57:26will be applicable
00:57:27TDS
00:57:2820%
00:57:29Surcharge
00:57:30Health and Education
00:57:31says
00:57:32Maximum
00:57:33TDS
00:57:3410%
00:57:35flat
00:57:36Surcharge
00:57:37Health and Education
00:57:38says
00:57:39Non-resident
00:57:40case
00:57:41Cut time
00:57:42Surcharge
00:57:43Applicable
00:57:44and
00:57:45Health and Education
00:57:46Add
00:57:47Non-resident
00:57:48Income
00:57:49Income
00:57:50Income
00:57:51Income
00:57:52Income
00:57:53Income
00:57:54115BBA
00:57:55Detection
00:57:56occurs
00:57:57Credit
00:57:58to the
00:57:59Pay account
00:58:00Indian
00:58:01Premier
00:58:02IPL
00:58:03and
00:58:04Probably
00:58:05a
00:58:06Cricket
00:58:07Player
00:58:08Foreign
00:58:09Payment
00:58:10For
00:58:11Payment
00:58:12To
00:58:13Payment
00:58:14For
00:58:15Participation
00:58:16In
00:58:17Indian
00:58:18In
00:58:19Indian
00:58:20Mid
00:58:21Bad
00:58:22Payment
00:58:23for
00:58:24Participation
00:58:25In
00:58:26India
00:58:27Advertisement
00:58:28Newspaper
00:58:29Article
00:58:30Performance
00:58:31In
00:58:34India
00:58:35Now calculate the amount of tax to be directed at source on payment made by, made to Ricky
00:58:47Ponte, an Australian cricketer.
00:58:49Now non-resident in India by a newspaper contribution, 25,000 rupees, but 195 yield, sorry 194 yield
00:58:55over both, 20 percentage plus 4 percentage health and education says will be addable.
00:59:0120 percentage 5,000 rupees, health and education says 4 percentage up to 200 rupees 5,200,
00:59:08otherwise 20.8 percentage data you can calculate.
00:59:12Is that clear?
00:59:14Now LB, LB, go on finish of watching the TDS fare, TDS rate being 5 percentage plus you have
00:59:29to add, why are you NRI payment made by, after surcharge, health and education says tax pay
00:59:35or include pay.
00:59:36LB, LB land bond, land infrastructure bond debt fund, so land bond, infrastructure debt fund
00:59:48you have to invest, you have to invest in interest, 5 percentage TDS will be leviable and of course
00:59:54timing of deduction which ever is earlier of amount of creditors or payment made to him,
00:59:58194 LB, 194 LC okay, Indian company, land company, LB land bond, the land company, Indian company
01:00:10for the deduction supplies to interest payments made to, okay, TDS deduction supplies to, okay,
01:00:25specific bond listed in international financial services center, IFSC, in the data issue 4 percentage,
01:00:42on or after this data 9 percentage, IFSC are in the, IFSC general cases under 5 percentage
01:00:49of course, the trade law meant to be the TDS applicable here, right, qualifying interest, qualifying
01:00:57interest, okay, foreign, borrowings in foreign currency from source outside India, foreign
01:01:02interest income and the non-residents
01:01:05interest income and the non-residents
01:01:08loan agreement
01:01:14loan agreement
01:01:17foreign lender interest income and interest income
01:01:21revenue
01:01:24long term infrastructure bond
01:01:27and rupee denominator bond
01:01:30which is issued before 1st july 2023
01:01:34borrowing and interest rates must be approved by the central government
01:01:37that is allowable LLC case
01:01:40foreign currency FEMA
01:01:44IFSC SES Act
01:01:47special economic zone
01:01:49Gandhinagar
01:01:51international financial services center
01:01:54transaction happened through recognized stock exchange
01:01:57which is defined here
01:01:59this is additional
01:02:01194 LD
01:02:04LD again bond and government securities
01:02:07bond and government securities
01:02:09interest payment for these reasons
01:02:12loan agreement infrastructure bond RDB
01:02:15TDS rate on the 5%
01:02:19payment to F2I's QFI
01:02:23foreign institution
01:02:25qualified foreign investors
01:02:27foreign investors
01:02:29applicable income
01:02:30rupee denominator bond
01:02:32issued by Indian companies
01:02:33government securities
01:02:34municipal debt securities
01:02:35within this period
01:02:36within this period
01:02:38and the dates
01:02:39will be missed
01:02:40that is not the
01:02:41oral view
01:02:42that is not the
01:02:44interest rate
01:02:45again
01:02:46central government
01:02:48approve rate
01:02:49fixed payment
01:02:50that is not the
01:02:52LC
01:02:53conditions
01:02:54the
01:02:56income
01:02:57rate
01:02:58so definitions also be similar
01:02:59right
01:03:00now section 195
01:03:01predominant
01:03:02whatever the payment
01:03:03may be for
01:03:04the non-resident
01:03:05section 195
01:03:06will be applicable
01:03:08payer may be any person
01:03:09in India recipient
01:03:10being non-resident
01:03:11or foreign company
01:03:12payment
01:03:13on the interest
01:03:14any other sum
01:03:15chargeable to tax
01:03:16in India
01:03:17India on the tax
01:03:18on the income
01:03:19income
01:03:20even
01:03:23Even one property foreign in India is a good one.
01:03:28India is a good one.
01:03:31He has to detect the TDS.
01:03:35So TDS rate is applicable tax rate.
01:03:40Higher of the rate under Double Taxation Avoidance Agreement at the rate enforced.
01:03:43DTA rate is a good one.
01:03:45In the applicable rate, Income Tax Act, which is higher will be taken.
01:03:51Okay. Now, Exemptions.
01:03:55Recipient can apply to the Assessing Officer using Form 13 for Certificate to receive payment without TDSR with a lower TDS.
01:04:03TDS is the same as they cut.
01:04:05Form 13 is the same.
01:04:07Sir, I am going to take the Assessing Officer to approve.
01:04:12TDS remittance is the same as you have to pay.
01:04:17So, U.S. or India is the same as you have to pay.
01:04:21If you are the same as you have to pay, you have to pay.
01:04:24TDS is the same as you have to pay.
01:04:26Either payment is the same as you have to pay or credit is the same as you have to pay.
01:04:29Payment or credit to the payer, whichever is earlier will be taken.
01:04:33And for Government, Public Sector Company, Financial Institution under Section 10 Class 23D, TDS is detected only on payment.
01:04:41In the cases, the payment is the same as you have to pay.
01:04:43Credit is the same as you have to pay.
01:04:44Payment is the same as you have to pay.
01:04:46Usually, in the rental, whichever is the same as you have to pay.
01:04:48It is special cases.
01:04:49Payers' responsibility, the payer must report the payment.
01:04:54Failure to do so, may result of 1 lakh penalty.
01:04:57If they are intimate, they should have a penalty.
01:05:00Is that clear?
01:05:01So, 195.
01:05:02Remember crucial case, 195.
01:05:04since I was 960 meters higher.
01:05:08.
01:05:09Now, 196A.
01:05:10196A.
01:05:111320 is sought as you have to pay.
01:05:12Comerapia is asked forPLE.
01:05:12Now, 196A.
01:05:13196A.
01:05:14196A.
01:05:15Any ataquesaufry.
01:05:16Comerapia provides the payment.
01:05:17əet?
01:05:17In this case, we found you easy to do.
01:05:18This payment can be filled with increasing cũ in your all.
01:05:19At least 348 meter units.
01:05:20A farm 사ацum for example.
01:05:22566 so, 708 meter units.
01:05:23ankle Nashum is bounded.
01:05:24On this page was in a complex völlig safe.
01:05:26ovo.
01:05:27We found you.
01:05:28There were significant numbers.
01:05:29The potential mitä?
01:05:30isto is HP 3D.