P - Budget

NCIC/24/2010-11/
February 14, 2011
To,
Mr. Pranab Mukharjee
Union Minister of Finance,
North Block
NEW DELHI
Hon’ble Sir,
This Chamber extends its sincere thanks & congratulations for

controlling the economy of the country efficiently and also for taking
an active interest to providing new direct tax code and also various
new provisions in taxation and collection of revenue.
This Chamber is parent body of Trade & Industries of Agra consisting of

approx. 1400 members of all types of trade & industries from Agra &
nearby Districts/areas Apart from this, about 24 commodity bodies
are also affiliated to it. In addition, this Chamber is also associated
with national & international associations like FICCI, CII, Assocham.
Taxable Limit
1. (i) The exemption limit provided for individuals is at present is very low
i.e. Rs.1,60,000/-, for senior citizens 2,40,000/- and for ladies
Rs.1,90,000/-. This limit is too low in such a high inflationary era of the
country. It is requested that general taxable limit should be raised to
Rs.2,50,000/- , for senior citizens Rs.3,50,000/- and for ladies taxable
limit should be raised to Rs.3,00,000/-.
(ii) Change of slab rate of tax: It is submitted that the tax
slab may also be adjusted. Taxation should be 10% upto
7,50,000/- and at 15,00,000/- 20% and thereafter it should be
30%. It is submitted these changes will cover the fact of inflation
on the low income group.
2. The lowering of age limit of senior citizens:
The age limit of senior citizens is at present 65 years under the

Income Tax Act. But in railways, airlines and banks it is 60 years.
It is submitted in the Income Tax Laws the age of senior citizens
should be reduced to 60 years.
A. DIRECT TAX:
3. Increase in monetary limit: Under the Income Tax Act there are
monetary limits for heads like cash expenditure, taking or paying loan
in cash, deduction of TDS on expenditure, compulsory audit. All these
limits fixed are very old or even ten to twenty years. They now need
upward revision on account of inflation from year to year. They may
be increased as under:
i) The limit under section 40A(3 )of cash expenditure be
raised from 20,000/- to 50,000/- of even 1,00,000/-
ii) Limit of compulsory audit under section 44AB be
increased from 60 Lacs to 1 Crore or even more.
iii) Limit of cash loan under section 269SS and cash
repayment under section 269T be raised from 20,000/-
to 50,000/- or even 1 Lac.
iv) Limit of TDS u/s 193, 194A from 5,000/- to 25,000/- , u/s
194C from 20,000/- to 1 Lac, u/s 194H from 2,500/- to
25,000/-, u/s 194I from 15,000/- to 25,000/- and u/s
194J from 30,000/- to 50,000/- AND also other sections
of TDS 194.
4. Capital Gain Tax: For Capital Gain Tax, the base year
determined for calculation of case is 1981. This is very old year
as base year. This may be revised.
5. Abolition of Sec. 50C of Income Tax: Introduction of 50C has
created real problems for a tax payer without any gain to exchequer. It
has opened gate of corruption. The circle rate fixed for stamp duty by
the State for sale of property is unrealistic and based on generality of
situation without regard to actual facts and circumstances of the
matter. The value of the property depends upon various factors like
need for money, vacant or with possession, application of tenancy
laws, condition of property, dispute of titles and other various factors.
All those factors adversely affect the value of the property
substantially. Hence, a general rule laid down under the section is
unrealistic and artificial. It is suggested that in the present society
there is no need of this section. It may be deleted.
6. Social Security Measure: - Through out the world social security is

provided to the tax payer either at the time of retirement or
emergency/ accidents or at disablement or unable to work, there is no
such provision in India for the welfare of tax payers, the payment of
tax by every citizen is his duty it is also expected that the Government
should take care of his welfare. Such provision may be enacted in
either in the Act itself or there may be separate legislation. The
provision of section 80C are not effective or sufficient for self employed
people. Some more benefit be allowed.
7. Standard Deduction from Salary: The provision of standard
deduction have been withdrawn from the statute from this year. This
is causing unnecessary trouble to the salary paid persons who are hard
hit in the society. It is suggested that either the standard deduction
should be restored or at least necessary expenditure should be allowed
for deduction from the income of salaried person.
8. SEZ for Agra: Creation of a special economic zone - SEZ in Agra is a

demand long time as it will boost export from this part of the country,
it will prove to be oxygen for industries dying of unprecedented
controls. With this the Taj Mahal and the industry will flourish side by
side. Conversion of developing EPIP into SEZ, in arrangement with the
Government of U.P., may also be a welcome proposition to achieve the
purpose.
Declaring Agra Backward Area:
It is further submitted that on account of Hon’ble Supreme court

decision, mostly the industries of Agra have been closed on the
grounds of pollution control excluding some cottage industries of
shoes etc. On account of thus, the development of Agra has
been blocked and has become a backward area. It is requested
that benefits of Backward Area be allowed to Agra.
Dis-allowance of expenditure where tax has not been
deducted:
9. Under provisions of section 40(i a) legitimate business expenditure on

which TDS is required to be deducted but has not been paid, the
expenditure is not allowed as business expenditure and hence added
to income shown in Profit & Loss Account. By doing so, the Govt. is not
only taxing income artificially but it is also disallowing expenditure. The
concept of taxing real income is being defeated. We would like to
mention that there are already penal provisions to penalize non-
deduction of tax or non payment of tax after deduction. In view of this
we suggest that provisions of 40(a) (i) to (V) should be deleted.
VOLUNTARY DISCLOSURE SCHEME
10. There is great talk in the paper that the black money is running
in parallel economy in India but no serious efforts have ever
been made to unearth the black money so that it can join the
main economy stream of India. It appears it is high time that
Government should bring a voluntarily disclosure Scheme in the
country. It will not only help to collect a great revenue for the
country but also have a check on corruption to abolish black
money which is used for the corruption. It is suggested voluntary
disclosure scheme should be brought in coming Budget.
INDIRECT TAX:
i) Excise on agriculture implements: Agriculture implements

like tractor is exempt from Excise whereas in case of pump
set, which is also used for agriculture, there is duty. It is
suggested that Excise Duty may be removed on all
equipments meant for agriculture.
ii) The limit of payment of excise duty on new units may be
restored as in the past. If the sale of the unit exceeds the
taxable limit within the first or second year, then concessional
duty should be levied and penal provision should not be made
applicable.
SERVICE TAX:
1. At present there is service tax levied on the builders on a sale or

constructed of flats. It is submitted that outright provisions to
levy of service tax on the same is not proper. It is submitted that
it should be abolished as it is an outright sale.
2. At present the limit is excise on the excisable units on the sales

over 1.5 crores. This limit is too low at present looking into the
rate of inflation in the prices. It is submitted it should raised to 5
crores.
These are some of the suggestions for practical working and

implementation of tax laws which your goodself may kindly favorably
consider the same in the ensuing budget.
With regards,
Yours sincerely,
(SHIV KUMAR AGARWAL) (K.C. AGRAWALA)
PRESIDENT PAST PRESIDENT & CHAIRMAN,

INCOME TAX CELL

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NCIC/24/2010-11/

February 14, 2011

Mr. Pranab Mukharjee

Union Minister of Finance,

This Chamber extends its sincere thanks & congratulations for

This Chamber is parent body of Trade & Industries of Agra consisting of

2. The lowering of age limit of senior citizens:

The age limit of senior citizens is at present 65 years under the

6. Social Security Measure: - Through out the world social security is

8. SEZ for Agra: Creation of a special economic zone - SEZ in Agra is a

Declaring Agra Backward Area:

It is further submitted that on account of Hon’ble Supreme court

9. Under provisions of section 40(i a) legitimate business expenditure on

VOLUNTARY DISCLOSURE SCHEME

i) Excise on agriculture implements: Agriculture implements

1. At present there is service tax levied on the builders on a sale or

2. At present the limit is excise on the excisable units on the sales

These are some of the suggestions for practical working and

(SHIV KUMAR AGARWAL) (K.C. AGRAWALA)

PRESIDENT PAST PRESIDENT & CHAIRMAN,

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