Recent Amendments and Issues.

(Specially for Builders and Developers)

under MVAT.
By: CA. Umesh Sharma

AGENDA:

To know the new provisions of works contract under

Rule 58 .
In simple way Revised Taxation of Builders and
Developers.
Or
Reconstruction of Tax Structure of Builders and
Developers.

Judgment of L&T and its impact on revision of rule 58.

New rule: W.e.f 20-6-2006

New rule 58 (1), Actual & Notes to Abatement Method, of
Cost of Land, etc.
New rule 58 (1A) Cost of land and Interest in land.
New rule 58 (1B)(a) Table of Stages of Construction.

Circular no 6T ,7T and 12T of 2014 and Issues in filing

of revised returns?

FOR SUCH DEALERS PROPER PLANNING

WILL BE REQUIRED AS DEPT IS GUNNING
THEM DOWN

And there are many moments in Law

Practice of
To be or not to be?

WORKS CONTRACT TAXATION

SOME PECULIARITIES:

Generally Indivisible Contracts are works contract i.e : (Goods + Services).

In Hindustan Shipyard Ltd Case, SC has observed that no straight formula is

there to determine a sale or works contract? Case to Case reference is required.

No intention to purchase goods.

Time of Sale: Generally, at the time goods are incorporated in work.

Goods transferred v/s Consumed during the contract?

Under MVAT Act, taxation of Works contract, following Options are available:

Option 1: Normal Taxation after Deduction as per books from Contract Value.

Option 2: Normal Taxation after % wise deduction from Contract Value.

Option 3: Composition Scheme. 5% and 1%.

All Options available Contract wise or lump sum basis.

Turnover of sales of goods involved in contract value shall be determined after

deduction as mentioned in rule 58.

IMPACT: The balance amount shall be considered for calculating the turnover of
tax and for applicability of MVAT audit.
5

JUDGMENT OF MCHI AND L&T

ITS IMPACT ANALYSIS.

LETS UNDERSTAND IT..,

L A R S E N A N D TOU B R O L I M I T E D A N D
A N O T H E R V S S TATE O F K A R N ATAK A A N D
A N O T H E R [ S U P R E M E C O U RT O F I N D I A , 2 6 S E P 2 0 1 3 ]

By the Forty-sixth Amendment, States have been empowered

to bifurcate the contract and to levy sales tax on the value of
the material in the execution of the works contract.

Whether contract involved a dominant intention to transfer

the property in goods, in our view, is not at all material. It is
not necessary to ascertain what is the dominant intention of
the contract.

Even if the dominant intention of the contract is not to

transfer the property in goods and rather it is the rendering
of service or the ultimate transaction is transfer of immovable
property, then also it is open to the States to levy sales tax on
the materials used in such contract if it otherwise has
elements of works contract.

L A R S E N A N D TOU B R O L I M I T E D A N D
A N O T H E R V S S TATE O F K A R N ATAK A A N D
A N O T H E R [ S U P R E M E C O U RT O F I N D I A , 2 6 S E P 2 0 1 3 ]

Once the characteristics or elements of works

contract are satisfied in a contract then irrespective
of additional obligations, such contract would be
covered by the term works contract.

Nothing in Article 366(29-A)(b) limits the term

works contract to contract for labour and service
only.

L A R S E N A N D TOU B R O L I M I T E D A N D
A N O T H E R V S S TATE O F K A R N ATAK A A N D
A N O T H E R [ S U P R E M E C O U RT O F I N D I A , 2 6 S E P 2 0 1 3 ]

For sustaining the levy of tax on the goods deemed to have

been sold in execution of a works contract, in our opinion,
three conditions must be fulfilled:

(i) there must be a works contract,

(ii) the goods should have been involved in the execution of a

works contract, and

(iii) the property in those goods must be transferred to a third

party either as goods or in some other form.

In a building contract or any contract to do construction, the

above three things are fully met.

In a contract to build a flat there will necessarily be a sale of

goods element. Works contracts also include building contracts
and therefore without any fear of contradiction it can be stated
that building contracts are species of the works contract.

L A R S E N A N D TOU B R O L I M I T E D A N D
A N O T H E R V S S TATE O F K A R N ATAK A A N D
A N O T H E R [ S U P R E M E C O U RT O F I N D I A , 2 6 S E P 2 0 1 3 ]

We have no doubt that the State legislatures lack legislative

power to levy tax on the transfer of immovable property under
Entry 54 of List II of the Seventh Schedule.

However, the States do have competence to levy sales tax

on the sale of goods in an agreement of sale of flat which
also has a component of a deemed sale of goods.

Aspects theory though does not allow the State legislature

to entrench upon the Union List and tax services by
including the cost of such service in the value of goods but
that does not detract the State to tax the sale of goods
element involved in the execution of works contract in a
composite contract like contract for construction of
building and sale of a flat therein.

L A R S E N A N D TOU B R O L I M I T E D A N D
A N O T H E R V S S TATE O F K A R N ATAK A A N D
A N O T H E R [ S U P R E M E C O U RT O F I N D I A , 2 6 S E P 2 0 1 3 ]

On Section 2(24):

There is no doubt in our mind that the amendment in

explanation b(ii) to Section 2(24) was brought because
of the judgment of this Court in Raheja Development.
We have already held that Raheja Development case
lays down the correct legal position.

Thus, in our view, there is no merit in the challenge to

the constitutional validity to the provisions of
explanation (b)(ii) to Section 2(24) of MVAT which were
amended with effect from 20.06.2006. The Division
Bench of the Bombay High Court took the view that the
provision under challenge was not in breach of any
constitutional boundaries.

L A R S E N A N D TOU B R O L I M I T E D A N D
A N O T H E R V S S TATE O F K A R N ATAK A A N D
A N O T H E R [ S U P R E M E C O U RT O F I N D I A , 2 6 S E P 2 0 1 3 ]

On Rule 58 (1A):

The value of the goods which can constitute the measure of the
levy of the tax has to be the value of the goods at the time of
incorporation of goods in the works even though property in
goods passes later.

Taxing the sale of goods element in a works contract is permissible even

after incorporation of goods provided tax is directed to the value of
goods at the time of incorporation and does not purport to tax the
transfer of immovable property.

The mode of valuation of goods provided in Rule 58(1A) has to

be read in the manner that meets this criteria and we read down
Rule 58(1-A) accordingly.

The Maharashtra Government has to bring clarity in Rule 58 (1A) as indicated above. Subject to this, validity of Rule 58(1-A) of
MVAT Rules is sustained.

14

II MPA
MPA C
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T ON
ON B
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ER
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S A
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D
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EV
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E LO
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R S:
S:
O
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F R
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SPE C
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T II VE
VE A
A ME
ME N
ND
DM
ME
EN
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T

IMPACT: NEW RULE 58 INTRODUCED

ON 29 T H JAN 2014 W.E.F 20-6-2006.

NEW RULE 58:

New rule: Retrospective W.e.f 20-6-2006

New rule 58 (1): Notes to Abatement Method of Cost
of Land, etc.
New rule 58 (1A): Cost of land and Interest in land.
New rule 58 (1B)(a) :Table of Stages of Construction
and Value of goods transferred.
New rule 58(1C): Non compliance of stages of
construction.
New rule 58(2): Value so determined shall be the sale
price of goods.

VALUE OF LAND: OLD RULE

58(1A)

17

The Cost of Land is to be determined first, from the

total contract value u/s rule 58 (1A).

Rule 58 (1A) specify How to determine the value of Land

involved in contract? i.e.., The Stamp duty value as on 1st
Jan of the year in which the agreement to sell the property is
registered. Subject to cap of 70% of the agreement

value.

Notification No.1512/CR-84,taxation 1 dt: 30 th July 2012, uploaded

on 16th Aug 2012 deleted the 70% cap of deduction of land cost
proviso under rule 58(1A). Retrospective w.e.f 20 th June 2006.

Once the cost of land is deducted from the total contract

value, the other deductions as per rule 58 will be applicable.

Accordingly the tax needs to be calculated on the value of

goods involved in the total contract.

CHANGES IN VALUE OF
LAND

18

Sr. No.

Old Rule

New Rule

The Stamp duty value as on

1st Jan of the year in which
the agreement to sell the
property is registered.

The Stamp duty value as on 1st Jan of

the year in which the agreement to sell
the property is registered.

No reference of Actual Cost of

Land.

Now reference of Actual Cost of land in

proviso.
It shall be open to the dealer to provide
before the Department of Town
Planning and Valuation that the
actual cost of the land is higher
than
that
determined
in
accordance
with
the
Annual
Statement
of
Rates
(including
guidelines)
prepared
under
the
provisions of the Bombay Stamp
(Determination of True Market Value of
Property) Rules, 1995

PRACTICAL ISSUES IN DETERMINATION OF

VALUE OF LAND.

19

Interest in Land is exhaustive list like TDR cost, Premium, Local

Authority taxes on land, NA Charges, etc.

Now actual cost incurred can be taken into account based on

stratification of the Department of Town Planning and Valuation.

Very difficult to establish now for the earlier period hence

in many cases there may be no impact on cost of land.

Excess tax collected will be refunded? Indirect taxation, forfeiture

of tax, pay back to costumer.

Refer Q.8 of 12T of 2014: Town planning certification is must for

actual cost.

Procedure to issue certificate? yet to be drafted by the Town

Planning dept. Refer Q.4 of 12T of 2014.

Deduction of Land cost in first year or proportionately? Refer Q.10

of 12T.

ONCE LAND VALUE IS DETERMINED, FIND

METHOD OF TAX AND NOW FIND STAGE OF
CONSTRUCTION

20

ONCE LAND VALUE IS DETERMINED, FIND

METHOD OF TAX AND NOW FIND STAGE OF
CONSTRUCTION.

21

Now lets look at each method and effect of new rules on tax
liability for filing revised returns:

Under MVAT Act, taxation of Works contract, following Options are

available:

Option 1: Normal Taxation after Deduction as per books from

Contract Value.

Option 2: Normal Taxation after % wise deduction from Contract

Value.

Now Turnover of sales of goods involved in contract value

shall be determined after determination of stage of
construction and as mentioned in rule 58 (1B).

IMPACT: The balance amount shall be considered

calculating the turnover for applicability of MVAT audit.

Please note that no effect of stages on following options:

Option 3: Composition Scheme of 5%.

Option 4: Composition Scheme of 1% w.e.f 1-4-2010.

for

NEW RULE 58(1B):

TABLE OF STAGES OF CONSTRUCTION

22

58[(1B)(a):

Where the dealer undertakes the

flats, dwellings, buildings or
transfers them in pursuance of
along with the land or interest
land then,

after deductions under sub-rules (1) and

(1A) from the total contract price, the value
of the goods involved in the works contract
shall be determined after applying the
percentage provided in column (3) of the
following TABLE depending upon the state at

construction of
premises and
an agreement
underlying the

NEW RULE 58(1B):

TABLE OF STAGES OF CONSTRUCTION

23

Sr.
No.

(1)
(a)
(b)
(c)

(d)

(e)

Stage during which the

enters into a contract
purchaser.

developer Amount
to
be
with the determined
as
value of goods
involved in works
contract.
(2)
(3)
Before issue of the Commencement
100%
Certificate.
From the Commencement Certificate
95%
to the completion of plinth level.
After the completion of plinth level to
85%
the completion of 100% of RCC
framework.
After the completion of 100% RCC
55%
framework
to
the
Occupancy
Certificate.
After the Occupancy Certificate.
Nil%

BEFORE ISSUE OF THE

COMMENCEMENT CERTIFICATE.

24

100%
taxable
value of
goods on
booking.

F RO M THE CO MME NC E ME NT CE RTIF IC ATE TO

T HE CO MPL E T IO N OF P LI NT H LE V E L .

25

95%
taxable
value of
goods on
booking.

AF T ER THE C O MPL ET IO N O F P LI NT H LE V E L TO
TH E CO MP L E T ION OF 1 0 0% O F R CC
FR A ME W OR K .

26

85%
taxable
value of
goods on
booking.

A F TE R TH E CO MP LE T ION OF 1 0 0% RCC
F RA ME W O RK TO TH E O C CU PAN CY C E RTI FI CATE .

27

55%
taxable
value of
goods on
booking.

AFTER THE OCCUPANCY

CERTIFICATE.

28

0%
taxable
value of
goods on
booking.

NEW RULE 58(1B) AND (1C):

TABLE OF STAGES OF CONSTRUCTION

29

(b)For determining the value of goods as per the Table

clause (a), it shall be necessary for the dealer to furnish
a certificate from the Local or Planning Authority
certifying the date of completion of the stages
referred above and where such authority does not
have a procedure for providing such certificate then
such certificate from a registered RCC consultant.

(1C) If the dealer fails to establish the stage during

which the agreement with the purchaser is entered,
then the entire value of goods as determined after
deductions under sub-rules (1) and (1A) from the value of
the entire contract, shall be taxable.]

NEW RULE 58(2):

TABLE OF STAGES OF CONSTRUCTION

30

Rule 58(2):

Thevalueofgoodssoarrivedatunders
ub-rule(1)9[,(1A) or, as the case may be,
under
sub-rule
(1B)]shall,forthepurposesoflevyoftax
,

bethesalepriceor,asthecasema
ybe,the
purchasepricerelatingtothetransf
erofproperty
ingoods(whetherasgoodsorinso
meotherform)involvedintheexec

31

Sr.
No.

(1)
(a)
(b)

(c)

(d)

(e)

ISSUES IN STAGES OF
CONSTRUCTION

Stage
during
which
the Who can issue the Amount
to
be
developer enters into a contract certificate
determined
as
with the purchaser.
value
of
goods
involved in works
contract.
(2)
(3)
(3)
Before
issue
of
the
Local Authority
100%
Commencement Certificate.
From
the
Commencement
RCC Consultant (As
95%
Certificate to the completion
there is no such
of plinth level.
procedure of LA)
After the completion of plinth
RCC Consultant (As
85%
level to the completion of
there is no such
100% of RCC framework.
procedure of LA)
After the completion of 100%
Local Authority
55%
RCC
framework
to
the
(What about Date of
Occupancy Certificate.
application to date
of issue period?)
After the Occupancy Certificate.
Local Authority
Nil%

BIG ISSUE

32

What is mean by Date of Contract?

Date of Purchaser entering into a

Contract is the trigger point.
1st advance receipt is a also a
contract.

BIG ISSUE

33

Date of
Contra
ct

Goods transferred after date of Contract

is taxable.
Hence purchases prior to that setoff
issues.
Rule 53(6), Taxable turnover will change.
Refer Q.11 and 26 of 12T.

34

NEW RULE 58(1B):

ISSUES IN TABLE OF STAGES OF CONSTRUCTION

Minimum 55% of value of goods may be taxed mandatorily, as

Occupancy Certificate is received after construction is complete
and all documents are submitted to Local Authority.

Local Authority takes time to issue Occupancy Certificate,

Whether date of application can be taken or date of issue?

Technical words like of plinth level, of RCC framework,

etc. needs to co-related with books of accounts.

100% RCC framework means 100% of the entire

building? Q.2 of 12T. It should be per unit of sale.

Agreement to sale needs to be checked for

installments amount and stages of construction,
generally it is mentioned.

Building wise/Unit wise issues may arise in each case to

case.

35

ISSUES IN STAGES OF
CONSTRUCTION

DATES?

36

For Land Value: Date of 1St Jan, in the year

when agreement to Sell is registered.

Where as:

For Stages of construction: Date of entering

into a contract.

37

RATE OF TAX ON SUCH GOODS USED

AFTER STAGE OF CONSTRUCTION

Rate of Tax is to be applied on the value of goods arrived after

determination of stage of construction.

Ratio of Rate of tax of purchases used after the stage of construction

needs to be applied.

Date of booking of invoice and date of entering into a contract needs

to be correlated.

Practically purchases are booked on date of receipt of Invoice, if

goods received earlier then date of entering into contract, many
peculiar issued may arise.

Further receipts booked after and prior the date of contract and rate
of tax on after the date of contract receipts and its reconciliation may
arise.

Practical implementation of new rule and filing revised return will be

very difficult.

If dealer fails then complete contract value will be taxed as

per rule 58 (1C).

38

N O W L ETS C H EC K IM PAC T O F N E W R U L E O N
( O PTI O N 1- D ED U C TIO N AS P ER B O O K S)

N O W L E T S C H E C K I M PAC T O F N E W R U L E O N
( O P T I O N 1 - D E D U C T I O N AS P E R B O O K S )

39

Rule58:

Determinationofsalepriceandofpurchase
pricein
respectofsalebytransfer of
propertyingoods(whetherasgoodorinso
meotherform)
involvedintheexecutionofaworkscontract:-

(1)Thevalueofthegoodsatthetimeofthetransferofproper
ty
in
the
goods
whetherasgoodsorinsomeotherform)involvedintheexecuti
onof
aworkscontract
maybedeterminedbyeffectingthefollowingdeductionsfrom
thevalueoftheentirecontract,
insofarasthe
amountsrelatingtothedeductionpertain
tothesaidworkscontract:

D E T E R M I N ATI O N O F S AL E P R I C E I N C A S E O F
W O R K S C O N T R AC T S AS P E R R U L E 5 8 .
( W I T H I N M A H AR AS H T R A S TATE )
( O P T I O N 1 - D E D U C T I O N AS P E R B O O K S )

40

(a)labourandservicechargesfortheexecutionoftheworks.

(b)amountspaidbywayofpriceforsub-contract,ifany,tosub-contractors;
(c)chargesforplanning,designingandarchitectsfees;
(d)chargesforobtainingonhireorotherwise,machineryandtoolsf
ortheexecutionoftheworkscontract;
(e)costofconsumablessuchaswater,electricity,fuelusedintheexec
utionofworks
contract,thepropertyinwhichisnottransferredinthecourseof
executionoftheworkscontract;
(f)costofestablishmentofthecontractortotheextenttowhichit
isrelatableto supplyofthesaidlabourandservices;
(g)othersimilarexpensesrelatabletothesaidsupplyoflabourandser
vices,wherethe
labourandservicesaresubsequenttothesaidtransferofproperty;
(h)
profitearnedbythecontractortotheextentitisrelatabletothesupplyo
f saidlabourandservices.

41

D E T E R M I N AT I O N O F S A L E P R I C E I N C A S E O F W O R K S
C O N T R A C T S AS P E R R U L E 5 8 .
( W I T H I N M A H A R A S H T R A S TAT E )
( O P T I O N 1 - D E D U C T I O N AS P E R B O O K S )

Total Contract Value (Value of Entire Contract)

Say Rs.1000

Less: Allowable Deductions

Stamp duty Value of land as per rule 58 (1A) or Actual Cost of Land , Cost of Interest in
Land like TDR, etc.
Sub Contract Value paid to RD sub-contractor.
Labour Charges for execution of WC.

Rs.200
Rs. 100
Rs. 10

Planning, Designing & Architects fees

Rs. 10

Hire Charges or otherwise, for obtaining Machinery & Tools

Rs. 10

Cost of Consumables in which there is no transfer of property

e.g.: Water, Electricity, Fuel, etc..

Rs. 10

Cost of Establishment relatable to supply of labour & services

Rs. 100

Similar other expenses relatable to supply

of Labour & Services

Profit relatable to supply of Labour & Services

SUB-TOTAL
Balance sales Price ----- Deemed Sale Value of Goods involved in execution of WC,
Find stage of construction of unit and apply the % to find value of goods transfer based
on date of entering into contract.

Rs. 50
Rs. 10
Rs. 500
= Rs. 500

SOME ISSUES UNDER OPTION

1:

42

How to calculate Purchase Ratio:

Consider only goods transferred after date of entering into

contract.

Do not consider Consumable, Capital Goods, etc.

Consider all Purchases i.e, MS plus OMS.

For OMS and URD purchases, apply local rate of tax on

sale of such goods.

Bifurcate Rate wise. i.e, 5% or 12.5%

Calculate ratio rate wise of total purchases.

Apply this ratio of rates on value of goods determined.

N O W L E T S C H E C K I M PAC T O F N E W R U L E O N
( O P T I O N 2 - D E D U C T I O N AS P E R % O R
A B ATE M E N T M E T H O D )

43

1.

Where the contractor has not maintained accounts which enable proper evaluation of different
deductions as below or where the Commr. finds that the accounts are not sufficiently clear or
intelligible, then the Contractor or Commr. may in lieu of deductions as below, deduct a Lump
sum deduction as provided in the Table u/r 58, to determine the SP of goods involved in WC.

2.

Deduction of the Stamp duty value of Land as per rule 58 (1A) or Actual Cost of land
and interest in land.

3.

The Sub-Contract Value shall be deducted from the Total Contract Value and

4.

Thereafter the lump sum Deduction of 30% allowable as per Table shall be made to
arrive at the SP of goods involved in WC.

Balance sales Price ----- Deemed Sale Value of Goods involved in execution of
WC,
Find stage of construction of unit and apply the % to find value of goods
transfer
based on date of entering into contract.
5.

3.

The value of goods so arrived at shall be the SP or PP relating to the transfer of

property in goods involved in execution of WC, for the purposes of levy of tax@ 0 /
1% /5% / 12.5%, as applicable.

4.

RD can collect the tax separately, to the extent payable, on any sale of goods [Sec.
60(2)]

5.

Where RD has not collected the tax separately, the tax element can be reduced from
the `Sale Price for the levy of tax [Rule 57(1)]

OP T IO N 1 & 2: R ATE O F TAX .

Schedules and Rates of Tax For Goods Involved in Works Contract
after the date of entering in contract and % of stage of construction.

Schedule A

0%

Exempted Goods Daily

Necessities

Schedule B

1%

Bullion, Jewelry, Precious

Stones

Schedule C

4%
or
5%

IT Products, Declared Goods,

Industrial
Inputs,
Telecom,
Products, Drugs & Medicines,
Renewable Energy Devices &
other products.
(Steel, Sand, Metal, etc.)

Schedule D

20%
34%

Motor Spirits, ATF, etc..

Schedule E

12.5
%

Residuary Entry (Cement, Tiles,

bath fittings, etc.).
44

SET OFF ON GOODS USED IN WC &

GENERAL CONDITIONS CONTD..

45

Issues in Main contractors & Sub contractors

Relationship shall be deemed to be that of the
Principal & Agent [Sec 45(4)].

Their liability to pay tax shall be joint & several.

Deductions will be given to either, based on producing

prescribed certificates

Payment made by Main Contractor issue Form 406 &

409 to Sub-Contractor

Payment made by Sub-Contractor issue Form 407 &

408 to Main Contractor

SCHEME OF COMPOSITION
FROM 20 T H JUNE 2006

46

Lump sum or Contract Wise or Portion of individual Contract wise

taxation:

New Explanation--whether in respect of the entire turnover of sales effected

by way of works contract or in respect of any portion of the turnover
corresponding to individual works contract, pay lump-sum by way of
composition :

Two Type of Contracts: 1) Construction Contract and 2) NonConstruction Contract.

Definition of Construction Contract is given.

For Construction Contract rate of Composition is 5%. With retention

of 4%.

For other than Construction Contract rate of Composition is 8%. With

retention of 36% of tax.

Deduction of land cost or Cost of Interest in land u/s rule 58(1A) and
58(1B) is not allowed under this composition scheme.

Deduction of tax paid by sub-contractor even under composition

allowed:
the amount payable towards sub-contract involving goods means the
aggregate value of the goods on which tax is paid and the quantum of said
tax paid by the sub-contractor or the sub-contract value on which tax by
way of composition is paid by the sub-contractor, as the case may be.

47

OVER ALL EFFECT OF NEW RULE

58

Taxability of Contracts entered before 20th

June 2006. Whether taxable or not?

Project wise Assessment.

SUMMING UP:
IMPORTANT POINTS TO REMEMBER:

48

For the Period from 20th June 2006 to 31st March 2010:

Find the Actual cost of land, if higher than revised returns subject of conditions.

Find the Cost of Interest in Land, if higher then revised returns.

Find the Stage of Construction and apply the % of value of goods on the date of
entering into contract. Please remember 1 st Advance date. Practically difficult task
other full value is taxable, hence no need to file revised return.

If books of accounts are appropriately maintained by dealer- go for Actual basis i.e..,
Option 1st.

If Actual basis is not possible then for Option 2 (i.e., % basis)

If 5% Composition Scheme. (No revision of returns required)

Even if after revision, refund arises, if collection from customer is made then, it may
be forfeited or it will have to be refunded back to customer.

Audit Report of 12-13 can be filed up to 10th May 2014. (other than composition
dealer)

From 1st April 2010 onwards:

Go for 1% Composition Scheme.

HOW TO FILE REVISED

RETURN?

49

Circular No.7T of 2014

Revised return can be filed for the period 20-6-2006 to 31-122013.

Annual Return for the one year may be filed. Refer Q.20 of 12T.

To be filed on or before 30th April 2014.

Even if assessment and appeal completed, option to file

revised return available.

No option of Cost plus method.

No option of filing original return of above period. Late fees and

penalty, etc. may be applicable. Q21 of 12T.

Interest will be applicable as per law. Refer Q.22 of 12T.

Refund after assessment. Q.18 of 12T.

FALL OUT OF NEW RULE 58

STO SAYING TO DEALER:

THANKS,
IN PRACTICE, TAKE CARE OF CHANGES IN
LAW, ,

KEEP LEARNING,
SORRY FOR ANY MISTAKE,
KEEP SMILING, ENJOY SUMMER HOLIDAYS WITH
NATURE