I. Background
Levy of income tax on book profits has its origin in US law on zero tax companies. In the Income-tax Act, 1961 (the Act) was introduced in substitution of Section 80 VVA by the Finance Act, 1987 by insertion of Section 115 J with effect from A.Y. 1988-89. The said section provided that where the total income of a company as computed under the Act in respect of any accounting year is less than thirty per cent of its book profit, the total income of the company chargeable to tax shall be deemed to be an amount equal to thirty per cent of such book profit. Book Profit Tax was abandoned with effect from A.Y. 1990-91 by the Finance Act, 1990. However, this tax was reintroduced with a new name, Minimum Alternate Tax (MAT) with effect from A.Y. 1997-98 under Section 115 JA. However, as a result of representations from various professional bodies against MAT, which had earlier promoted dropping of book profits tax, the Government brought in credit for MAT paid under section 115 JAA against regular tax with effect from 1-4-1998 that is A.Y. 1998-99, the second year of MAT. But the availing of credit under section 115 JAA was short — lived. The Finance Act, 2000 came out with the new MAT provisions dropping section 115 JAA and substituting section 115 JA by section 115 JB with effect from A.Y. 2001-02. But, the tax credit already earned under section 115 JAA was permitted against regular tax payable even after substitution of section 115 JA by section 115 JB, but MAT tax paid under section 115 JB did not merit any credit.
It may, therefore, be seen, that there were three different versions of tax on book profits, all at different points of time under Chapter XIIB i.e. under section 115J, section 115JA and section 115 JB.
II. Present MAT provisions
Section 115JB of the Act provides for a Minimum Alternate Tax (MAT) on companies. Under the original provisions of this section, a company was required to pay at least 7.5% of its book profit as corporate tax. In case, the tax liability of a company under regular provisions was more than this amount, the provisions of MAT did not apply and the company was required to pay corporate tax as per the regular scheme.
Thereafter, Finance Act, 2005 provided that the income tax payable on the total income as computed under the Act in respect of any previous year relevant to the assessment year commencing on or after 1st April, 2007, is less than ten per cent of its book profit, such book profit shall be deemed to be the total income of the company assessee and the tax payable for the relevant previous year shall be ten per cent of such book profit. The said percentage was raised from time-to-time and presently it is eighteen and one-half per cent. Section 115 JB inter alia provides that in case of company assessees, the profit and loss account for the relevant previous year shall be prepared as per the provisions of Part—2 of the Schedule—VI of the Companies Act, 1956 and while preparing the annual accounts including profit and loss account, the accounting policies, accounting standards and methods and rates adopted for calculating depreciation shall be the same as have been adopted for the purpose of preparing such accounts including profit and loss account and laid before the company at its annual general meeting in accordance with the provisions of section 210 of the Companies Act, 1956. Explanation — 1 to this section defines “book profit” as meaning net profit as shown in the profit and loss account for the relevant previous year which to be increased or reduced as per the items specified in Explanation — 1.
III. Proposed Amendments to Section 115JB by the Finance Bill, 2017
In the present Finance Bill of 2017 section 115JB of the Act is proposed to be amended by clause 47 of the Bill. The amendment is proposed so as to align the provisions of section 115JB for the company preparing financial statements in accordance with the provisions of Indian Accounting Standards and to update the provisions of the Companies Act, 1956 referred to in the said section in accordance with the provision of the Companies Act, 2013 which has replaced earlier Companies Act, 1956. The Indian Accounting Standards are required to be adopted by certain companies from Financial Year 2016-17 mandatorily. The proposed amendments will be operative from
A.Y. 2017-18. The memorandum explaining the proposed amendments to Section 115JB is stated as under :
“Central Government notified the Indian Accounting Standards (Ind-AS) which are converged with International Financial Reporting Standards (IFRS) and prescribed the Companies (Indian Accounting Standards) Rules, 2015 which laid down a roadmap for implementation of this Ind-AS.
Globally, different approaches have been adopted to deal with the tax issues arising from adoption of IFRS. For ensuring horizontal equity across the companies irrespective of the fact that whether they follow Ind-AS or the existing Indian GAAP, the Central Government has issued Income Computation and Disclosure Standards (ICDS) for computation of taxable income for specified heads of income.
As the book profit based on Ind-AS compliant financial statement is likely to be different from the book profit based on existing Indian GAAP, the Central Board of Direct Taxes (CBDT) constituted a committee in June, 2015 for suggestion the framework for computation of minimum alternate tax (MAT) liability under section 115 JB for Ind-AS compliant in the year of adoption and thereafter.
The Committee submitted first interim report on 18th March, 2016 which was placed in public domain by the CBDT for wider public consultations. The Committee submitted the second interim report on 5th August, 2016 which was also placed in public domain. The comments / suggestions received in respect of the first and second interim report were examined by the Committee. After taking into account all the suggestions / comments received, the Committee submitted its final report on 22nd December, 2016.
In view of the above, it is proposed to amend section 115 JB so as to provide the framework for computation of book profit for Ind-AS compliant companies in the year of adoption and thereafter. Thereafter, the memorandum reproduces the salient features of the said proposed framework. The said salient features are considered hereafter in this write-up.
IV. Applicable provisions of the Companies Act, 2013
As per Section 129 of Companies Act, 2013 the financial statements of the companies shall be in such form or forms as may be provided for different class or classes of companies as
per Schedule — III. Schedule — III has two divisions:
Division — 1 is applicable for a company whose financial statements are required to comply with the companies (Accounting Standards) Rules, 2006. The said rules are applicable to small and medium sized companies as defined by Rule — 2 (1) (f) of the said Rules. The Central Government has prescribed Accounting Standards 1 to 7 and 9 to 29 as recommended by the Institute of Chartered Accountants of India which are to be complied with by the small and medium sized companies.
Division — 2 of the said Schedule — III is applicable for a company whose Financial Statements are drawn up in compliance of the Companies (Indian Accounting Standards) Rules, 2015. The classes of companies which have obligation to comply with Indian Accounting Standards are specified under Rule — 4 of the said Rules. The amendments proposed in Section 115 JB is applicable to the said companies which prepare statement of profit & loss account as per Part — II of Division — 2 to Schedule — III of the Companies Act, 2013 and adopt Indian Accounting Standards for the first time. In order to understand the implications of the proposed amendments it will be necessary to have a look at the following paras of general instructions given for preparation of statement of profit & loss account.
1. XX
2. The Statement of Profit and Loss shall include :
(1) Profit or Loss for the period;
(2) Other Comprehensive Income for the period.
The sum of (1) and (2) above is “Total Comprehensive Income.”
3. Revenue from operations shall disclose separately in the notes
(a) Sale of products (including Excise Duty);
(b) Sale of services; and
(c) Other operating revenues
4. Finance Costs : Finance costs shall be classified as —
(a) Interest;
(b) Dividend on redeemable preference shares;
(c) Exchange differences regarded as an adjustment to borrowing costs; and
(d) Other borrowing costs (specify nature).
5. Other income : Other income shall be classified as —
(a) Interest Income;
(b) Dividend Income; and
(c) Other non-operating income (net of expenses directly attributable to such income)
6. Other Comprehensive Income shall be classified into —
A. Items that will not be reclassified to profit or loss
(i) Changes in revaluation surplus;
(ii) Remeasurement of the defined benefit plans;
(iii) Equity Instruments through Other Comprehensive Income;
(iv) Fair value changes relating to own credit risk of financial liabilities designated at fair value through profit and loss.
(v) Others (specify nature).
7. XX
8. XX
The statement of profit & loss account as per Part II below the line is as under:
|
Particulars |
Note No. |
Figures for the current reporting period |
Figures for the previous reporting period |
|
|
XIII |
Profit / (loss) for the period (IX + XII) |
|||
|
XIV |
Other Comprehensive Income A. (i) Items that will not be reclassified to profit or loss. (ii) Income tax relating to items that will not be reclassified to profit or loss. B. (i) Items that will be reclassified to profit (ii) Income tax relating to items that will be reclassified to profit or loss. |
|||
|
XV |
Total Comprehensive Income for the period (XIII + XIV) (comprising of Profit (Loss) and Other Comprehensive Income for the period). |
The proposed amendments to section 115 JB have been made on the basis of final report of the Committee. It may be noted that before switching over to Ind-AS financial statements for first time, the companies used to follow Indian GAAP financial statements. On first time adoption of Ind-AS, the companies are required to record the difference between the Ind-AS and GAAP directly in retained earnings and reserves as on the date of switching over to Ind-AS. Further, Other Comprehensive Income would also include items of valuation differences would never be re-classified to profit or loss. The Committee observed that many of these items of differences which never be re-classified to the statement of profit and loss A/c and hence they would be excluded in computation of book profits for the purpose of 115JB of the Act. Thus the amendments have been made to rope in such items in calculating book profit as per section 115JB.
V. First time Adoption of Ind-AS — 101
The salient features of this standard are stated as under:
1. Objective
The objective of this Indian Accounting Standard (Ind-AS) is to ensure that an entity’s first Ind-AS financial statements, and its interim financial reports for part of the period covered by those financial statements, contain high quality information that:
(a) Is transparent for users and comparable over all periods presented;
(b) Provides a suitable starting point for accounting in accordance with Ind-AS; and
(c) Can be generated at a cost that does not exceed the benefits.
2. Scope
An entity shall apply this Ind-AS in:
(a) Its first Ind-AS financial statements and
(b) Each interim financial report, if any, that it presents in accordance with Ind-AS 34 Interim Financial Reporting for part of the period covered by its first Ind-AS financial statements.
An entity’s first Ind-AS financial statements are the first annual financial statements in which the entity adopts Ind-ASs, in accordance with Ind-AS notified under the Companies Act, 2013 and makes an explicit and unreserved statement in those financial statements of compliance with Ind-ASs.
3. Recognition and measurement of opening Ind-AS Balance Sheet
An entity shall prepare and present an opening Ind-AS Balance Sheet at the date of transition to Ind-ASs. This is the starting point for its accounting in accordance with Ind-ASs.
4. Accounting policies
An entity shall use the same accounting policies in its opening Ind-AS Balance Sheet and throughout all periods presented in its first Ind-AS financial statements. Those accounting policies shall comply with each Ind-AS effective at the end of its first Ind-AS reporting period barring certain exceptions.
5. Exceptions to the retrospective application of other Ind-ASs
This Indian Accounting Standard prohibits retrospective application of some aspects of other Ind-ASs.
6. Exemptions from other Ind-ASs
An entity may elect to use one or more of the exemptions contained in the standard.
7. Explanation of transition to Ind-ASs
An entity shall explain how the transition from previous GAAP to Ind-ASs affected its reported Balance Sheet, financial performance and cash flows.
8. Reconciliation
The entity’s first Ind-AS financial statements shall give detailed reconciliation between the previous GAAP and Ind-AS in respect of various items.
9. Use of fair value as deemed cost
If the entity uses fair value in its opening Ind- AS Balance Sheet as deemed cost for any item of property, the detailed particulars are required to be furnished with regard to each item as per previous GAAP and opening Ind-AS Balance Sheet.
VI. Framework for Computation of Book Profit for Ind-AS Compliance Companies
The Committee has submitted a framework for computation of book profit for Ind-AS compliance companies in the year of adoption and thereafter.
The main features of the frame-work are as under:
A. MAT on Ind-AS compliant financial statement
i. No further adjustments to the net profits before other comprehensive income of Ind-AS compliant companies, other than those already specified under section 115JB of the Act shall be made.
ii. The other comprehensive income includes certain items that will permanently be recorded in reserves and hence never be re-classified to the statement of profit and loss included in the computation of book profits. These items shall be included in book profits for MAT purposes at the point of time as specified below —
|
Sr. No. |
Items |
Point of Time |
|
1 |
Changes in revaluation surplus of Property, Plant or Equipment (PPE) and intangible assets (Ind-AS 16 and Ind-AS 38) |
To be included in book profits at the time of realisation / disposal / retirement or otherwise transferred |
|
2 |
Gains and losses from investments in equity instruments designated at fair value through other comprehensive income (Ind-AS 109) |
To be included in book profits at the time of realisation / disposal / retirement or otherwise transferred |
|
3 |
Remeasurement of defined benefit plans (Ind-AS 19) |
To be included in book profits every year as the remeasurements gains and losses arises |
|
4 |
Any other item |
To be included in book profits every year as the gains and losses arise |
iii. Appendix A of Ind-AS 10 provides that any distributions of non-cash assets to shareholders (for example, in a demerger) shall be accounted for at fair value. The difference between the carrying value of the assets and the fair value is recorded in the profit and loss account. Correspondingly, the reserves are debited at fair value to record the distribution as a ‘deemed dividend’ for the shareholders. As there is a corresponding adjustment in retained earnings, this difference arising on demerger shall be excluded from the book profits. However, in the case of a resulting company, where the property and the liabilities of the undertaking or undertakings being received by it are recorded at values different from values appearing in the books of account of the demerged company immediately before the demerger, any change in such value shall be ignored for the purpose of computing of book profit of the resulting company.
B. MAT on first time adoption
i. The adjustment arising on account of transition to Ind-AS from existing Indian GAAP is required to be recorded directly in Other Equity at the date of transition to Ind-AS. Several of these items would subsequently never be reclassified to the statement of profit and loss / included in the computation of book profits. Accordingly, the following treatment is proposed:
(a) Those adjustments recorded in other comprehensive income and which would subsequently be reclassified to the profit and loss, shall be included in book profits in the year in which these are reclassified to the profit and loss;
(b) Those adjustments recorded in other comprehensive income and which would never be subsequently reclassified to the profit and loss shall be included in book profits as specified hereunder —
|
Sr. No. |
Items |
Point of Time |
|
1 |
Changes in revaluation surplus of PPE and intangible assets (Ind-AS 16 and Ind-AS 38) |
To be included in book profits at the time of realisation / disposal / retirement or otherwise transferred |
|
2 |
Gains and losses from investments in equity instruments designated at fair value through other comprehensive income (Ind-AS 109) |
To be included in book profits at the time of realisation / disposal / retirement or otherwise transferred |
|
3 |
Remeasurement of defined benefit plans (Ind-AS 19) |
To be included in book profits equally over a period of five years starting from the year of first time adoption of Ind-AS |
|
4 |
Any other item |
To be included in book profits equally over a period of five years starting from the year of first time adoption of Ind-AS |
(c) All other adjustment recorded in Reserves and Surplus (excluding Capital Reserves and Securities Premium Reserve) as referred to in Division-II of Schedule III of Companies Act, 2013 and which would otherwise never subsequently be reclassified to the profit and loss account, shall be included in the book profits, equally over a period of five years starting from the year of first time adoption of Ind-AS subject to the following —
a. PPE and intangible assets at fair value as deemed cost
An entity may use fair value in its opening Ind-AS Balance Sheet as deemed cost for an item of PPE or an intangible asset as mentioned in paragraphs D5 and D7 of Ind-AS 101. In such cases the treatment shall be as under:
• The existing provisions for computation of book profits under section 115JB of the Act provide that in case of revaluation of assets, any impact on account of such revaluation shall be ignored for the purposes of computation of book profits. Further, the adjustments in retained earnings on first time adoption with respect to items of PPE and Intangible assets shall be ignored for the purpose of computation of book profits.
• Depreciation shall be computed ignoring the amount of aforesaid retained earnings adjustment.
• Similarly, gain / loss or realisation / disposal / retirement of such assets shall be computed ignoring the aforesaid retained earnings adjustment.
b. Investments in subsidiaries, joint ventures and associates at fair value as deemed cost
An entity may use fair value in its opening Ind-AS Balance Sheet as deemed cost for investment in a subsidiary, joint venture or associate in its separate financial statements as mentioned in paragraph D15 of Ind-AS 101. In such cases retained earnings adjustment shall be included in the book profit at the time of realisation of such investment.
c. Cumulative translation differences
• An entity may elect a choice whereby the cumulative translation differences for all foreign operations are deemed to be zero at the date of transition to Ind-AS. Further, the gain or loss on a subsequent disposal of any foreign operation shall exclude translation differences that arose before the date of transition to Ind-AS and shall include only the translation differences after the date of transition.
• In such cases, to ensure that such Cumulative translation differences on the date of transition which have been transferred to retained earnings, are taken into account, these shall be included in the book profits at the time of disposal foreign operations as mentioned in paragraph 48 of Ind-AS 21.
ii. All other adjustments to retained earnings at the time of transition (including for example, Decommissioning Liability, Asset retirement obligations, Foreign Exchange Capitalisation / Decapitalisation, Borrowing Costs Adjustments, etc.) shall be included in book profits, equally over a period of five years starting from the year of first time adoption of Ind-AS.
iii. Section 115JB of the Act already provides for adjustments on account of deferred tax and its provision. Any deferred tax adjustments recorded in Reserves and Surplus on account of transition to Ind-AS shall also be ignored.
C. Reference year for first time adoption adjustments
In the first year of adoption of Ind-AS, the companies would prepare Ind-AS financial statement for reporting year with a comparative financial statement for immediately preceding year. AS per Ind-AS 101, a company would make all Ind-AS adjustments on the opening date of the comparative financial year. The entity is also required to present an equity reconciliation between previous Indian GAAP and Ind-AS amounts, both on the opening date of preceding year as well as on the closing date of the preceding year. It is proposed that for the purposes of computation of book profits of the year of adoption and the proposed adjustments, the amounts adjusted as of the opening date of the first year of adoption shall be considered. For example, companies which adopt Ind-AS with effect from 1st April, 2016 are required to prepare their financial statements for the year 2016-17 as per requirements of Ind-AS. Such companies are also required to prepare an opening balance sheet as of 1st April, 2015 and restate the financial statements for the comparative period 2015-16. In such a case, the first time adoption adjustments as of 31st March, 2016 shall be considered for computation of MAT liability for previous year 2016-17 (Assessment Year 2017-18) and thereafter. Further, in this case, the period of five years proposed above shall be previous years 2016-17, 2017-18, 2018-19, 2019-20 and 2020-21.
VII. Proposed Amendments to Section 115 JB
As stated above, Para 6 of General Instructions for Preparation of Statement of Profit and Loss requires classification of Other Comprehensive Income into items that will not be re-classified to profit or loss and items that will be re — classified to profit or loss. Keeping this in mind, in Section 115JB, new sub-sections (2A), (2B) and (2C) are proposed to be inserted after sub-section (2). The discussion on the said sub — sections are as under:
1. Sub-section (2A) states that for a company whose financial statements are drawn up in compliance to the Indian Accounting Standards specified in Annexure to the Companies (Indian Accounting Standards) Rules, 2015, the book profit as computed in accordance with Explanation 1 to sub- section (2) shall be further.
(a) Increased by all amounts credited to other comprehensive income in the statement of profit and loss under the head “Items that will not be re- classified to profit or loss”;
(b) Decreased by all amounts debited to other comprehensive income in the statement of profit and loss under the head “Items that will not be re- classified to profit or loss”;
(c) Increased by amounts or aggregate of the amounts debited to the statement of profit and loss on distribution of non-cash assets to shareholders in a demerger in accordance with Appendix A of the Indian Accounting Standards 10;
(d) Decreased by all amounts or aggregate of the amounts credited to the statement of profit and loss on distribution of non-cash assets to shareholders in a demerger in accordance with Appendix A of the Indian Accounting Standards 10;
The first proviso to sub-section (2A) states that nothing contained in clause (a) or clause (b) shall apply to the amount credited or debited to other comprehensive income under the head “Items that will not be re — classified to profit or loss” in respect of —
(i) Revaluation surplus for assets in accordance with the Indian Accounting Standards 16 and Indian Accounting Standards 38; or
(ii) Gains or losses from investments in equity instruments designated at fair value through other comprehensive income in accordance with the Indian Accounting Standards 109:
The second proviso to sub — section (2A) states that the book profit of the previous year in which the asset or investment referred to in the first proviso is retired, disposed, realised or otherwise transferred shall be increased or decreased, as the case may be, by the amount of the aggregate of the amounts referred to in the first proviso for the previous year or any of the preceding previous years and relatable to such asset or investment.
2. Sub-section (2B) states that in demerger, in the case of a resulting company, the property and the liabilities of the undertaking or undertakings being received by it are recorded at values different from values appearing in the books of account of the demerged company immediately before the demerger, any change in such value shall be ignored for the purpose of computation of book profit of the resulting company under this section.
3. Sub-section (2C) states that for a company referred to in sub-section (2A), the book profit of the year of convergence and each of the following four previous years, shall be further increased or decreased, as the case may be, by one — fifth of the transition amount;
The first proviso to sub-section (2C) states that the book profit of the previous year in which the asset or investment referred to in sub-clauses (B) to (E) of clause (iii) of the Explanation is retired, disposed, realised or otherwise transferred shall be increased or decreased, as the case may be, by the amount of the aggregate of the amounts referred to in the said sub-clause relatable to such asset or investment:
The second proviso to sub-section (2C) states that the book profit of the previous year in which the foreign operation referred to in sub -clauses (F) of clause (iii) of the Explanation is disposed or otherwise transferred, shall be increased or decreased, as the case may be, by the amount of the aggregate of the amounts referred to in the said sub-clause relatable to such foreign operations.
Explanation (iii) defines ‘transition amount’ to mean — amount or aggregate of the amounts adjusted in other equity on the convergence date but not including the following :
(A) Amount or aggregate of the amounts adjusted in the other comprehensive income on the convergence date which shall be subsequently re-classified to the profit and loss;
(B) Revaluation surplus for assets in accordance with the Indian Accounting Standards 16 and Indian Accounting Standards 38 adjusted on the convergence date;
(C) Gains or losses from investments in equity instruments designated at fair value through other comprehensive income in accordance with the Indian Accounting Standards 109 adjusted on the convergence date;
(D) Adjustments relating to items of property, plant and equipment and intangible assets recorded at fair value as deemed cost in accordance with paragraphs D5 and D7 of the Indian Accounting Standards 101 on the convergence date;
(E) Adjustments relating to investments in subsidiaries, joint ventures and associates recorded at fair value as deemed cost in accordance with paragraph D15 of the Indian Accounting Standards 101 on the convergence date; and
(F) Adjustments relating to cumulative translation differences of a foreign operation in accordance with paragraph D13 of the Indian Accounting Standards 101 on the convergence date.
VIII. Summary and Conclusion
1. Under section 145(2) of the Act, the Central Government has notified income computation and disclosure standards. These standards are more or less similar to the current Indian GAAP, but they are not the same. Due to conflicts between the two, the litigation has increased. The switching over to Ind-AS would also give rise to litigation as there is no alignment between the CG notified standards and Ind-AS. The main provisions
of the proposed amendments are analysed as under :
|
Sr. No. |
Items |
Point of Time |
Remarks |
|
1. |
Changes in revaluation, surplus of Property, Plant or Equipment (PPE) and Intangible assets |
To be included in book profits at the time of realisation / disposal / retirement or otherwise transferred |
The company assessee will have MAT liability only when the assets are disposed of / sold etc. |
|
2. |
Gains and losses from investments in equity instruments designated at fair value through other comprehensive income |
To be included in book profits at the time of realisation / disposal / retirement or otherwise transferred |
The company assessee will have MAT liability only when the assets are disposed of / sold etc. |
|
3. |
Remeasurement of defined benefit plans |
To be included in book profits every year as the remeasurements gains and losses arise |
The company assessee will not face the burden of MAT liability in one year as the same will be spread over |
|
4. |
Any other item |
To be included in book profits every year as the gains and losses arise |
The company assessee will not face the burden of MAT liability in one year as the same will be spread over |
2. It may be noted that the company assessees can reduce their tax liability under MAT if they choose right FTA options.
3. The proposed amendments are ambiguous and are not properly worded as a result of which the company assessees would face an uphill task of arriving at book profit and computing their MAT liability which would give lever to assessing authorities to make upward revision of book profit.
4. No write-up on the Finance Bill can ever be completed without paying tribute to late. Mr. N. A. Palkhiwala. I take liberty to quote the following passages from the “Preface to the Eight Edition” (1990) of Kanga & Palkhiwala’s “The Law and Practice of Income Tax”.
“Today the Income-tax Act, 1961, is a national disgrace. There is no other instance in Indian jurisprudence of an Act mutilated by more than 3,300 amendments in less than thirty years. Simple provisions like sections 11 to 13 (which deal with exemption of the income of charitable trusts) have suffered no less than fifty amendments.
The tragedy of India is the tragedy of waste — waste of national time, energy and manpower. Tens of millions of man -hours, crammed with intelligence and knowledge — of taxgatherers, taxpayers and tax advisers — are squandered every year in grappling with the torrential spate of mindless amendments. The feverish activity achieves no more good than a fever.
The Finance Ministry has become almost pathological in its “change mania”. A stable fiscal policy is to a nation what a stable family life is to an individual. But stability is anathema to the North Block.
It has become normal to have amendments to Income Tax Rules more than half a dozen times in a single year. Various Forms are changed overnight. Can this country, where crores of school children and adults have to go without writing paper, afford the luxury of throwing away millions of pages of printed Forms which are consigned to the scrap heap so non-chalantly?”
The proposed amendments could have been made simpler. However one has to wait and watch as to which amendments would become part of the Act and after being incorporated in the Act how they are implemented and interpreted in future.