New ITR Form 6: 4 New Schedules & countless additional information – Is it only impact of Demonetization & GST

The new form for Filing of Income Tax Return for the Companies i.e. ITR-6 for the AY 2018-19 has been notified by the CBDT on April 5, 2018 vide notification no. 16/2018 which has brought enormous changes in requirement of disclosures. Implementation of GST, demonetization, application of Ind AS, ICDS, increasing international transactions and OECD guidelines on BEPS impact has made additional disclosures substantive. It is time to get ready and look at the additional disclosures requirement. It is going to take a lot of time to get all the details, to make their schedules, in analyzing their impact on the computation of total income and their presentation in the New Form.

A summary of the additional information which will be required to the file in the New ITR Form is as follows:

1. Details of IGST, CGST, SGST & UTGST received/receivable & paid/payable and the amount O/S at the end of the year separately under each head.

2. Confirmation that whether the financial statements of the company are drawn up in compliance to the Ind AS specified in Annexure to the companies (Indian Accounting Standards) Rules, 2015, if Yes, disclosure of Balance Sheet & P/L Account as per the Ind AS. Two New Schedules have been introduced for B/S & P/L Account details as per the Ind AS.

3. Disclosure of Other Comprehensive Income (‘OCI’) details under the head of P&L:

a. Items that will not be reclassified to P&L

• Changes in revaluation surplus
• Re-measurements of the defined benefit plans·
• Equity instruments through OCI
• Fair value Changes relating to own credit risk of financial liabilities designated at FVTPL
• Share of Other comprehensive income in associates and joint ventures, to the extent not to be classified to P&L·
• Others (Specify nature)
• Income tax relating to items that will not be reclassified to P&L

b. Items that will be reclassified to P&L

• Exchange differences in translating the financial statements of a foreign operation·
• Debt instruments through OCI·
• The effective portion of gains and loss on hedging instruments in a cash flow hedge·
• Share of OCI in associates and joint ventures to the extent to be classified into P&L·
• Others (Specify nature)·
• Income tax relating to items that will be reclassified to P&L 

4. Provision of disclosure of Deemed Total Income has been introduced in the MAT Schedule. In case, financial statements of the company are drawn up in compliance to the Ind -AS, the following information is required to be disclosed in the MAT Schedule i.e.

a. Amounts credited/debited to other comprehensive income in statement of profit & loss under the head “items that will not be reclassified to profit & loss”

b. Amounts debited/credited to the statement of profit & loss on distribution of non-cash assets to shareholders in a demerger

c. One fifth of the transition amount as referred to in section 115JB (2C) (if applicable)

d. Others (including residual adjustment)

5. New Schedule of GST – Break-up of total expenditure with entities registered or not registered under the GST:

a. Expenditure in respect of entities registered under GST

• Relating to goods or services exempt from GST
• Relating to entities falling under composition scheme
• Relating to other registered entities
• Total payment to registered entities

b. Expenditure relating to entities not registered under GST

6. New Schedule of transactions in Foreign Currency – Break-up of payments/receipts in foreign currency:

a. Payments/receipts made during the year on capital account

b. Payments/receipts made during the year on revenue account

7. Additional disclosure in respect of the Depreciation i.e.

a. Revised depreciation schedule as the highest rate of depreciation for any block of asset is restricted to 40%

b. Details of depreciation disallowed u/s 38(2) of the IT Act i.e. where any building, machinery, plant or furniture is not exclusively used for the purposes of the business or profession.

c. Land details need to be disclosed – at NIL rate.

d. Proportionate aggregate depreciation allowable in the event of succession, amalgamation, demerger etc.

8. Where DTAA benefits have been claimed the following additional information shall be disclosed:

• Country name & Code
• Article of DTAA
• DTAA Rate as per Treaty
• Whether TRC obtained
• Section of I.T. Act
• Rate as per I.T. Act
• Applicable rate

9. Deviation in P&L due to ICDS notified – New Form provides that the overall impact of deviation should be classified in two parts i.e.

a. Increase in the profit or decrease in loss because of deviation

b. Decrease in the profit or increase in loss because of deviation

(In the old Form, it was only overall impact which needs to be disclosed)

10. Appropriation towards Corporate Social Responsibility (CSR) activities

11. Transfer of TDS Credit to Another Person. (Deducted in the hands of any other person as per rule 37BA(2) (if applicable)) – Under the provision of the IT Act, where the whole or any part of the income on which tax has been deducted at source is assessable in the hands of a person other than the deductee, credit for the whole or any part of the TDS, as the case may be, shall be given to the other person and not to the deductee provided that the deductee file a declaration with the deductor and the deductor reports the tax deduction in the name of the other person in the tax withholding statement. The new ITR form provides separate column where these details are required to be shown.

12. Deviation in P&L due to deviation in the Method of valuation of closing stock – New Form provides that the overall impact of deviation should be classified in two parts i.e.

a. Increase in the profit or decrease in loss because of deviation

b. Decrease in the profit or increase in loss because of deviation

13. In case of unlisted company, particulars of natural persons who were the ultimate beneficial owners, directly or indirectly, of shares holding not less than 10% of the voting power at any time of the previous year.

14. In case of non-resident, SWIFT Code of the foreign Bank Account to be declared.

15. In case, total turnover/ gross receipts in the previous year 2015-16 was exceeding Rs.50 crore, the company is liable to pay tax @25%. (for the AY 2017-18, it was Rs.5 Crores for the PY 2014-15 and the tax rate was @29%. These slabs are applicable only for the domestic companies.)

16. Income from transfer of carbon credits u/s 115BBG need to be shown separately at Part B – TI, Schedule OS & Schedule SI

17. Fee for default in furnishing return of income (section 234F)

18. In the case of sale of shares of unlisted companies, the requirement to disclose the Actual Sales consideration and Fair Market value of the shares.

19. In case of Deduction under Capital Gain (i.e. u/s 54B/54D/54EC/54EE /54G/54GA etc.) additional detail is required to be disclosed e.g. date of transfer of original asset etc.

20. Details of additions to be made under section 56(2)(x) – Tax the deemed gift of certain defined properties/assets in the hands of every person receiving such property/assets in the hands of every person receiving such property/asset subject to certain exceptions as provided therein.

21. The new form requires additional information of Deduction not allowable u/s 58 – With a view to improve compliance of provision relating to TDS, amendment has been made in section 58 to provide that provisions of section 40(a)(ia) will, so far as they may be, apply in computing income from Other Sources as they apply in computing income chargeable under the head of income from PGBP.

22. Information on Income u/s 59 – The new Form also seeks information of income u/s 59 which mention that the provisions of Section 41(1) (Taxability on remission of trading liability) shall apply, so far as may be, in computing the income of an assessee u/s 56, as they apply in computing the income of an assessee under the head of PGBP.

The only removal is Schedule for deduction u/s 10A which is no longer required.