Monday, 22 June 2015

Understanding Taxation of Political parties.


 
The income tax law prevalent in India has shown a kind and compassionate treatment. Section 13A of the Income-tax Act, 1961 confers tax-exemption to recognized political parties for income from house property, income by way of voluntary contributions, income from capital gains and income from other sources. In other words, only income under the head salaries and income from business or profession are chargeable to tax in the hands of political parties in India. These political outfits can enjoy the above-said tax-exemption if they maintain proper books of accounts and other documents along with a record of contributions in respect of donations to the party in excess of Rs 20, 000.
Further, the accounts of such political party are to be audited by a chartered accountant and the party must be registered with the Election Commission of India. However, it would be enough if such political party keeps and maintains such books of accounts and other documents as would enable the assessing officer to properly deduce the income therefrom. In other words, the party need not maintain all books and records as prescribed under section 44AA of the Income-tax Act. Since the income of political parties are governed by the special provisions of section 13A of the Income tax Act, 1961, the provisions of Chapter IV-D of the Act which are applicable for normal profits and gains of normal profession cannot be applied in the cases of political parties.
Further, income of political parties from voluntary contributions cannot be said to be income from profession so as to attract section 44AA or 44AB or section 271B of the Income-tax Act. However, the political parties are required to maintain the accounts and getting them audited by a chartered accountant, as provided u/s 13A for claiming exemption. Under section 45(i) of the Wealth tax Act, 1957 no tax would be levied in respect of the net wealth of any political party as defined in Explanation to section 13A of the Income –tax Act, 1961. Thus, political parties in India are destined to enjoy tax freedom not only from the so-called income tax law but also from its sister law, viz, the wealth-tax law.
Under section 139(4B) of the Income tax Act, 1961, political parties are however under a statutory obligation to file return of income in respect of each assessment year. If and when the total income of a political party exceeds the maximum amount, which is not chargeable to tax, the liability of the political party to file ROI voluntarily arises. For this purpose, total income has to be computed without giving effect to provisions of section 13A. In case of political parties, the returns are required to be signed by the ‘Executive Officer’ of the parties. Further, the amendment made in 2003 to the Representation of the People Act, 1951 requires that the treasurer of every political party must file a declaration in respect of donations exceeding Rs. 20,000 at a time. Accordingly, the party treasurer must file a report of contributions received to the Election commission before the due date for furnishing the return of income under Section 139 of the Income tax Act.
More importantly, section 13A has been amended and tax exemption for a political party is contingent upon the submission of the report by the party treasurer. Moreover, contributions over Rs.20,000 should be by crossed cheque or draft. However, the parties can receive any amount below this from any person without submitting the report from the party treasurer.
Section 80GGB is a new insertion in the Income-tax Act, 1961. This enables Indian companies to get full deduction in their income-tax assessments for contributions made to political parties. Interestingly, there is no ceiling fixed on the amount of such contribution. Section 80GGC gives similar deduction for non-company taxpayers. Advertisements in souvenirs published by political parties would also be eligible for deduction. For this purpose, the term “political party” means a political party registered under section 29A of the Representation of the People Act, 1951.
 
Return of Income of Political Parties [Section 139(4B)]
  • 1. Under this section, a political party is required to file a return of income if, before claiming exemption under section 13A, the party has taxable income. The grant of exemption from income-tax to any political party under section 13A is subject to the condition that the political party submits a return of its total income within the time limit prescribed under section 139(1).
  • 2. The chief executive officer of the political party is statutorily required to furnish a return of income of the party for the relevant assessment year, if the amount of total income of the previous year exceeds the basic exemption limit before claiming exemption under section 13A.
  • 3. The return must be filed in the prescribed form and verified in the prescribed manner setting forth such other particulars as may be prescribed by the CBDT.
  • 4. The provisions of the Act would apply as if it were a return required to be furnished under section 139(1).
 
CBDT has vide Notification No. 24/2014 dated 01.04.2014 amended rule 12 of Income Tax Rules 1962. Prior to amendment of Rule 12 and upto A.Y. 2013-14 All Political Parties were allowed to Furnish ITR 7 in any of the following mode :-
(i)           furnishing the return in a paper form;
(ii)          furnishing the return electronically under digital signature;
(iii)         transmitting the data in the return electronically and thereafter submitting the verification of the return in Form ITR-V;
But with amendment in Rule 12 w.e.f. A.Y. 2014-15 Political Parties can File ITR 7 only electronically under digital signature.
Relevant Extract of Rule 12 of Income Tax Rules 1962
(3) The return of income referred to in sub-rule (1) may be furnished in any of the following manners, namely:—
(i)           furnishing the return in a paper form;
(ii)          furnishing the return electronically under digital signature;
(iii)         transmitting the data in the return electronically and thereafter submitting the verification of the return in Form ITR-V;
(iv)         furnishing a bar-coded return in a paper form:
(b)            a person required to furnish the return in Form ITR-7 shall furnish the return for assessment year 2014-15 and subsequent assessment years,-
    (A) in case it is furnished under sub-section (4B) of section 139, in the manner specified in clause (ii);
    (B) in other cases, in the manner specified in clause (i) or clause (ii) or clause (iii)
Relevant Extract of Section 139(4B)
Section 139 (4B)The chief executive officer (whether such chief executive officer is known as Secretary or by any other designation) of every political party shall, if the total income in respect of which the political party is assessable (the total income for this purpose being computed under this Act without giving effect to the provisions of section 13A) exceeds the maximum amount which is not chargeable to income-tax, furnish a return of such income of the previous year in the prescribed form and verified in the prescribed manner and setting forth such other particulars as may be prescribed and all the provisions of this Act, shall, so far as may be, apply as if it were a return required to be furnished under sub-section (1).]
 
 
FAQs - ITR of political parties
 
1.       Do political parties get tax exemption? If so, how much?
 
Under Section 13A of the Income Tax Act, political parties are exempt from paying Income Tax but are required to file their Income Tax returns annually to the Income Tax Department. They enjoy 100% tax exemption from all sources of income.
 
2.       Under what Act do the Political Parties enjoy tax exemption?
 
Political parties registered with the Election Commission of India are exempt from paying Income Tax under Section 13A of Income Tax Act, 1961 as long as the political parties file their Income Tax Returns every Assessment Year along with their audited accounts, Income/ Expenditure details and balance sheet.
 
There is a proviso to Sec 13A as follows:
 
“Provided further that if the treasurer of such political party or any other person authorised by that political party in this behalf fails to submit a report under subsection (3) of section 29C of the Representation of the People Act, 1951 (43 of 1951) for a financial year, no exemption under this section shall be available for that political party for such financial year.”
 
3.       Under what section do the political parties have to file their income tax returns and how often?
 
Similar to the Income Tax Returns (ITR) filed by individual tax payers in India, registered political parties too
 
have to file their Income Tax Returns every year. According to Section 139 (4B), returns of a political party is required to be filed of a particular financial year, audited and submitted by the 30th of September.
 
4.       How to get a copy of the ITR of a particular political party?
 
For obtaining a copy of the ITR of a political party, an RTI has to be drafted to the Income Tax Department of the city in which the political party is registered. Examples of such RTIs can be found at  http://adrindia.org/content/rtis-scanned-copies-filed-political-parties-income-tax-returns-donations where both the RTIs and their replies from the concerned authority have been made available.
 
5.       What is the main information to look for in an ITR filed by the political party?
 
There are five components that provide information relating to the functioning of the political party. They are:
 
·   Balance Sheet: Contains a broad information of the main sources of funds (Corpus fund, general funds, loans etc) and the application of those funds (assets, investments, advances etc)
 
·   Income and Expenditure Account: Income from fee/ grants, donations, sale of coupons etc and the Expenses towards election, finance, employee costs etc
 
·   Schedules: This is the breakup of individual component in the balance sheet wherein every detail regarding loans taken, given, details of purchase of any asset, details of investments etc
 
·   Contribution report: This is the report containing details of donors who have made contribution above Rs 20,000 to the political party during the specified financial year. A copy of this report this sent to the Election  Commission on an annual basis (mandatory) which correlates with the Income Tax department for tax exemption.
 
  Assessment order: Ordering scrutiny of the accounts provided by the party
 
6.       What is an assessment order and who issues it?
 
If the income tax returns filed by the political party come into scrutiny by the Income Tax Department, a notice is issued to the party requesting their presence for an assessment proceeding. Such a notice is called an assessment order, the proceedings of which should be conducted by the Income Tax Department by the end of the next financial year. An example where an assessment order might be issued is when a political party declares NIL income during a particular financial year. Once called for assessment proceedings, the said political party has to show adequate proof for declaring NIL income in its returns.
 
7.       What are the sources from which political parties derive their income?
 
From the Income Tax Returns filed by political parties, it can be safely said that they function mainly on the basis of donations from individuals and companies/ institutions. Apart from voluntary contributions, income received from sale of coupons, membership fee collected and interest earned form the major sources of income of political parties.
 
8.       One of the sources of income has been given as ‘Sale of Coupons’. What are coupons and how are they made available to the political parties for sale?
 
Coupons are one of the ways devised by the political parties for collecting donations and hence are printed by the party itself. There is no cap or limit as to how many coupons can be printed or the total quantum (that is the total amount/worth of coupons). Details of donors is not required for coupons with small amounts (say Rs 5/10/20 etc), and might be where all the unaccounted/black money might be pumped in. The only source of information regarding the coupon system is the party itself and no on else. Coupon system does not come under the scope of Election Commission of India and they have no control over it.
 
9.       How is the ‘donations’ given in the ITR different from the donations report submitted to the ECI?
 
Donations, mentioned as one of the sources of income, given in the Income Tax returns is the sum of donations received through various means during that financial year such as through sale of coupons, through a party rally, while conducting public meeting and need not necessarily be above Rs 20,000 and do not provide information about the individual amount collected nor the mode of payment of these donations whereas the donations report submitted to the ECI are those made above Rs 20,000 listing the details of the donors, their address and their mode of payments.
 
10.   What are the types of accounting methods followed by the political parties and what is the suggested method of accounting?
 
There are two types of accounting methods currently being followed by political parties: The Cash accounting and the accrual method of accounting. The former method registers the transactions when the related cash transactions take place. Thus, the revenue of political parties such as donations, grants etc is recognized when funds are actually received while failing to show a proper picture of the financial position of the party. On the other hand, the accrual method of accounting, records transactions during the period they occur such as revenue, expenses, assets and liabilities in real-time thus providing information about the real level of organisation’s activities.
 
Accrual basis of accounting is recommended by the Institute of Chartered Accountants of India (ICAI) for the political parties.
 
11.   Have there been any concerns about the way political parties have been filing their Income Tax Returns?
 
As all political parties do not employ the same method of accounting, there is a concern that the present auditing techniques do not meet the financial information requirements of the public at large. Hence a sound accounting and auditing framework for standardising the procedure of filing returns would improve the accountability of political parties towards utilising their financial resources.
 
12.   What is the Institute of Chartered Accountants of India (ICAI)?
 
The Institute of Chartered Accountants of India is the body which defines the way the Income Tax returns have to be audited and submitted. It is a known fact that the funding of the political parties are diversified hence the objective of accountability and transparency is of great importance. ICAI had laid down a few recommendations to the ECI for improving transparency and accountability in dissemination of accounts of the political parties which were accepted by the ECI.
 
13.   What are the latest recommendations by the ICAI towards filing of Income Tax Returns by the political parties?
 
The recommendations aim at bringing in a standard format through which the political parties can file their Income Tax returns. The document containing guidelines issued to the Chartered Accountants by ICAI for a uniform audit can be viewed at  http://adrindia.org/sites/default/files/Guidance_Note_on_Accounting_Auditing_of_Political_Parties.pdf
 
As mentioned earlier, cash flow of accounting has a few flaws whereas accrual method, though superior, did not capture the cash flow of the party effectively. Hence the new recommendations suggest that a format be used so that the advantages of both the methods be utilised. The suggested ITR to contain:
 
·       Balance Sheet
 
·       Income and Expenditure Account
 
·       Cash flow Statement: Similar to the cash mode of accounting giving information of cash receipts/ payments as they occur
 
·       Notes forming part of financial statements: Notes giving reasons for not following the suggested changes and any additions made to the suggested changes
 
Recommendations for Auditing of Political Parties
 
ICAI has recommended for audit of the accounts of political parties, by a firm of Chartered Accountants, appointed on rotation every 3 years, by the ECI. Auditors would be required to follow the Auditing and Assurance Standards issued by the ICAI, while auditing the accounts of the political parties.
 

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