1.

Lead time for introduction of proposed changes in Budget: No lead time is given for introduction of new rates/procedures/duties.

Any New Levy & Mechanism Should Be Notified Early.Reasonable time should be provided to assesses for any changes made to any act which brings out a change to the existing rate/procedure/duty etc.

The industry faces stoppage of activities for bringing about any new changes in their systems especially when most of the companies are running on ERP.

2.

Wealth Tax on vacant Industrial Land

Vacant Industrial lands, which are earmarked for future expansion to be exempt from Wealth Tax.

The quantum of investment in automobile sector is sizeable. The land is acquired by the industry keeping in mind future expansion plans. Under such circumstances, new industrial units will have vacant land meant to meet requirements for future expansion. To tax investments made on land, which are not fully utilized and are in vacant condition is a retrograde step. At present holding of Industrial land in vacant is allowed under law only for a period of two years, thereafter such vacant land is subject to wealth Tax. However such a provision is detrimental to auto industries whose investments are in different phases spread over a period of 10-20 years.

3.

Issues in implementation of new tax/rate/change in structure

Either the tax should be kept at a totalled single rate or the imposition/change in any tax structure should be done in consultation with representatives of the software industry like SAP, Oracle, etc.

On introduction of education cess, the industry as well as the customs faced problems in updating the systems immediately. The invoicing at times comes to a grinding halt due to this.

This would mean a smooth transition to the proposed tax structure. Also there should be interim arrangements to tide over immediate implementation of any new tax or cess.