As we are aware that at present the dividend income received from a domestic company is exempt from tax in the hands of the recipient. this is due to the fact that a specific exemption has been given under section 10(34) of the Income Tax Act, 1961. The exemption is available if the dividend is received by the shareholder from a domestic company if the dividend has suffered a Dividend Distribution Tax (DDT) under section 115-O.
Similarly, any dividend received by the unitholders of a mutual fund is also exempt in the hands of the recipients.
The exemption is given to the recipients of the dividend income only after the introduction and levy of dividend distribution tax (DDT) on the dividend declared, distributed and paid by a domestic company and a mutual fund.
The provision related to DDT on the dividend declared, distributed and paid by a domestic company was introduced for the first time by the Finance Bill, 1997.
Prior to the introduction of the provisions related to DDT on dividend or section 115-O, every company was required to deduct taxes at the time of payment of dividends to a shareholder if the dividend payment exceeds Rs. 2,500 and was required to deposit the same in the Central Government account. The company was also required to issue TDS certificates to all shareholders in whose cases the tax had been deducted. The shareholders, in turn, had to show the dividend in their return of income and pay the tax at the rate applicable in their case. They also had to enclose the TDS certificates along with the return and claim credit for the tax deducted at source. Many a time, the tax deducted or a part thereof is required to be refunded to the assessee. Thus the procedure for tax collection was cumbersome and involved a lot of paperwork.
In order to encourage investment in the shares of domestic companies, the Finance Bill, 1997 proposed to exempt from income-tax, dividends received from domestic companies on or after 1st June 1997.
Consequently, deductions under section 80L and 80M in respect of corporate dividends had been discontinued. The provisions relating to tax deduction at source from dividends had also been suitably modified.
Provisions of sections 115-O, 115P and 115Q were first time inserted by the Finance Act, 1997 to introduce DDT and simultaneously section 10(33) was amended to provide an exemption from the dividend income to the recipients or shareholders. The provisions were introduced in Chapter XII-D of the Income Tax Act, 1961.
The Finance Act, 2002 withdrawn the dividend distribution tax (DDT) and consequently the exemption given to recipients of dividend income under section 10(33) was also withdrawn.
In the very next year, the Finance Act, 2003 reintroduced the DDT in respect of dividend declared, distributed or paid on or after 1-4-2003 and inserted a new clause (34) in section 10 to make dividend exempt again in the hands of the shareholders. Since then the provision is continued till 31st March 2020.
The Finance Act, 2014 amended the provisions related to payment of DDT by grossing up the dividend amount payable. The dividend amount would need to be grossed up for taxes before distribution.
Finance Act, 2016 introduced a new provision to tax the DDT suffered dividend amount in excess of Rs 10 lakh received by an Indian resident from a company to be taxed at 10%.
The Finance Bill, 2020 has proposed to make the dividend taxable again in the hands of the recipient by abolishing the dividend distribution tax (DDT).
Thus, the provision of DDT is applicable from 1-4-2003 to 31-3-2020.
Due to the abolishment of section 115-O and section 115R related to DDT from 01-04-2020, there are 17 other consequential amendments in the Finance Bill, 2020 related to dividend income.
Thus, the provision of DDT is applicable from 1-4-2003 to 31-3-2020.
Due to the abolishment of section 115-O and section 115R related to DDT from 01-04-2020, there are 17 other consequential amendments in the Finance Bill, 2020 related to dividend income.
All the amendments are applicable from Assessment Year 2021-22.
Amendment of Section 115-O
Abolishment of Dividend Distribution Tax on companies
Presently, Section 115-O provides that, in addition to the income-tax chargeable in respect of the total income of a domestic company, any amount declared, distributed or paid by way of dividends shall be charged to additional income-tax at the rate of 15 percent. The tax so paid by the company (called DDT) is treated as the final payment of tax in respect of the amount declared, distributed or paid by way of dividend.
Such a dividend referred to in section 115-O is exempt in the hands of shareholders under clause (34) of section 10.
In the case of business trust, a specific exemption is provided under sub-section (7) of section 115-O, subject to certain conditions.
Similarly, an exemption is provided for distributed profits of a unit of an International Financial Service Centre, on fulfilment of certain conditions, under sub-section (8) of section 115-O.
The incidence of tax is, thus, on the payer company/Mutual Fund and not on the recipient, where it should normally be. The dividend is income in the hands of the shareholders and not in the hands of the company.
The incidence of the tax should, therefore, be on the recipient.
Moreover, the present provisions levy tax at a flat rate on the distributed profits, across the board irrespective of the marginal rate at which the recipient is otherwise taxed. The provisions are hence, considered, iniquitous and regressive.
The present system of taxation of dividends in the hands of company/mutual funds was reintroduced by the Finance Act, 2003 (with effect from the assessment year 2004-05) since it was easier to collect tax at a single point and the new system was leading to increase in compliance burden.
However, with the advent of technology and the easy tracking system available, the justification for the current system of taxation of dividends has outlived itself.
In view of above, the Finance Bill, 2020 has proposed an amendment to the section 115-O so that dividend is taxable in the hands of shareholders at the applicable rate and the domestic company is not required to pay any DDT.
The Finance Bill, 2020 has therefore proposed that "any amount declared, distributed or paid by a domestic company by way of dividends (whether interim or otherwise) on or after the 1st day of April, 2003, but on or before the 31st day of March, 2020" shall be covered under the provisions of section 115-O.
In effect, any amount declared, distributed or paid by a domestic company by way of dividends (whether interim or otherwise) on or after the 1st day of April 2020 shall not be liable for Dividend Distribution Tax (or DDT).
Amendment of Section 115R
Abolishment of Dividend Distribution Tax on mutual funds
Presently, under section 115R, specified companies and Mutual Funds are required to pay additional income tax on income distributed to its unitholders at the rates ranging from 10 per cent to 30 per cent depending upon the type of fund.
Such income distributed referred to in section 115R is exempt in the hands of unitholders under clause (35) of section 10.
The Finance Bill, 2020 has proposed an amendment to section 115R so that the distributed income is taxable in the hands of unitholders at the applicable rate and the specified company or mutual funds are not required to pay any DDT.
In effect, any distributed income by a specified company or a Mutual Fund on or after the 1st day of April 2020 shall not be liable for Dividend Distribution Tax (or DDT).
Amendment of section 10(34)
Exemption from dividend income withdrawn
Due to the abolishment of DDT on dividend income under section 115-O, the tax exemption given to the recipients of the dividend income i.e. the shareholders under section 10(34) has been withdrawn.
The Finance Bill, 2020 has proposed to amend clause (34) of section 10 to provide that the provision of this clause shall not apply to any income, by way of dividend, received on or after 1st April, 2020.
In effect, the tax exemption on dividend income received on and after 1st April 2020 shall not be available and thus, the receipt of dividend income is taxable.
Amendment of section 10(35)
Exemption from distributed income withdrawn
Due to the abolishment of DDT on distributed income under section 115R, the tax exemption given to the recipients of the distributed income from a specified company or a mutual fund i.e. the unitholders under section 10(35) has been withdrawn.
The Finance Bill, 2020 has proposed to amend clause (35) of section 10 to provide that the provision of this clause shall not apply to any income, in respect of units, received on or after 1st April, 2020.
In effect, the tax exemption on distributed income received on and after 1st April 2020 shall not be available and thus, the receipt of such income is taxable.
Amendment of section 57
Deduction for expense under section 57 from Dividend Income
As per section 56(2)(i), dividend income shall be chargeable to tax under the head 'Income from other sources'. Section 57 (i) allows deduction of expenses for the purpose of realising dividend income.
Presently, no deduction can be claimed for the dividend income which has suffered DDT under section 115-O. Since section 115-O is made inapplicable from 01-04-2020, hence section 57 is amended to cover any dividend income. As a result, any expenses incurred for earning the taxable dividend income can be claimed as deduction under section 57(i), subject to another amendment restricting the deduction as mentioned below.
The Finance Bill, 2020 has proposed another amendment in section 57 to provide that no deduction shall be allowed from the dividend income or income from units of a Mutual Fund except deduction on account of interest expense and such deduction of interest expenses shall not exceed 20 percent of the dividend income or income from units. For this purpose, a proviso is inserted in section 57(i).
As a result in respect of dividend and income from mutual fund units, only interest expenses and that too up to 20 percent of dividend income or income from mutual fund units can be claimed as a deduction. Any other expenses even though they are directly related to earn the dividend income cannot be claimed as a deduction. Hence, expenses like Demat charges, bank charges, advisory fees, etc. cannot be claimed expenses even though the dividend income is taxable.
Amendment of section 194
TDS from Dividend Income
Presently, no deduction of income-tax (TDS) is required for the dividend income which has suffered DDT under section 115-O. Since section 115-O is made inapplicable from 01-04-2020, hence section 194 is amended to cover any dividend income.
At present, section 194 prescribes for deduction of tax from dividend income subject to a threshold limit of Rs. 2,500 at the rates in force. Finance Bill, 2020 has proposed to amend the threshold limit to Rs. 5,000 and also prescribed the rate of TDS in the Income Tax Act itself at 10 percent. It is further proposed to amend the mode of payment provisions to payment of dividend in any mode viz., cash, cheque, warrants, etc.
The Finance Bill, 2020 has proposed to amend section 194 to include dividend for income-tax deduction.
Accordingly, an Indian company or a company which has made the prescribed arrangements for the declaration and payment of dividends (including dividends on preference shares) within India, shall, before making any payment by any mode in respect of any dividend or before making any distribution or payment to a shareholder, who is resident in India, of any dividend within the meaning of section 2(22)(a)/(b)/(c)/(d)/(e), deduct from the amount of such dividend, income-tax at the rate of 10 percent.
At the same time, the rate of 10 percent is proposed to be prescribed and the threshold is proposed to be increased from Rs 2,500/- to Rs 5,000/- for the dividend paid by any mode other than cash.
Further, at present, the mode of payment of dividend to any shareholder is given as “an account payee cheque or warrant”. It is proposed to change this to any mode.
Amendment of section 194K
TDS from Distributed Income from mutual fund units
Presently, under the existing provision, any amount of income distributed by a specified company or a Mutual Fund to its unitholders is subject to levy of additional income tax on such distributed income at the specified rate.
The Finance Bill, 2020 has proposed to amend section 115R so as to provide that the income distributed on or before the 31st day of March, 2020 shall only be covered under the provisions of section 115R.
Thus, in respect of income distributed on or after 1-4-2020, no such additional tax will be payable by the Mutual Fund and Specified Companies on the distributed income to the unitholders.
A simultaneous amendment has also been proposed in section 10(35) so as to provide that the provision of section 10(35) shall not apply to any income, in respect of units, received on or after 1st April, 2020.
Thus, now such income shall be taxable in the hands of the recipient.
In the line of TDS on dividend income, the Finance Bill, 2020 has proposed to deduction of income tax (TDS) on the income distributed to the unitholders by a mutual fund, etc.. For this purpose, a new section 194-K is introduced to provide that any person responsible for paying to a resident any income in respect of units of a Mutual Fund specified under clause (23D) of section 10 or units from the administrator of the specified undertaking or units from the specified company shall at the time of credit of such income to the account of the payee or at the time of payment thereof by any mode, whichever is earlier, deduct income-tax thereon at the rate of 10 percent.
It may also be provided for the threshold limit of Rs 5,000/- so that income below this amount does not suffer tax deduction.
It is also proposed to defined “Administrator”, “specified company”, as already defined in clause (35) of section 10. It is also proposed to define “specified undertaking” as in clause (i) of section 2 of the Unit Trust of India (Transfer of Undertaking and Repeal) Act, 2002.
It is also proposed to provide that where any income is credited to any account like suspense account, in the books of account of the person liable to pay such income, the liability for tax deduction under this section would arise at that time.
From the language of the amendment proposed by the Finance Bill, 2020 it appears that TDS under section 194K is applicable on income by way of dividend as well as capital gain arising on redemption of units.
However, the Board has now clarified that the intention of the legislature is not to tax capital gain income and tax will, therefore, be levied only on dividend income received by the Mutual Fund or Specified Company.
Thus, a suitable amendment will be made in the related provisions at the time of passing of the Bill.
Amendment of section 80M
Deduction in respect of inter-corporate dividend
The Finance Bill, 2020 has proposed to abolish the Dividend Distribution Tax (DDT) and re-introduced the classical system of taxing the dividend income in the hands of investors from 1st April, 2020.
In the case where the shareholder is a company then there may be a cascading effect of taxation on the dividend income since the company may, in turn, declare dividend to its shareholders. To mitigate the cascading effect of the tax on dividend, the Finance Bill, 2020 has proposed to insert new section 80M, as it existed before its removal by the Finance Act, 2003, to remove the cascading effect, with a change that set-off will be allowed only for dividend distributed by the company one month prior to the due date of filing of return, in place of due date of filing return earlier.
Section 80M was earlier removed by the Finance Act, 2003 after the introduction of DDT payable by the companies. It is now proposed to reintroduced by the Finance Bill, 2020.
Sub-section (1) of the new section 80M provides that where the gross total income of a domestic company in any previous year includes any income by way of dividends from any other domestic company, there shall, in accordance with and subject to the provisions of this section, be allowed in computing the total income of such domestic company, a deduction of an amount equal to so much of the amount of income by way of dividends received from such other domestic company as does not exceed the amount of dividend distributed by the first-mentioned domestic company on or before the due date.
Amendment of section 10(23D)
The provisions of Chapter XII-E [section 115R, section 115S, and section 115T] shall not apply to section 10(23D).
Section 10(23D) exempts income any income of a Mutual Fund registered under the Securities and Exchange Board of India Act, 1992 or set up by a public sector bank or a public financial institution or authorized by the Reserve Bank of India and subject to such other specified conditions.
Section 10(23D) exempts income any income of a Mutual Fund registered under the Securities and Exchange Board of India Act, 1992 or set up by a public sector bank or a public financial institution or authorized by the Reserve Bank of India and subject to such other specified conditions.
Amendment of section 10(23FC)
Section 10(23FC) deals with exemption of interest income from a special purpose vehicle and dividend income referred to in section 115-O(7) of a business trust.
As a consequence of the abolishment of section 115-O, the condition specified in section 10(23FC) related to section 115-O(7) is substituted with dividend income received or receivable from a special purpose vehicle by the Finance Bill, 2020. As a result, the dividend which will not suffer DDT from 1st April, 2020, shall also be exempt from tax from AY 2021-22.
According to section 115-O(7), no DDT is applicable on dividend income distributed to a business trust, if-
(i) dividend is declared, distributed and paid out of its current income, and
(ii) whole of the equity shares of the domestic company is held by the business trust.
Amendment of section 115A
Section 115A(1) prescribes for taxation on dividends, royalty, and technical service fees in the case of non-resident and foreign companies. Presently, section 115A(1)(a)(i) refers to dividends other than dividends referred to in section 115-O. It further provides income-tax shall be paid on the amount of income by way of dividends other than dividends referred to in section 115-O at the rate of 25 percent.
As a consequence of the abolishment of section 115-O, the Finance Bill, 2020 has removed the condition related dividends referred to in section 115-O and hence the dividend shall refer to any dividend income from AY 2021-22. Since the exemption under section 10(34) is also withdrawn, the dividend will become taxable under this section and all the provisions of the section shall apply to the dividend income.
Amendment of section 115AC
Section 115AC provides where the total income of a non-resident includes income by way of dividends, other than dividends referred to in section 115-O, on Global Depository Receipts, income-tax shall be paid on the amount of income by way of dividends other than dividends referred to in section 115-O at the rate of 10 percent.
It further provides that where the gross total income of the non-resident consists only of income by way of interest or dividends, other than dividends referred to in section 115-O in respect of specified bonds or Global Depository Receipts, then no deduction shall be allowed to him under sections 28 to 44C or section 57(i)/(iii) or under Chapter VI-A.
As a consequence of the abolishment of section 115-O, the Finance Bill, 2020 has removed the condition related dividends referred to in section 115-O and hence the dividend shall refer to any dividend income from AY 2021-22. Since the exemption under section 10(34) is also withdrawn, the dividend will become taxable under this section and all the provisions of the section shall apply to the dividend income.
Amendment of section 115ACA
Section 115ACA provides where the total income of a resident employee includes income by way of dividends, other than dividends referred to in section 115-O, on Global Depository Receipts of an Indian company engaged in specified knowledge-based industry or service and purchased by him in foreign currency, income-tax shall be paid on the amount of income by way of dividends other than dividends referred to in section 115-O at the rate of 10 percent.
It further provides that where the gross total income of the resident employee consists only of income by way of dividends, other than dividends referred to in section 115-O in respect of Global Depository Receipts, then no deduction shall be allowed to him under any provisions of the Income Tax Act.
As a consequence of the abolishment of section 115-O, the Finance Bill, 2020 has removed the condition related dividends referred to in section 115-O and hence the dividend shall refer to any dividend income from AY 2021-22. Since the exemption under section 10(34) is also withdrawn, the dividend will become taxable under this section and all the provisions of the section shall apply to the dividend income.
Amendment of section 115AD
Section 115AD provides where the total income of a Foreign Institutional Investor includes income by way of dividends, other than dividends referred to in section 115-O, from securities, income-tax shall be paid on the amount of income by way of dividends other than dividends referred to in section 115-O at the rate of 20 percent.
It further provides that where the gross total income of the Foreign Institutional Investor consists only of income by way of dividends, other than dividends referred to in section 115-O in respect of securities, then no deduction shall be allowed to him under any provisions of the Income Tax Act.
As a consequence of the abolishment of section 115-O, the Finance Bill, 2020 has removed the condition related dividends referred to in section 115-O and hence the dividend shall refer to any dividend income from AY 2021-22. Since the exemption under section 10(34) is also withdrawn, the dividend will become taxable under this section and all the provisions of the section shall apply to the dividend income.
Amendment of section 115BBDA
Section 115BBDA provides for taxation of dividends exceeding Rs. 10 Lakh in the hands of a specified shareholder who is a resident in India. The rate of tax is 10 percent.
As a consequence of the abolishment of section 115-O, the Finance Bill, 2020 has proposed to amend this section so as to restrict the applicability of the provisions of this section to dividend declared, distributed or paid by a domestic company or companies on or before the 31st day of March 2020.
Due to the withdrawal of the exemption under section 10(34), the entire dividend income shall be taxed at the applicable tax rates of the shareholder. From 01-04-2020, the shareholder shall not be eligible to enjoy the lower rate of tax of 10 percent on dividend income as well as the exemption limit of Rs. 10 Lakh.
Amendment of section 115C
Section 115C defines investment income means any income derived other than dividends referred to in section 115-O from a foreign exchange asset.
As a consequence of the abolishment of section 115-O, the Finance Bill, 2020 has removed the condition related dividends referred to in section 115-O and hence the investment income shall refer to any income derived from a foreign exchange asset from AY 2021-22.
Amendment of section 115UA
Section 115UA deals with tax on the income of a unitholder of a business trust and that of a business trust. Presently, only a business trust deriving interest income from a special purpose vehicle is covered.
As a consequence of the abolishment of section 115-O and section 10(23FC) by the Finance Bill, 2020, a business trust deriving interest as well as dividend income from a special purpose vehicle is covered under section 115UA.
Amendment of section 194LBA
Section 194LBA requires deduction of tax from the income distributed by a business trust to its resident unitholders at the prescribed rates.
As a consequence of the abolishment of section 115-O, the Finance Bill, 2020 has proposed to amend section 194LBA to provide for a tax deduction by the business trust on dividend income paid to unitholder, at the rate of 10 percent for resident unitholders. For non-resident unitholders, it would be 5 percent for interest and 10 percent for dividend.
Amendment of section 195
Section 195 requires deduction of tax from the income paid to non-residents. The second proviso to section 195 provides for no deduction of tax in respect of any dividends referred to in section 115-O paid to a non-resident.
As a consequence of the abolishment of section 115-O, the Finance Bill, 2020 has proposed to omit the second proviso.
The omission has lifted the restriction for non-deduction of TDS on dividend income which suffered DDT. As a result, any dividend payment to a non-resident on and after 01-04-2020 shall be subject to TDS under section 195.
Apart from the above-mentioned amendment, there is one more benefit/relief that assessees will get due to the abolishment of section 115-O and withdrawal of exemption from dividend income under section 10(34).
This is in respect of disallowances of expenses under section 14A for earning exempt income. Since dividend income is presently exempt, assessing officers were rampantly disallowing arbitrary expenses if the assessee has invested in shares of other companies irrespective of the fact whether any dividend income (exempt income) is earned or not. It has been a subject matter of intense litigation over the years. With the amendments, it appears there will be a substantial reduction in litigation for disallowances under section 14A. Though disallowance under section 14A still there if anyone earns any exempt income, say agricultural income, but practically it is very negligible.
Clause wise amendments
at a glance related to Dividend Income in the Finance Bill, 2020
|
Clause
|
Nature
|
Topic
|
Effective from
|
|
7
|
Amendment of section 10(23D)
|
Consequential
amendment subsequent to abolishment of DDT
|
AY
2021-22
|
|
7
|
Amendment of section 10(2FC)
|
Consequential
amendment subsequent to abolishment of DDT
|
AY
2021-22
|
|
7
|
Amendment of section 10(23FD)
|
Consequential
amendment subsequent to abolishment of DDT
|
AY
2021-22
|
|
7
|
Amendment of section 10(34)
|
Consequential
amendment subsequent to abolishment of DDT-Exemption withdrawn
|
AY
2021-22
|
|
7
|
Amendment of section 10(35)
|
Consequential
amendment subsequent to abolishment of DDT-Exemption withdrawn
|
AY
2021-22
|
|
30
|
Amendment of section 57
|
Consequential
abolishment of DDT, clause (I) to exclude the dividends referred to in
section 115-O.
|
AY 2021-22
|
|
A new
proviso is inserted in Clause(i) to disallow any deduction for dividend
income and income from mutual fund units except interest expenses which shall
be limited to 20% pf gross dividend income or income from mutual fund
units
|
AY 2021-22
|
||
|
40
|
Insertion of new section 80M
|
Deduction
in respect of certain inter-corporate dividends
|
AY 2021-22
|
|
47
|
Amendment of section
115A(1)
|
Consequent
to abolishment of DDT, the dividend income shall not include Dividend
referred to in section 115-O
|
AY 2021-22
|
|
48
|
Amendment of section
115AC
|
Consequent
to abolishment of DDT, the dividend income shall not include Dividend
referred to in section 115-O
|
AY 2021-22
|
|
49
|
Amendment of section
115ACA
|
Consequent
to abolishment of DDT, the dividend income shall not include Dividend
referred to in section 115-O
|
AY 2021-22
|
|
50
|
Amendment of section
115AD
|
Consequent
to abolishment of DDT, the dividend income shall not include Dividend
referred to in section 115-O
|
AY 2021-22
|
|
54
|
Amendment of section
115BBDA
|
Consequent
to abolishment of DDT, the dividend income shall not be liable to tax under
this section from 01.04.2020.
|
AY 2021-22
|
|
55
|
Amendment of section 115C
|
Consequent
to abolishment of DDT, the investment income shall include Dividend
income.
|
AY 2021-22
|
|
59
|
Amendment of section
115-O
|
The
provisions of DDT on dividend income by a domestic company shall be
applicable till 31.03.2020.
|
AY 2021-22
|
|
60
|
Amendment of section 115R
|
The
provisions of DDT on income distributed by a Mutual Fund shall be applicable
till 31.03.2020.
|
AY 2021-22
|
|
62
|
Amendment of section
115UA
|
Consequent
to abolishment of DDT, the dividend income shall be taxable in the hands of a
business trust
|
AY 2021-22
|
|
74
|
Amendment of section 194
|
Consequent
to abolishment of DDT, TDS on dividend prescribed
|
01.04.2020
|
|
80
|
Insertion of new section
194K
|
TDS on
income from mutual funds prescribed
|
01.04.2020
|
|
81
|
Amendment of section
194LBA
|
Consequent
to abolishment of DDT, TDS on dividend income is prescribed at 10%
|
01.04.2020
|
|
85
|
Amendment of section 195
|
Consequent
to abolishment of DDT, TDS on dividend is made applicable
|
01.04.2020
|
Conclusion:
Suggested Readings:
The amendment in section 115-O and section 115R is the central focus point of dividend taxation in the Budget 2020. All other amendments are consequential to the abolishment of the section 115-O and section 115R or dividend distribution tax or DDT.
Remember, section 115-O or DDT is applicable up to 31-03--2020 while dividend income is taxable in the hands of investors from 01-04-2020. Hence, if any company declares any dividend on 30th March 2020 it has to pay DDT. When the dividend will be paid by the company or the dividend will be received by the shareholder in April 2020, the recipient has to pay tax on the dividend income even though the same has suffered DDT. Since from 01-04-2020, any dividend income is taxable in the hands of the recipient due to withdrawal of exemption of DDT suffered dividends by section 10(34) from 01-04-2020, the dividend income received in April 2020 will be subject to tax in the hands of the recipient.
Suggested Readings:
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