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APAO Union Budget Proposal for Year 2016
a)
Clarificatory amendment
in Section 80 IA with regard
to Upgrading existing
infrastructure
APAO Union Budget Proposal for Year 2016- 17
Page 1 of 22
DIRECT TAX
Income tax
amendment
regard
Government has substituted present Section 80IA by
the Finance Act 1999 with effect from 1.4.2000 in lieu of
earlier Section 80 IA by the Finance Act 1991. The
purpose of substituting the section was to give a flip to
industrial undertakings and enterprises engaged in
infrastructure development such as airport
power and water supply etc.
Infrastructure development is pre requisite for the
growth and development of any country. Infrastructure
development is achievable in two ways i.e.to build
altogether new infrastructure or to convert the existing
structure by upgrading it for enhancing the existing
capacity. It goes without saying that whether it is new
infrastructure or an upgradation both entails huge
Capex investment and human efforts.
The fiscal benefit available to new infrastructure is
very much clear in the section in the present form.
However suitable clarity is required in the case of
upgrading the existing set up as to whether the section
extends to that as well.
Hence, it is requested that government make
suitable amendment in the section so as to make it
amply clear that the up-gradation of the existing
infrastructure be also eligible for the benefit of Sec
80IA, so that there is no ambiguity with regard to claim
of Sec 80 IA.
Government has substituted present Section 80IA by
Finance Act 1999 with effect from 1.4.2000 in lieu of
earlier Section 80 IA by the Finance Act 1991. The
purpose of substituting the section was to give a flip to
industrial undertakings and enterprises engaged in
infrastructure development such as airport, highways,
Infrastructure development is pre requisite for the
growth and development of any country. Infrastructure
in two ways i.e.to build
altogether new infrastructure or to convert the existing
enhancing the existing
capacity. It goes without saying that whether it is new
upgradation both entails huge
ment and human efforts.
The fiscal benefit available to new infrastructure is
very much clear in the section in the present form.
However suitable clarity is required in the case of
upgrading the existing set up as to whether the section
Hence, it is requested that government make
suitable amendment in the section so as to make it
gradation of the existing
eligible for the benefit of Sec
y with regard to claim
APAO Union Budget Proposal for Year 2016
b)
Support services
airport to be termed
infrastructure
c)
Conditions of section 80
regarding agreement with
statutory authority be given
a wider interpretation
APAO Union Budget Proposal for Year 2016- 17
Page 2 of 22
of
termed as
In the airport sector of infrastructure, there are
many ancillary/support services required which are
very essential for smooth functioning
example fuel facility, parking, cargo, ground handling
etc. One cannot even imagine any airport in absence
of these facilities as these are life line services for
airport. The industry needs support, assurance and
clarity on whether all the relevant functions& ancillary
functions/revenue streams which have nexus for
smooth functioning of the airport (
operator has directly performed these functions or by
a concessionaire (third party operator) who is granted
Service Provider Rights) because ultimately the
operator is responsible for smooth functioning of these
important functions at the airport.
In the absence of clear definition of Airport under
the present Sec of 80 IA, it leaves an ambiguity
whether these services enjoy benefit of Sec 80 IA or
not.
Hence it is requested that clarification & assurance
about eligibility of all relevant activities for tax holiday
under Section 801A of the Income Tax Act should be
extended to all support service as well.
Conditions of section 80-IA
regarding agreement with
statutory authority be given
Concession Agreements signed by the Airport Operator
with downstream Concessionaire providing Cargo/
Farm/ Ground Handling infrastructure & s
treated at par with the Agreement signed with
Government and accordingly benefit of 80IA should be
provided to the downstream concessionaire.
In the airport sector of infrastructure, there are
many ancillary/support services required which are
very essential for smooth functioning of airports. For
example fuel facility, parking, cargo, ground handling
etc. One cannot even imagine any airport in absence
ife line services for
he industry needs support, assurance and
e relevant functions& ancillary
functions/revenue streams which have nexus for
whether the airport
operator has directly performed these functions or by
a concessionaire (third party operator) who is granted
because ultimately the
operator is responsible for smooth functioning of these
In the absence of clear definition of Airport under
the present Sec of 80 IA, it leaves an ambiguity
ces enjoy benefit of Sec 80 IA or
Hence it is requested that clarification & assurance
about eligibility of all relevant activities for tax holiday
under Section 801A of the Income Tax Act should be
extended to all support service as well.
Concession Agreements signed by the Airport Operator
with downstream Concessionaire providing Cargo/ Fuel
Ground Handling infrastructure & services to be
treated at par with the Agreement signed with
and accordingly benefit of 80IA should be
provided to the downstream concessionaire.
APAO Union Budget Proposal for Year 2016
d)
Minimum Alternate Tax
115JB
e)
Tax free bonds u/s 80CCF
APAO Union Budget Proposal for Year 2016- 17
Page 3 of 22
u/s
The government has introduced the concept of MAT
on all the companies. Infrastructure companies have
long gestation period as they are highly capital
intensive.
Hence it is requested that MAT should not be
applicable on such infrastructure companies
Alternatively, if outright exemption is not
infrastructure projects like airport should at the least
have concessional MAT rate of 5% of book profits
instead of merit rate of 21.34%.
80CCF
In the Finance Act 2012, the deduction under
section 80 CCF has been done away with. Previously
in budget 2011, various government undertakings were
allowed to issue tax free bonds of 30,000 crores in year
2012 to give boost to infrastructure development in
railways, power, housing and highways development.
It is recommended that the deduction should be
restored.
Further the scope of infrastructure should be
expanded to cover Airport also. In addition to existing
issuers, private infrastructure companies should also be
allowed to issue such tax free bonds for various
infrastructure activities. Allowing such benefit
enable them to source money from cost effective
funds as already these companies are under the grip
of mounting debt at high costs. There could be a
question on protection of investor
would be unsecured loans of private infrastructu
companies. To mitigate this risk, the government may
propose minimum credit rating to be eligible to issue
such bonds or any other condition which the
government may deem fit for issuance of such bonds.
The government has introduced the concept of MAT
all the companies. Infrastructure companies have
long gestation period as they are highly capital
Hence it is requested that MAT should not be
applicable on such infrastructure companies.
Alternatively, if outright exemption is not granted,
projects like airport should at the least
have concessional MAT rate of 5% of book profits
Finance Act 2012, the deduction under
has been done away with. Previously
in budget 2011, various government undertakings were
allowed to issue tax free bonds of 30,000 crores in year
2012 to give boost to infrastructure development in
railways, power, housing and highways development.
ecommended that the deduction should be
Further the scope of infrastructure should be
expanded to cover Airport also. In addition to existing
issuers, private infrastructure companies should also be
allowed to issue such tax free bonds for various
infrastructure activities. Allowing such benefit would
enable them to source money from cost effective
funds as already these companies are under the grip
of mounting debt at high costs. There could be a
investor’s money as these
would be unsecured loans of private infrastructure
companies. To mitigate this risk, the government may
propose minimum credit rating to be eligible to issue
such bonds or any other condition which the
government may deem fit for issuance of such bonds.
APAO Union Budget Proposal for Year 2016
f)
Reintroduction of Section
10 (23G)
APAO Union Budget Proposal for Year 2016- 17
Page 4 of 22
Tax deduction under section 80 CCF
in infrastructure bonds should be made applicable for
all years and should not be renewed on a year
basis by the Finance Act each year. Also, the
investment limit and the deduction allowable should
be increased from Rs. 20,000 to Rs.
individuals / HUE.
While the infrastructure sector needs a boost,
individual investors also look at being eligible to claim
tax deductions made in infrastructure sector. These
should be promoted to allow benefits to the
infrastructure sector as also to the investors and which
eventually lead to overall development and growth of
the economy. This will also attract larger household
savings to the infrastructure sector.
Section
Section 10(23G) was omitted by Finance Act 2006, with
effect from 1.4.2007.This section was enacted to
exempt income by way of dividends other than
dividend referred to in Sec 115 O, interest or long term
capital gains of an infrastructural capital funds o
infrastructural capital company etc. by way of shares
or long term finance in any enterprise or undertaking
engaged in the business referred to in sub section 4 of
sec 80IA or Sub Sec 3 of Sec80IAB or housing project
referred to in sub section 10 of 80IB or a hotel project or
a hospital project duly approved by the central
government. However this will be subject to payment
of MAT. This section was very encouraging for the
investor as it gives incentive to invest the money in
infrastructure projects. It is recommended that this
section be restored back and the income of
Infrastructure Company should also be exempted from
payment of MAT.
Tax deduction under section 80 CCF for investment
in infrastructure bonds should be made applicable for
all years and should not be renewed on a year-to-year
basis by the Finance Act each year. Also, the
investment limit and the deduction allowable should
be increased from Rs. 20,000 to Rs. 50,000 for
While the infrastructure sector needs a boost,
individual investors also look at being eligible to claim
tax deductions made in infrastructure sector. These
should be promoted to allow benefits to the
infrastructure sector as also to the investors and which
eventually lead to overall development and growth of
the economy. This will also attract larger household
Section 10(23G) was omitted by Finance Act 2006, with
effect from 1.4.2007.This section was enacted to
ividends other than
dividend referred to in Sec 115 O, interest or long term
capital gains of an infrastructural capital funds or an
infrastructural capital company etc. by way of shares
or long term finance in any enterprise or undertaking
engaged in the business referred to in sub section 4 of
sec 80IA or Sub Sec 3 of Sec80IAB or housing project
0IB or a hotel project or
a hospital project duly approved by the central
government. However this will be subject to payment
of MAT. This section was very encouraging for the
investor as it gives incentive to invest the money in
t is recommended that this
section be restored back and the income of
Infrastructure Company should also be exempted from
APAO Union Budget Proposal for Year 2016
g)
Exemption from levy of
Income tax under Section
10 AA for service rendered
to Domestic Airlines
Operator and consider
that as an export.
h)
Allowing companies to
issue Infrastructure Bonds
bonds
Issued by infrastructure
companies should also
qualified under section
54EC of the Act
i)
No applicability of
without PAN – section
206AA
APAO Union Budget Proposal for Year 2016- 17
Page 5 of 22
Exemption from levy of
Income tax under Section
10 AA for service rendered
to Domestic Airlines
consider
Currently out of approx 400 civil A
majority of them fly to the Middle E
and European countries for availing mandatory MRO
services and pay out in valuable foreign currency
or Pound or Euro). This results in huge foreign exchange
outflow from the Indian economy. By
these domestic airline customer to avail MRO services
here at India the country will be saving precious
foreign exchange every year besides also
of earning valuable foreign currency from various
international airline customers. This
foreign currency from flowing out of the country
indirectly tantamount to export of services and hence
the same needs to be exempted f
under Section 10AA of the Income Tax Act.
to
Bonds-
infrastructure
also be
section
With a view to accelerate the growth in
sector, which is very vital for the economic
development of the country, bonds issued by
infrastructure companies should also be qualified
under section 54EC of the Act. Presently bonds issued
by few organizations like NHAI and REC only are
qualified under section 54EC of the Act for making
investment so as to claim exemption from capital
gains.
TDS
section
It is recommended that a clause should be
inserted to provide that the requirement of PAN would
not be applicable to non-residents in respect of
specified cases.
A new section 206AA was introduced in the
Finance Act, 2009, under which a penal rate of TDS
has been made applicable with effect from 1.4.2010
@20% or higher rate if prescribed, in cases where PAN
is not available.
civil Aircrafts in India,
East and other Asian
and European countries for availing mandatory MRO
services and pay out in valuable foreign currency (USD
in huge foreign exchange
outflow from the Indian economy. By enabling all
to avail MRO services
here at India the country will be saving precious
foreign exchange every year besides also the potential
earning valuable foreign currency from various
This saving of valuable
out of the country
to export of services and hence
the same needs to be exempted from income tax
under Section 10AA of the Income Tax Act.
With a view to accelerate the growth in infrastructure
sector, which is very vital for the economic
development of the country, bonds issued by
infrastructure companies should also be qualified
under section 54EC of the Act. Presently bonds issued
by few organizations like NHAI and REC only are
qualified under section 54EC of the Act for making
investment so as to claim exemption from capital
It is recommended that a clause should be
the requirement of PAN would
residents in respect of
A new section 206AA was introduced in the
Finance Act, 2009, under which a penal rate of TDS
has been made applicable with effect from 1.4.2010
higher rate if prescribed, in cases where PAN
APAO Union Budget Proposal for Year 2016
j)
Disallowance of
expenditure incurred in
relation to income not
includible in total income
u/s 14A of the Act
APAO Union Budget Proposal for Year 2016- 17
Page 6 of 22
Disallowance of
expenditure incurred in
relation to income not
includible in total income
As per the existing provisions of section 14A of
the Act, no deduction shall be allowed in respect of
expenditure incurred by a taxpayer in relation to
income which does not form part of total income
under the Act. Further, section 14A of the Act states
that the provisions of this section shall also apply in
cases where an assessee claims that no expenditure
has been incurred by him in relation to income which
does not form part of the total income under the Act.
In this regard, a method has been prescribed under
rule 8D of the Income Tax Rules, to calculate the
amount of disallowance for the purpose of section 14A
of the Act. Rule 8D has created genuine hardships for
taxpayers, as the calculations basis under rule 8D is
arbitrary. In many cases, disallowance calculated as
per rule 8D method exceeds the amount of tota
exempted income earned during the year. This is
because of:
• Firstly, the interest expense, which does not form
part of exempted income, is disallowed.
• Secondly, while working out the half percentage
of the average investments, all the investments in
shares/ mutual funds are considered.
• Thirdly, this income does not demarcate
between investments that have generated or
not generated income during the year.
• Lastly, no distinction has been made for
companies earning dividend income due to
holding strategic investments in group
companies and very little expenditure is
attributable to earn such dividend income.
It is suggested that:
• Only those expenses which are directly related to
earnings of exempt income should be
disallowed.
• Further, the overall maximum limit of expenses to
As per the existing provisions of section 14A of
deduction shall be allowed in respect of
expenditure incurred by a taxpayer in relation to
income which does not form part of total income
under the Act. Further, section 14A of the Act states
that the provisions of this section shall also apply in
here an assessee claims that no expenditure
has been incurred by him in relation to income which
does not form part of the total income under the Act.
In this regard, a method has been prescribed under
rule 8D of the Income Tax Rules, to calculate the
nt of disallowance for the purpose of section 14A
of the Act. Rule 8D has created genuine hardships for
taxpayers, as the calculations basis under rule 8D is
arbitrary. In many cases, disallowance calculated as
per rule 8D method exceeds the amount of total
exempted income earned during the year. This is
Firstly, the interest expense, which does not form
part of exempted income, is disallowed.
Secondly, while working out the half percentage
of the average investments, all the investments in
res/ mutual funds are considered.
Thirdly, this income does not demarcate
between investments that have generated or
not generated income during the year.
Lastly, no distinction has been made for
companies earning dividend income due to
nvestments in group
companies and very little expenditure is
attributable to earn such dividend income.
Only those expenses which are directly related to
earnings of exempt income should be
Further, the overall maximum limit of expenses to
APAO Union Budget Proposal for Year 2016
k)
Amalgamation
l)
Abolition of MAT and DDT
(Dividend Distribution Tax)
on SEZ units
APAO Union Budget Proposal for Year 2016- 17
Page 7 of 22
be disallowed should not exceed the tax
payable on exempted income earned.
Overall maximum limit of expense to be disallowed in
case of dividend income earned from holding
strategic investment in group comp
capped.
i. Section 72A of the Act, which deals with
treatment of unabsorbed losses and unabsorbed
depreciation, in case of amalgamation, is
restrictive in its application. Presently benefits of
section 72A are available only to company
owning industrial undertaking o
or a banking company. Due to this restriction,
other sectors are not eligible for benefits in the
form of loss from one company to another.
It is suggested that sectorial restrictions u/s 72A
may be removed and provisions of this
made applicable for all the sectors.
ii. Presently MAT u/s 115JAA cannot be carried
forward by the amalgamated company.
The Income Tax Act needs to be amended so as to
allow carry forward of MAT credit in the hands of
amalgamated company for the re
years.
Abolition of MAT and DDT
(Dividend Distribution Tax)
Finance Act 2011 has levied MAT and DDT on SEZ
units. Already SEZ units are being surrendered owing to
procedural wrangles and SEZ developers are
notifying the same. This levy is a further blow for SEZ.
Consequently, it should be abolished.
be disallowed should not exceed the tax
payable on exempted income earned.
Overall maximum limit of expense to be disallowed in
case of dividend income earned from holding
strategic investment in group companies should be
Section 72A of the Act, which deals with
treatment of unabsorbed losses and unabsorbed
depreciation, in case of amalgamation, is
restrictive in its application. Presently benefits of
section 72A are available only to company
owning industrial undertaking or a ship or a hotel
or a banking company. Due to this restriction,
are not eligible for benefits in the
form of loss from one company to another.
It is suggested that sectorial restrictions u/s 72A
may be removed and provisions of this section be
made applicable for all the sectors.
Presently MAT u/s 115JAA cannot be carried
forward by the amalgamated company.
The Income Tax Act needs to be amended so as to
allow carry forward of MAT credit in the hands of
amalgamated company for the remaining number of
Finance Act 2011 has levied MAT and DDT on SEZ
units. Already SEZ units are being surrendered owing to
procedural wrangles and SEZ developers are de-
notifying the same. This levy is a further blow for SEZ.
Consequently, it should be abolished.
APAO Union Budget Proposal for Year 2016
m) Lowering of Income Tax
rate as promised under
Income Tax Act, 1961 to be
implemented.
n) Simplification of rules and
procedure for obtaining
Concessional TDS
Certificate for deduction of
tax on income under Sec
197 of the Income Tax Act.
APAO Union Budget Proposal for Year 2016- 17
Page 8 of 22
owering of Income Tax
e as promised under
Income Tax Act, 1961 to be
In Budget 2015, the Finance minister has committed
lowering of basic rate of corporate tax to 25 per cent
from 30 per cent in four years which needs to be
implemented right from the Financial Year 2016
onwards with a view to provide some liquidity in the
hands of Indian Corporate to invest the surplus funds
towards expansion of the industry.
Simplification of rules and
procedure for obtaining
Certificate for deduction of
tax on income under Sec
197 of the Income Tax Act.
As per the current provisions, we need to provide
data of customer-wise break-up of each revenue
stream while applying for Nil / Concessional TDS on
income under Sec 197 of the Income Tax Act.
Since, the sector is covered under tax holiday U/Sec
80IA and most of us are paying only MAT tax. Under
the circumstances, TDS at merit rate on our revenues
will invariably result in huge refund claims.
Since the sector is very capital intensive, block
working capital in the form of Refund of TDS on
income for almost 2 years is a severe financial
hardship.
Further, since the nature of income is dynamic and
dependent on the choice of passengers of preferring
airlines, estimation of aviation income
level (airlines) for UDF/ PSF and other income pose a
genuine practical difficulty.
Hence, we seek special provisions to our sector
(Similar to provisions for Non-residents) so that we can
provide only revenue-wise break down thereby
relaxing customer-wise break down. Currently,
certain certificates are underutilised and certain
others have surpassed the estimated threshold.
Relaxation of customer-wise break up will be very
beneficial in eliminating situation of blocking of
working capital in the form of excess TDS over tax
liability.
In Budget 2015, the Finance minister has committed
basic rate of corporate tax to 25 per cent
from 30 per cent in four years which needs to be
implemented right from the Financial Year 2016-17
onwards with a view to provide some liquidity in the
hands of Indian Corporate to invest the surplus funds
As per the current provisions, we need to provide
up of each revenue
stream while applying for Nil / Concessional TDS on
income under Sec 197 of the Income Tax Act.
Since, the sector is covered under tax holiday U/Sec
80IA and most of us are paying only MAT tax. Under
the circumstances, TDS at merit rate on our revenues
will invariably result in huge refund claims.
Since the sector is very capital intensive, blocking of
working capital in the form of Refund of TDS on
income for almost 2 years is a severe financial
Further, since the nature of income is dynamic and
dependent on the choice of passengers of preferring
airlines, estimation of aviation income at customer-
level (airlines) for UDF/ PSF and other income pose a
Hence, we seek special provisions to our sector
residents) so that we can
wise break down thereby
wise break down. Currently,
certain certificates are underutilised and certain
others have surpassed the estimated threshold.
wise break up will be very
beneficial in eliminating situation of blocking of
the form of excess TDS over tax
APAO Union Budget Proposal for Year 2016
a)
Allowance of bad debts in
service tax
b)
Exemption from service tax on
supply of water and electricity
within an airport
APAO Union Budget Proposal for Year 2016- 17
Page 9 of 22
INDIRECT TAX
Service Tax
in
Finance Act 2011 introduced Point of Taxation
Rules 2011 that makes it mandatory for service
provider to pay the service
invoicing or payment received, whichever is earlier.
Further if invoice is not raised within 30 days from the
date of completion of service, then point of taxation
will be the date of completion of service.
Many times service providers are not able to
collect the amount from the recipient including the
service tax which requires to be written off as bad
debt.
CBEC vide para 11 (ii) of Circular No 341/34/2010
dated 31-03-2011 states that adjustment of service tax
paid on bad debts are not available while
discharging service tax on output service.
CBEC should make amendment in law and
other regulations made thereunder so as to provide
relief to service provider in case of bad debts through
adjustment or refund.
Exemption from service tax on
electricity
In the erstwhile provisions of service tax there was
an exemption from levy of service tax on services by
way of supply of water and electricity when provided
within an airport vide notification no. 31/2010 dt 22
Jun-10. However similar exemption is not available in
the newly introduced negative list approach of
taxing the services.
It is requested to kindly provide similar exemption
from levy of service tax in the negative list approach
of taxing the services by way of supply of water and
Electricity within an Airport.
Finance Act 2011 introduced Point of Taxation
Rules 2011 that makes it mandatory for service
provider to pay the service tax at the time of
invoicing or payment received, whichever is earlier.
Further if invoice is not raised within 30 days from the
date of completion of service, then point of taxation
will be the date of completion of service.
oviders are not able to
collect the amount from the recipient including the
service tax which requires to be written off as bad
CBEC vide para 11 (ii) of Circular No 341/34/2010
2011 states that adjustment of service tax
ad debts are not available while
discharging service tax on output service.
CBEC should make amendment in law and
other regulations made thereunder so as to provide
relief to service provider in case of bad debts through
In the erstwhile provisions of service tax there was
an exemption from levy of service tax on services by
way of supply of water and electricity when provided
within an airport vide notification no. 31/2010 dt 22-
10. However similar exemption is not available in
the newly introduced negative list approach of
It is requested to kindly provide similar exemption
tax in the negative list approach
of taxing the services by way of supply of water and
APAO Union Budget Proposal for Year 2016
c)
MRO Services to be
exempted from Service Tax
inclusion in negative list
d)
Airport Development Fee
Exempted from Service Tax
APAO Union Budget Proposal for Year 2016- 17
Page 10 of 22
be
Tax by
Maintenance Repairs and
services is crucial and mandatory for the smooth
running and upkeep of aircrafts.
Besides the small exemption available today, it is
desirable to exempt the MRO services as a whole
from imposition of service tax in order to promote
industry in India. MRO services needs to be included
in the negative list of services which are not taxable.
MRO Business has a huge potential to attract foreign
investments and earn precious foreign exchange
and at same time save outflow of foreign ex
from India and for promoting the upcoming MRO
business which has just begun to grow in
MRO services require high level engineering and
technical set up and advanced IT systems which are
available in India. This has the potential of bei
developed as a hub for international airline
customers and earn valuable foreign currency This
saving of valuable foreign currency from flowing out
of the country indirectly tantamounts to export of
services and hence the same needs to be exempted
from income tax under Section 10AA of the Income
Tax Act.
Fee to be
Tax
Since Development fee is tax or cess in nature which
is an important source of funding for specified
purposes as enlisted under the terms of section 22A
of the Airport Authority of India, 1994 (also held by
the Hon’ble Supreme Court in case of
Online Forum vs UOI ) and therefore levy of tax on tax
is unjustified, which should be clarified by way of a
suitable clarification.
Maintenance Repairs and Operations(MRO)
services is crucial and mandatory for the smooth
running and upkeep of aircrafts.
Besides the small exemption available today, it is
desirable to exempt the MRO services as a whole
from imposition of service tax in order to promote the
industry in India. MRO services needs to be included
in the negative list of services which are not taxable.
MRO Business has a huge potential to attract foreign
investments and earn precious foreign exchange
and at same time save outflow of foreign exchange
from India and for promoting the upcoming MRO
business which has just begun to grow in India.
MRO services require high level engineering and
technical set up and advanced IT systems which are
available in India. This has the potential of being
developed as a hub for international airline
customers and earn valuable foreign currency This
saving of valuable foreign currency from flowing out
of the country indirectly tantamounts to export of
services and hence the same needs to be exempted
income tax under Section 10AA of the Income
tax or cess in nature which
is an important source of funding for specified
purposes as enlisted under the terms of section 22A
of the Airport Authority of India, 1994 (also held by
the Hon’ble Supreme Court in case of Consumer
erefore levy of tax on tax
is unjustified, which should be clarified by way of a
APAO Union Budget Proposal for Year 2016
e)
Taxability of Service portion & VAT
in execution of Annual
Maintenance Contract (AMC
f)
The government has
withdrawn service tax
exemption provided to
construction of Greenfield
airports. This exemption needs
to be restored
g)
Show cause notice needs to be
mandatorily served while
enforcing recovery of service
tax dues of the Assessee
including from any other third
party from whom money is due
or may become due.
h)
Exemption from levy of service
tax for services rendered from
the SEZ unit
APAO Union Budget Proposal for Year 2016- 17
Page 11 of 22
Taxability of Service portion & VAT
in execution of Annual
Contract (AMC).
The total exemption from Service tax may be
required on such transactions (AMC / CMC at the
airport) as these are also works contract services
though, they are not in the nature of original works.
It is recommended that notification No. 24/2012
Service Tax should be amended to state if VAT is p
on the goods component (even on value after
availing deemed labour deduction),
should be payable only on the balance amount.
The government has
service tax
exemption provided to
reenfield
exemption needs
This will make construction of new airports
more expensive.
Exemption should be made available to
encourage infrastructure development by private
entities. This exemption needs to be restored.
cause notice needs to be
mandatorily served while
enforcing recovery of service
tax dues of the Assessee
including from any other third
party from whom money is due
Partial or whole service tax shall be recovered
along with interest thereon in any of the modes
specified in section 87, without service of notice
under subsection (1).
Existing provisions requires serving of a show cause
notice to the assessee wherein he
chance to explain as to why the tax has not been
paid by him.
Exemption from levy of service
tax for services rendered from
Section 26(e) grants exemption to units in DTA
from service tax under Chapter V of the
Act, 1994 on taxable services provided to a
developer or unit to carry on the authorized
operations in a SEZ.
There is no specific provision in SEZ Act for
exemption from levy of service tax for services
The total exemption from Service tax may be
required on such transactions (AMC / CMC at the
airport) as these are also works contract services
though, they are not in the nature of original works.
It is recommended that notification No. 24/2012-
Service Tax should be amended to state if VAT is paid
on the goods component (even on value after
availing deemed labour deduction), service tax
balance amount.
This will make construction of new airports
Exemption should be made available to
encourage infrastructure development by private
This exemption needs to be restored.
Partial or whole service tax shall be recovered
along with interest thereon in any of the modes
without service of notice
Existing provisions requires serving of a show cause
wherein he is given a
chance to explain as to why the tax has not been
Section 26(e) grants exemption to units in DTA
from service tax under Chapter V of the Finance
Act, 1994 on taxable services provided to a
developer or unit to carry on the authorized
There is no specific provision in SEZ Act for
exemption from levy of service tax for services
APAO Union Budget Proposal for Year 2016
i)
Interest for delayed payment
of Service Tax to be relaxed.
APAO Union Budget Proposal for Year 2016- 17
Page 12 of 22
rendered by an SEZ unit to an Unit i
Area (DTA). Whereas Section 26 of the SEZ Act lists
the various exemption, drawbacks and concessions
to the entities in the SEZ. Section 26(e) grants
exemption to units in DTA from service tax under
Chapter V of the Finance Act, 1994 on t
services provided to a developer or unit to carry on
the authorized operations in a SEZ. If Section 26
exempts DTA service providers rendering service to
Developer/Unit, there is all the more reasons for
exemption from service tax to service provide
located within SEZ rendering service wholly within or
from SEZ. Else the basic purpose of establishing the
SEZ unit will be defeated.
nterest for delayed payment
to be relaxed.
Vide Notification No 12/2014
rate of interest to be charged on delayed
payment of service tax has been enhanced w.e.f.
1.10.2014, with reference to the period of delay.
Thus, longer the delay period, higher would be the
rate of interest payable (Maximum @30%).
However it may be noted that instances where
payment of service tax was delayed due to
genuine reasons/ difficulty in relation to
interpretation of statues/facts are involved,
to any reason such as non-receipt thereof from
the service recipients such as Government
the above notification tends to be extremely harsh
and against natural justice.
rendered by an SEZ unit to an Unit in Domestic Tariff
Area (DTA). Whereas Section 26 of the SEZ Act lists
the various exemption, drawbacks and concessions
to the entities in the SEZ. Section 26(e) grants
exemption to units in DTA from service tax under
Chapter V of the Finance Act, 1994 on taxable
services provided to a developer or unit to carry on
the authorized operations in a SEZ. If Section 26
exempts DTA service providers rendering service to
Developer/Unit, there is all the more reasons for
exemption from service tax to service provider
located within SEZ rendering service wholly within or
from SEZ. Else the basic purpose of establishing the
Notification No 12/2014-ST dated 11.7.2014,
rate of interest to be charged on delayed
payment of service tax has been enhanced w.e.f.
1.10.2014, with reference to the period of delay.
Thus, longer the delay period, higher would be the
rate of interest payable (Maximum @30%).
noted that instances where
payment of service tax was delayed due to
genuine reasons/ difficulty in relation to
interpretation of statues/facts are involved, or due
receipt thereof from
the service recipients such as Government Parties,
the above notification tends to be extremely harsh
APAO Union Budget Proposal for Year 2016
j)
Increase the Threshold limits
under Service Tax Law to
be enhanced to 25 Lakhs.
k)
Cenvat credit in relation to
construction activities for
original works in building
airport assets and also
estate, hotel and associated
infrastructure activities to be
restored to Airports.
APAO Union Budget Proposal for Year 2016- 17
Page 13 of 22
ncrease the Threshold limits
under Service Tax Law to
be enhanced to 25 Lakhs.
Currently the threshold limit of Rs 10 lacs under
service tax law seems to be very low which
involves cumbersome compliance issue there
under. Further, the liability of service recipient
arises under Reverse charge mechanism even in a
case where the service provider doesn’t have to
pay tax since his income within the threshol
as noted above. The said limit has to be
enhanced to a minimum of Rs 25 lacs to synch
with the implementation of GST law and remove
the lacunae indicated above.
envat credit in relation to
construction activities for
original works in building
airport assets and also real
associated
to be
The Central Government had extended support
to construction and expansion of Infrastructures
including that of Airport by specifically allowing
CENVAT Credit of construction and works contract
services performed at Airport Sector by giving
exception to exclusion part given in input service
definition under Rule 2(I) of CENVAT Rules till July
01,2012. However, upon introduction of Negative
List Regime the classification of taxable services
became redundant, the exemption granted to
specified services including that of Airport service
(zzm) of clause (105) of section 65 of the Finance
Act, 1994 was withdrawn prompting unavailability
of CENVAT credit from input services.
However, the original works such as (a) all new
constructions; (b) all types of a
alterations to abandoned or damaged structures
on land that are required to make them workable;
(c) erection , commissioning or installation of plant
and machinery or equipments are structures,
whether prefabricated or otherwise was exempted
vide ST No.-25/2012 dated 20.06.2012. Hence
change in input service definition had no major
Currently the threshold limit of Rs 10 lacs under
to be very low which
involves cumbersome compliance issue there
under. Further, the liability of service recipient
arises under Reverse charge mechanism even in a
case where the service provider doesn’t have to
pay tax since his income within the threshold limit
as noted above. The said limit has to be
enhanced to a minimum of Rs 25 lacs to synch
with the implementation of GST law and remove
the lacunae indicated above.
The Central Government had extended support
to construction and expansion of Infrastructures
including that of Airport by specifically allowing
CENVAT Credit of construction and works contract
services performed at Airport Sector by giving
clusion part given in input service
definition under Rule 2(I) of CENVAT Rules till July
01,2012. However, upon introduction of Negative
List Regime the classification of taxable services
became redundant, the exemption granted to
ing that of Airport service
(zzm) of clause (105) of section 65 of the Finance
Act, 1994 was withdrawn prompting unavailability
of CENVAT credit from input services.
However, the original works such as (a) all new
constructions; (b) all types of addition and
alterations to abandoned or damaged structures
on land that are required to make them workable;
(c) erection , commissioning or installation of plant
and machinery or equipments are structures,
whether prefabricated or otherwise was exempted
25/2012 dated 20.06.2012. Hence
change in input service definition had no major
APAO Union Budget Proposal for Year 2016
APAO Union Budget Proposal for Year 2016- 17
Page 14 of 22
impact for Airport sector at that time.
But aforesaid exemption granted under Serial No
14 stands withdrawn vide Notification No 06/2015 ST
dated March 01, 2015 effective from April 01, 2015
onwards affecting the development of Airport
infrastructures assets which is very important for
growth of the economy.
In this regard, APAO has already made a specific
representation in May 2015 before the Honourable
Finance Minister vide letter No. APAO/ MoF/2015
dated 22nd May 2015 (Refer Annexure
a relief of :
a. either total restoration of exemption from
service tax carried out at Airports
or
b. admissibility of CENVAT credit of the Service Tax paid for
all services relating to construction and works contract in
Airport
We, therefore, earnestly request that CENVAT
credits arising out of inputs and input services be
granted to construction of Airport assets,
Also, the associated infrastructure
Real Estate Sectors require the same relief from levy
of service tax or eligibility for total input credit so
that the cost of development of overall airport
infrastructure does not go up and maintain the
character of thrust sector
We, therefore, earnestly request that CENVAT
credits arising out of inputs and input services be
granted to construction of Airport assets, Hotels and
Real Estate Sectors despite specific restoration of
the erstwhile Exemption granted to Airport assets.
impact for Airport sector at that time.
said exemption granted under Serial No
14 stands withdrawn vide Notification No 06/2015 ST
15 effective from April 01, 2015
onwards affecting the development of Airport
infrastructures assets which is very important for
already made a specific
before the Honourable
ance Minister vide letter No. APAO/ MoF/2015-16
Refer Annexure - II ) seeking
either total restoration of exemption from
service tax carried out at Airports
admissibility of CENVAT credit of the Service Tax paid for
all services relating to construction and works contract in
We, therefore, earnestly request that CENVAT
credits arising out of inputs and input services be
o construction of Airport assets,
Also, the associated infrastructure like Hotels and
Real Estate Sectors require the same relief from levy
for total input credit so
that the cost of development of overall airport
infrastructure does not go up and maintain the
equest that CENVAT
arising out of inputs and input services be
ted to construction of Airport assets, Hotels and
Real Estate Sectors despite specific restoration of
the erstwhile Exemption granted to Airport assets.
APAO Union Budget Proposal for Year 2016
l)
Utilization of education cesses
paid should be allowed for
adjustment against Service Tax
post June 2015. Notification to
this effect need to be issued.
m)
Exemption from service tax on
services rendered by CISF to
airports
APAO Union Budget Proposal for Year 2016- 17
Page 15 of 22
Utilization of education cesses
paid should be allowed for
adjustment against Service Tax
. Notification to
this effect need to be issued.
The rate of Service tax has been increased
from 12.36% to flat 14% effective from June 1, 2015.
However, the existing balance of Education
Cesses paid were not available as set
basic service tax liability since there were no
Education cess liability arises post June 01,2015.
After these changes there is no clarity so far
issued by the Department about the unutilized
balance of Education cess and Higher education
cess as to whether the cess would be lapsed or
can be adjusted in the major
service tax liability.
However, the CBEC vide
12/2015-Central Excise (N.T.) dated April 30,
has amended the Cenvat Credit Rules, 2004 to
allow use of Credit of Education Cess (EC) and
Secondary and Higher Education Cess (SHEC)
paid on inputs or capital goods received in the
factory of manufacture of final product can be
utilized for payment of Excise Duty. We therefore
request that similar notification be issued for
service provider also.
Exemption from service tax on
services rendered by CISF to
Presently service tax is charged on services
provided by CISF to airports, which is resulting into
increase in cost to the aviation industry. Full
exemption of service tax on all services rendered
by CISF at the airports should be provided by
including the same in the negative list.
*********
The rate of Service tax has been increased
from 12.36% to flat 14% effective from June 1, 2015.
However, the existing balance of Education
Cesses paid were not available as set-off against
basic service tax liability since there were no
bility arises post June 01,2015.
After these changes there is no clarity so far
issued by the Department about the unutilized
balance of Education cess and Higher education
cess as to whether the cess would be lapsed or
can be adjusted in the major head of Basic
However, the CBEC vide Notification No.
Central Excise (N.T.) dated April 30, 2015
has amended the Cenvat Credit Rules, 2004 to
allow use of Credit of Education Cess (EC) and
Secondary and Higher Education Cess (SHEC)
paid on inputs or capital goods received in the
factory of manufacture of final product can be
of Excise Duty. We therefore
request that similar notification be issued for
Presently service tax is charged on services
which is resulting into
increase in cost to the aviation industry. Full
exemption of service tax on all services rendered
by CISF at the airports should be provided by
including the same in the negative list.
APAO Union Budget Proposal for Year 2016
a)
Concessional Customs Duty
Goods required for
development of Airports
Clarification under Project
Imports to allow benefit of
Project Import to all items
required for Airport
Development Projects.
Due to peak tariff rate of
custom duty, goods for Airport
development are imported at
higher rate which resulting
higher project cost. We request
that goods imported for
development of Airports should
be eligible for basis
concessional custom duty @ 5%.
b)
Exemption from Custom Duty
X-ray baggage inspection
system and parts thereof
other Airport security systems
Exemption from duties of
Customs on all Airport Security
systems including X-ray
baggage inspection system
and part
Thereof required by Airport
Operator upon certification of
MoCA.
APAO Union Budget Proposal for Year 2016- 17
Page 16 of 22
CUSTOM DUTY
Duty on
for
Project
Imports to allow benefit of
Project Import to all items
Airport
Due to peak tariff rate of
goods for Airport
development are imported at
higher rate which resulting
higher project cost. We request
that goods imported for
development of Airports should
be eligible for basis
concessional custom duty @ 5%.
Under customs tariff vide Sl.No.232 of notification No.
21/2002 – Customs dated 1st March, 2002 a lower rate
of basic custom duty had been specified as
compared to peak tariff rate. However, subsequent
to reduction in peak tariff from 12.5% to 10% items
included under List 20 corresponding to Sl.No.232 of
the above notification were not allowed any
concessional rate of duty because Sl.No.232 was
deleted from the above Customs notification. This has
resulted into import of goods for Airport development
at peak tariff rate of Customs Duty
for development of Airports. We request the erstwhile
List 20 be expanded and goods imported for
development of Airports should be eligible for basic
concessional customs duty
@5%. The suggested list of goods
required for Airport development is enclosed as
Annexure- I .
Duty for
inspection
and
systems.
of
Customs on all Airport Security
ray
system
Airport
Operator upon certification of
Vide entry No.382 of notification 21/2002
dated 1st March, 2002 - X-ray baggage inspection
system and parts thereof are eligible for NIL basic
customs duty subject to fulfilment
of the notification. Condition 81 prescribes that import
should be by Government or its authorized person for
anti-smuggling or by CISF, Police Force, Central
Reserve Police Force, National Security Guard (NSG)
or Special Protection Group (SPG) for bomb
detection and disposal. Import of x
inspection system at Airports is for security purpose
and security is Sovereign function (Reserved Activity)
as per State Support Agreement (SSA) with Ministry of
Civil Aviation ( MoCA ) and import cost is met out of
Security Component of Passenger Service Fee.
l.No.232 of notification No.
Customs dated 1st March, 2002 a lower rate
of basic custom duty had been specified as
compared to peak tariff rate. However, subsequent
to reduction in peak tariff from 12.5% to 10% items
ponding to Sl.No.232 of
the above notification were not allowed any
concessional rate of duty because Sl.No.232 was
deleted from the above Customs notification. This has
resulted into import of goods for Airport development
uty for goods required
for development of Airports. We request the erstwhile
List 20 be expanded and goods imported for
ts should be eligible for basic
duty
goods
Airport development is enclosed as
Vide entry No.382 of notification 21/2002 – Customs
ray baggage inspection
system and parts thereof are eligible for NIL basic
ment of condition No.81
Condition 81 prescribes that import
should be by Government or its authorized person for
smuggling or by CISF, Police Force, Central
Reserve Police Force, National Security Guard (NSG)
or Special Protection Group (SPG) for bomb
Import of x-ray baggage
inspection system at Airports is for security purpose
y is Sovereign function (Reserved Activity)
as per State Support Agreement (SSA) with Ministry of
) and import cost is met out of
Security Component of Passenger Service Fee.
APAO Union Budget Proposal for Year 2016
APAO Union Budget Proposal for Year 2016- 17
Page 17 of 22
However, since import is not directly undertaken by
the above specified agencies but by respective
Airport operators, duty concession is not available
though money is being paid out of funds of
Government of India (GoI). Hence, this condition
needs to be amended to expand its scope to cover
other security systems also and to incorporate import
by respective Airport operators subject to certificate
from Government (MoCA). This concession should not
be limited to x-ray machines alone because there are
other machines, which are used for bomb detection
and disposal. Further, it should also include other
goods required for Airport security. Entry at Sl. No. 382
should be amended to “X-ray baggage inspection
system and other airport security systems and parts
thereof” (falling under chapter 84, 90 or any other
chapter).
List of such Security Systems are furnished below:
a) X-ray baggage inspection system and parts
thereof,
b) Explosive detectors,
c) Bomb/suspect luggage containment vessels/units.
d) Robots for handling of bombs or suspected
baggage,
e) Parameter security intrusion
and accessories
f) Access Control System
g) Hydraulic bollards,
h) Boom barriers
i) Cameras for CCTV.
All the above systems are bought as per
specifications laid down by Bureau of Civil Aviation
Security (BCAS), MoCA, and GoI.
However, since import is not directly undertaken by
ve specified agencies but by respective
Airport operators, duty concession is not available
though money is being paid out of funds of
Government of India (GoI). Hence, this condition
needs to be amended to expand its scope to cover
also and to incorporate import
by respective Airport operators subject to certificate
from Government (MoCA). This concession should not
ray machines alone because there are
other machines, which are used for bomb detection
rther, it should also include other
goods required for Airport security. Entry at Sl. No. 382
ray baggage inspection
system and other airport security systems and parts
thereof” (falling under chapter 84, 90 or any other
ist of such Security Systems are furnished below:
ray baggage inspection system and parts
c) Bomb/suspect luggage containment vessels/units.
d) Robots for handling of bombs or suspected
intrusion system
All the above systems are bought as per
specifications laid down by Bureau of Civil Aviation
APAO Union Budget Proposal for Year 2016
c)
Free of duty Import of Spares &
Consumables by MRO operators
APAO Union Budget Proposal for Year 2016- 17
Page 18 of 22
Import of Spares &
Consumables by MRO operators
All Materials like aircrafts spares and consumables has
to free of duty by MRO Operators. Presently there is a
free of duty of aircraft spares with a condition that the
same utilized within one year from the date of import
otherwise the same is taxable. Consumable are
taxable from the beginning.
Hence, the Free of Duty is required for Import of
Spare and Consumables with no restrictions by MRO
Operators.
********
All Materials like aircrafts spares and consumables has
to free of duty by MRO Operators. Presently there is a
free of duty of aircraft spares with a condition that the
from the date of import
otherwise the same is taxable. Consumable are
Hence, the Free of Duty is required for Import of
Spare and Consumables with no restrictions by MRO
APAO Union Budget Proposal for Year 2016
a)
Issue of “C” Form by Airport
Operators
b)
ATF as Declared Goods
Classification of “Aviation
Turbine Fuel (ATF)” as Declared
Goods to bring a uniform tariff
/Tax across India.
APAO Union Budget Proposal for Year 2016- 17
Page 19 of 22
CENTRAL SALES TAX
Allow Airport sector to issue “C” form.
Though Airport sector is an important infrastructure
sector like telecom, electricity generation and
distribution, and mining, it is not included as one of the
eligible categories which can issue concessional Form
“C� because of which purchase of goods for Airport
development attracts higher Sales Tax resulting in
increased cost of project, which is not in public interest
as any increase in cost of project ultimately translates
into higher passenger fees. In view of th
sector should also be allowed to issue C Form and to
this extent Section 8(3)(b) of Central Sales Tax Act,
1956 may be suitably amended.
“Aviation
Turbine Fuel (ATF)” as Declared
uniform tariff
Aviation Turbine Fuel (ATF) may be classified as
“Declared Goods� category under CST Act with a
uniform application of Sales Tax rate all over the
country. This will facilitate emergenc
as “Hubs� and stabilize ATF prices across the country
which will lower tariffs for passengers.
********
Allow Airport sector to issue “C” form.
Though Airport sector is an important infrastructure
sector like telecom, electricity generation and
distribution, and mining, it is not included as one of the
ch can issue concessional Form
because of which purchase of goods for Airport
development attracts higher Sales Tax resulting in
increased cost of project, which is not in public interest
as any increase in cost of project ultimately translates
into higher passenger fees. In view of this, Airport
sector should also be allowed to issue C Form and to
this extent Section 8(3)(b) of Central Sales Tax Act,
uel (ATF) may be classified as
category under CST Act with a
uniform application of Sales Tax rate all over the
country. This will facilitate emergence of Indian Airports
e ATF prices across the country
which will lower tariffs for passengers.
APAO Union Budget Proposal for Year 2016
a).
Change in Baggage
Rules
b.
Services rendered by MRO to be
eligible under SFIS / SEIS scheme
APAO Union Budget Proposal for Year 2016- 17
Page 20 of 22
POLICY ISSUE
Baggage rules, 1998 permit, inter alia, duty free
of articles other than articles mentioned in
to the rules, to the extent of Rs.45
prohibits import of liquor or wine in excess
With depreciation of Rupee there is need to
allowance to at least Rs.60,000 from
duty free import of liquor may be allowed upto 3 ltrs. of
liquor and additional 2 ltrs. of wine
Services rendered by MRO to be
IS scheme
Services rendered by MRO (even to domestic airlines)
should be considered as deemed export and
eligible for SFIS / SEIS scheme.
**-**
Baggage rules, 1998 permit, inter alia, duty free import
of articles other than articles mentioned in Annexure 1
the rules, to the extent of Rs.45,000. Annexure 1
prohibits import of liquor or wine in excess of 2 ltrs.
With depreciation of Rupee there is need to increase
0,000 from Rs.45,000 and also
allowed upto 3 ltrs. of
Services rendered by MRO (even to domestic airlines)
deemed export and be
APAO Union Budget Proposal for Year 2016
Annexure-I
Sl. No.
Tariff Code
1
Chapter 84 or any other chapter
2
Chapter 84 or any other chapter
3
Chapter 84 or any other chapter
4
Chapter 84 or any other chapter
5
Chapter 84 or any other chapter
6
Chapter 84 or any other chapter
7
Chapter 84 or any other chapter
8
Chapter 84 or any other chapter
9
Chapter 84 or any other chapter
10
Chapter 84 or any other chapter
11
Chapter 84 or any other chapter
12
Chapter 70 or any other chapter
13
Chapter 94 or any other chapter
APAO Union Budget Proposal for Year 2016- 17
Page 21 of 22
I Goods required for Airport development
Code Particulars
Chapter 84 or any other chapter Navigational / Communication Aids
Chapter 84 or any other chapter
Airfield Crash Fire Tenders & other fire
fighting vehicles
Chapter 84 or any other chapter Elevated Transport Vehicle
Chapter 84 or any other chapter AC Plant of capacity more than 200 TR
Chapter 84 or any other chapter T-5 Triphosfor Tube
any other chapter Flight Inspection System (Ground & Air)
Chapter 84 or any other chapter
Runway Marking & Pavement testing
machine
Chapter 84 or any other chapter Baggage Conveyor (handling) system
Chapter 84 or any other chapter
Passenger Boarding bridges
(Aerobridges) along with associated
Visual Guidance Docking Systems
Chapter 84 or any other chapter HVAC & accessories
Chapter 84 or any other chapter Travelators / Escalators / Lifts
chapter Structural glazing (glass)
Chapter 94 or any other chapter Airport ground lighting
Navigational / Communication Aids
Tenders & other fire
Elevated Transport Vehicle
AC Plant of capacity more than 200 TR
Flight Inspection System (Ground & Air)
Runway Marking & Pavement testing
Baggage Conveyor (handling) system
bridges
(Aerobridges) along with associated
Visual Guidance Docking Systems
Travelators / Escalators / Lifts
APAO Union Budget Proposal for Year 2016
14
Chapter 76 or any other chapter
15
Chapter 73 or any other chapter
16
Chapter 57 or any other chapter
17
Chapter 94 or any other chapter
18
Chapter 94 or any other chapter
19
Chapter 94 or any other chapter
20
Chapter 94 or any other chapter
21
Chapter 84 or any other chapter
22
Chapter 84 or any other chapter
23
Chapter 94 or any other chapter
24
Chapter 94 or any other chapter
25
Chapter 69 or any other chapter
26
Chapter 84 or any other chapter
27
Chapter 85 or any other chapter
28
Chapter 85 or any other chapter
APAO Union Budget Proposal for Year 2016- 17
Page 22 of 22
Chapter 76 or any other chapter Aluminium (Roof sheeting)
Chapter 73 or any other chapter False ceiling
Chapter 57 or any other chapter Carpet
Chapter 94 or any other chapter Fire proof door
Chapter 94 or any other chapter Revolving door
Chapter 94 or any other chapter LED Light fittings
Chapter 94 or any other chapter Check in counters
other chapter Chillers
Chapter 84 or any other chapter
Ground Power Unit (frequency
convertor)
Chapter 94 or any other chapter Signages
Chapter 94 or any other chapter Chairs
Chapter 69 or any other chapter Vitrified tiles
Chapter 84 or any other chapter Runway Sweepers
Chapter 85 or any other chapter Variable speed drives
Chapter 85 or any other chapter LCD/ LED Flat Panels
Aluminium (Roof sheeting)
(frequency