Real ease of business could be by merging CBDT & CBIC: An appeal to Hon’ble Prime Minister Sir by the Team Tax Talk


Real ease of business could be by merging CBDT & CBIC: An appeal to Hon’ble Prime Minister Sir by the Team Tax Talk



Respected Shri Narendra Ji Modi

The Hon’ble Prime Minister

Government of India

New Delhi

Subject: Conceptualizing the idea of “Tax Department of India”

Reference: Your aim of providing Ease of Business to the Business

Respected Sir,

With your capability to take every bold decision & out of the box thinking approach, we are writing to you with faith and confidence. We strongly believe that you know the ground reality very well and your intervention is now needed on the economic front for making the dream of a 5 Trillion Economy come true.

In the recent past, despite your true concerns and intentions, the tax laws & provisions are introduced in such a way that the industries are flooded with unintended & unnecessary clerical compliances rather than innovation and production. Most of such compliances work didn’t result in any direct or indirect revenue enhancement of the Government and purpose can be served with alternative options.

Here is one just provision which need to be scrapped on topmost priority for ensuring Ease of Business in true spirit:

Issue Impact Bold and Out of the Box Solution
New Income Tax Law requires TDS & TCS on purchase & sales of Goods

[Section 206AB & 206C(1H) of the Income Tax Act-1961]

If any person with turnover exceeding Rs. 10 Cr purchases goods of more than Rs. 50 Lakh then buyer is required to do TDS @ 0.10% on such purchases.

Similar provision is there on the seller as well which requires TCS on sale.

There are situations where the buyer as well as seller are required to do TDS & TCS on the same transactions due to various intricacies & ill conceived provisions.

In short
a) Almost each & every transaction would be subject to the TDS/TCS compliances.

b) Buyer & seller would be required to carry out unending reconciliation work throughout the year. Some may do TDS including GST, Expenses etc and some may do without it.

Every transaction would be required to be incorporated in the quarterly return.

Every year, based on Annual Information Statement (Formerly, 26AS) explanation and information would be required to be furnished as there may be duplication of the same data (i.e., from seller as well as buyers).

The purpose of this provision as explained in the Budget document was to
a) enhance the tax collection
b) widen the tax base

This provision is neither going to increase the revenue nor going to widen the tax base.

Already the taxpayers with turnover of Rs. 50 Lakh are liable to be registered with the GST department. While drafting the provision, it has been forgotten that the GST department is already collecting the same data wherein date-wise, bill-wise, item-wise information is already available in the Government database. Asking the taxpayers to furnish the same data again and again enhances the clerical compliances for the businesses.

Merge the CBDT & CBIC to have one common administration. One “Nation- One Tax” need to be succeeded by “One Tax Officer” for the business


It may be named as the “TAX DEPARTMENT OF INDIA”.


This will be the biggest reform in the tax administration of the Country since inception

Let the assessee be asked to submit the data once only and the returns forms may be designed in such a way that data once collected will serve all the purposes.

Merging will result in real EASE OF BUSINESS with reduction in the administrative cost of the department as well.


The concern of Governance between center and state can be solved by properly visualizing the probable issues as to data collection and power sharing.


Under your strong capability to take the bold decisions & power of administration, we have a strong feeling that:

  1. If not now, when?
  2. If not you, who?

We as taxpayers & citizens of the country, very well understand the importance of taxes in the development of any country. However, the taxes should be collected in the same way a bee collects the honey from the flower whereby flowers quality remains undeterred.

We would be happy to meet and present our ideas of merging both the departments which will be the biggest reforms of the country in tax administration. One businessman is well equipped to handle multiple business compliances and so could be possible with the tax officer.

We too carry a dream of 5 Trillion Indian economy and would be happy to share valuable input with you

Thanking you

Yours faithfully

For The Team Tax Talk