AMENDMENTS SEMINAR/WIRC Prof. Siddharth N.

Surana-9773300126
AMENDMENTS FOR A.Y. 15-16 & A.Y. 16-17
Points to be noted before studying these amendments:
1. These notes are a combination of amendments introduced by the Finance Act, 2014 and
Finance Bill, 2015.

2. Amendments of the Finance Bill, 2015 are proposals introduced by the Finance Minister in
the Parliament and may undergo some changes before becoming the Finance Act, 2015

3. The amendments introduced by the Finance Act, 2014 are relevant for students appearing in
May 2015 and Nov 2015 attempts (also obviously applicable for future attempts). However,
it is very important to note that the amendments introduced by the Finance Bill, 2015 are
applicable for May 2016 and future attempts (i.e. these amendments should be ignored by
students of May 2015 & November 2015 students)

4. Kindly give a feedback about your reading on siddharthsuran@gmail.com or +91 9773300126.

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-Prof. Siddharth Narendra Surana (CA)

Mumbai-2

ALL THE BEST. MAY GOD BLESS YOU

AMENDMENTS SEMINAR/WIRC Prof. Siddharth N. Surana-9773300126
I) BASIC CONCEPTS
1. Rates of Tax for A.Y. 15-16
1) For Individuals:
1) Resident Senior Citizens (60 years and above)
SLAB RATE
0-3,00,000 0% (Basic Exemption Limit)
3,00,000-5,00,000 10%
5,00,000-10,00,000 20%
10,00,000-Above 30%

ii) Resident Very Senior Citizens (80 years and above)

SLAB RATE
0-5,00,000 0% (Basic Exemption Limit)
5,00,000-10,00,000 20%
10,00,000-Above 30%

iii) Other Individuals (including all non residents, even if senior or very senior citizens)
SLAB RATE
0-2,50,000 0% (Basic Exemption Limit)
2,50,000-5,00,000 10%
5,00,000-10,00,000 20%
10,00,000-Above 30%
There has been no change in slab rates for A.Y. 16-17 and thus the above slabs continue to be
applicable for Individual assessees.
Rebate u/s 87A for Resident Individuals with Net Taxable Total Income not exceeding
Rs. 5,00,000 Tax liability or Rs. 2,000 whichever is less.
Surcharge @ 10% of Tax Liability if NTTI exceeds Rs. 1 crore. (subject to marginal
relief) [However, w.e.f. A.Y. 16-17 if NTTI exceeds Rs. 1 crore, the applicable rate of Surcharge
shall be 12% of Basic Tax]
Education Cess @3% of [Basic Tax + SC if applicable Rebate if applicable] always.
2) For HUF/AOP-BOI/Artificial Juridical Person
Same as A) i) except that Rebate is not applicable

3) For Partnership firms (incl LLP) & Local

Authorities: Basic Tax Rate - Flat 30%
Surcharge if NTTI > 1 crore; 10% of Basic Tax for A.Y. 15-16; 12% of Basic Tax for
A.Y. 16-17 Education Cess @3% of [Basic Tax + SC if applicable] always

4) For Companies:
1) For Domestic Companies:
Basic Tax Rate - Flat 30% (for both A.Y. 15-16 & A.Y. 16-17)
V. Imp. Note: The reduction in tax rate to 25% has not been immediately applied, it
shall become applicable over the next four years
Surcharge if NTTI > 1 crore but not exceeding 10 crore; 5% of Basic Tax for A.Y. 15-
16; 7% of Basic Tax for A.Y. 16-17 and if NTTI > 10 crore 10% of Basic Tax for A.Y.
15-16; 12% of Basic Tax for A.Y. 16-17
AMENDMENTS SEMINAR/WIRC Prof. Siddharth N. Surana-9773300126
Education Cess @3% of [Basic Tax + SC if applicable] always

1) For Other than Domestic Companies:

Basic Tax Rate - Flat 40% (for both A.Y. 15-16 & A.Y. 16-17)
Surcharge if NTTI > 1 crore but not exceeding 10 crore; 2% of Basic Tax for A.Y. 15-
16 & A.Y. 16-17 and if NTTI > 10 crore 5% of Basic Tax for A.Y. 15-16 & A.Y. 16-17
Education Cess @3% of [Basic Tax + SC if applicable] always
5) For Cooperative Societies:
SLAB RATE
0-10,000 10%
10,000-20,000 20%
20,000-Above 30%
Surcharge @ 10% of Tax Liability if NTTI exceeds Rs. 1 crore. (subject to marginal relief)
[However, w.e.f. A.Y. 16-17 if NTTI exceeds Rs. 1 crore, the applicable rate of Surcharge shall
be 12% of Basic Tax]
Education Cess @3% of [Basic Tax + SC if applicable] always.

II) RESIDENTIAL STATUS

1. A Company shall be considered as Resident in India if:
1) It is an Indian Company
2) Its Place of Effective Management at any time during the year is in India. (w.e.f. A.Y. 16-17)

61) AGRICULTURE INCOME

1. No amendment in AY 15-16 as well as AY 16-17.

IV) EXEMPT INCOME

1. W.E.F. A.Y. 16-17, Any payment (Principal+Interest) from the Sukanya Samriddhi Account
shall be exempt.
2. W.E.F. A.Y. 16-17, Income of Swachh Bharat Kosh & Clean Ganga Fund shall be exempt.
3. W.E.F. A.Y. 16-17, Any Income of a Real Estate Investment Trust by way of Rent in respect of
immovable properties let out which are directly owned by it shall be exempt.
4. W.E.F. A.Y. 16-17, Benefit of Section 10(38) shall also be available to the shareholders of a
Special Purpose Vehicle who are allotted units of a Business Trust in lieu of shares.
V) SALARY
1. No amendment in AY 15-16. However, w.e.f. AY 16-17, exemption for transport allowance
shall be increased from 800 p.m. to Rs. 1,600 p.m.

VI) HOUSE PROPERTY

1. The limit on maximum allowable Interest deduction is respect of Self Occupied Property
(SOP) has been increased from 1,50,000 to Rs. 2,00,000 w.e.f. A.Y. 15-16
AMENDMENTS SEMINAR/WIRC Prof. Siddharth N. Surana-9773300126
VIII) PROFITS AND GAINS OF BUSINESS OR PROFESSION
(PGBP)
A.Y. 15-16
1. U/s 32AC, if an assessee being a Company engaged in the manufacture or production of any
article or thing fails to invest >100 crores in new P&M in PY 13-14 and PY 14-15 together, but
still has invested in new P&M >25crore in any particular Previous Year, it shall be entitled to a
deduction of 15% of such investment in that particular year.

2. Followingtwo businesses have been added as specified business u/s 35AD:

Laying and operating a slurry pipeline for transportation of iron ore
Setting up and operating a semi conductor wafer fabrication manufacturing unit, if such
unit is notified by the CBDT.

3. Any capital asset in respect of which a deduction u/s 35AD is claimed and allowed shall be
used only for the specified business for a period of 8 years beginning from the Previous Year in
which such asset is purchased or constructed.

4. Once a deduction is claimed u/s 35AD, the assessee shall not be entitled to claim a
deduction u/s 10AA i.e. SEZ.

5. For the purpose of section 37(1) any expenditure incurred by the assessee on the activities
related to corporate social responsibility referred to in section 135 of the Companies Act, 2013
shall not be deemed to be an expenditure incurred by the assessee for the purpose of the
business or profession and thus shall be disallowed.

6. [ALSO IN TDS] U/s 40(a) in respect of amounts paid to non residents the expense shall be allowed as
a deduction if TDS is deposited with the Central Government on or before the due date u/s 139(1).

7. [ALSO IN TDS] U/s 40(a) in respect of amounts paid to residents, where TDS has not been
deducted or deducted but not deposited with the Central Government, only 30% of the expense
shall be disallowed. Further, in future when payment is actually made only 30% of the expense
shall be allowed as a deduction.

8. U/s 444AE, the deemed income shall be 7,500 p.m. per truck whether light or heavy.
A.Y. 16-17
1. Additional depreciation in respect of a manufacturing unit set up in the backward region of
Andhra Pradesh or Telangana as notified by the C.G. shall be 35% instead of 20%.

2. When additional depreciation in respect of New P&M acquired by a Manufacturer was

restricted to half of the normal rate i.e 10% (or for a manufacturing unit set up in the backward
region of Andhra Pradesh or Telangana as notified by the C.G. 17.5%) if the asset was used for
less than 180 days during the year, the balance half can be claimed in the subsequent year.

3. New Section 32AD has been inserted to provide for deduction in respect of NEW P&M
acquired for the purpose of setting up a NEW manufacturing unit in the backward region of
Andhra Pradesh or Telangana as notified by the C.G @15% of Cost of Such Assets. However,
the assets which are ineligible for deduction u/s 32AC as well as Additional Depreciation u/s 32
are also ineligible for deduction u/s 32AC. This deduction is over and above the normal
depreciation, additional depreciation and deduction u/s 32AC.
AMENDMENTS SEMINAR/WIRC Prof. Siddharth N. Surana-9773300126
IX) INCOME FROM OTHER SOURCES
1. W.E.F. A.Y. 15-16 any sum of money received as advance in the course of negotiations for transfer of a
capital asset if such sum is forfeited and negotiations do not result in transfer of capital asset, shall be
taxable as IFOS and shall not be deducted from the cost of acquisition of the capital asset at the time of
transfer. However, forfeitures prior to A.Y. 15-16 have not been taxed as IFOS, thus they will continue to
be subtracted from COA at the time of transfer of capital asset. [ALSO IN CG]

X) CAPITAL GAINS
1. Securities held by FIIs in accordance with SEBI regulations shall be regarded as capital
asset. (A.Y. 15-16)

2. Following transactions shall be excluded from the definition of taxable transfer:

Any transfer of capital asset being a government security by one non resident to another
non resident outside India. [Sec. 47 (viib)]
Any transfer of capital asset being shares of a special purpose vehicle to a business trust in
lieu of units allotted by that trust to the transferor. [Sec. 47 (xvii)]

3. Assets becoming Long Term Capital Assets after holding period of >12 months
(instead of >36 months): [ALSO IN CAPITAL GAINS]
Upto A.Y. 14-15 W.E.F. A.Y. 15-16
1. Shares 1. Listed Securities
2. Listed Securities 2. Units of Equity Oriented Mutual Fund
3. Units of UTI/Mutual Fund 3. Zero Coupon Bond
4. Zero Coupon Bonds
Thus, unlisted shares and units of funds other than equity oriented mutual fund will now
become LTCA after holding period of >36 months.

4. Incase of units of a business trust allotted in pursuance of transfer of shares, there shall be included the
period for which the shares were held by the assessee, to decide whether LTCA or STCA. (A.Y. 15-16)

5. Rate of tax on LTCG is 20%. However, in respect of the following assets assesse has the
option to take tax rate of 10% without indexation benefit: [ALSO IN CAPITAL GAINS]
Upto A.Y. 14-15 W.E.F. A.Y. 15-16
1. Listed Securities 1. Listed Securities
2. Units of UTI/Mutual Fund 2. Zero Coupon Bond
3. Zero Coupon Bonds
Thus, this option is withdrawn from units of UTI/mutual fund.
6. The Cost Inflation Index for P.Y. 14-15 is 1024.

7. W.E.F. A.Y. 15-16 any sum of money received as advance in the course of negotiations for transfer of a
capital asset if such sum is forfeited and negotiations do not result in transfer of capital asset, shall be
taxable as IFOS and shall not be deducted from the cost of acquisition of the capital asset at the time of
transfer. However, forfeitures prior to A.Y. 15-16 have not been taxed as IFOS, thus they will continue to
be subtracted from COA at the time of transfer of capital asset. [ALSO IN IFOS]

8. In respect of compulsory acquisition u/s 45(5), enhanced compensation shall be taxable in the year in
which final order of court or tribunal is made instead of year of receipt of compensation. (A.Y. 15-16)
AMENDMENTS SEMINAR/WIRC Prof. Siddharth N. Surana-9773300126
9. Sec 111A and 10(38) shall be applicable on units of Business Trust also, excluding those
units which were received as a consideration for transfer of shares in the SPV. [However, w.e.f.
A.Y. 16-17 even shareholders of the SPV will be eligible for such benefit]

10. U/s 54 and 54F exemption shall be available only in respect of one residential house
acquired in India.

11. U/s 54EC total amount of exemption shall be restricted to Rs. 50lakhs, whether in one or
more financial year.

XI) CLUBBING OF INCOME

1. No amendment in AY 15-16 as well as AY 16-17.
XII) SET OFF & C/F OF LOSSES
1. No amendment in AY 15-16 as well as AY 16-17.

XIII) DEDUCTIONS UNDER CHAPTER VI-A

1. The maximum allowable deduction u/s 80C has been increased to Rs. 1,50,000 from Rs. 1,00,000.
Corresponding amendment has been made u/s 80CCE under which maximum deduction u/s
80C+80CCC+80CCD shall be restricted to Rs. 1,50,000. However, it is pertinent to note that the individual
limits u/s 80CCC and 80CCD have not been raised and they are still Rs. 1,00,000. (A.Y. 15-16)

2. However, w.e.f. A.Y. 16-17 even the individual limit of Section 80CCC has been raised to Rs. 1,50,000

3. W.e.f. A.Y. 16-17 u/s 80CCD over and above the existing deduction, an additional deduction
of Rs. 50,000 shall be available in respect of contributions to the NPS.

4. W.e.f. A.Y. 16-17, u/s 80D the limit for maximum deduction has been increased from Rs.
15,000 to Rs. 25,000. Similarly, in respect of Senior Citizens the maximum limit has been raised
from 20,000 to Rs. 30,000. [Limits raised for both Individual assessees as well as HUF
assessees]. Further, in respect of medical expenditure of Resident Very Senior Citizens (80
years and above, for whom medical expenditure is incurred but no policy is available), deduction
shall be available for treatment expenditure within the overall limit of Rs. 30,000 as prescribed

5. W.e.f. A.Y. 16-17 the deduction limits u/s 80DD & 80U have been raised as
follows: Normal Disability - 75,000
Severe Disability - 1,25,000

6. U/s 80DDB the limit for deduction for treatment of Resident Very Senior Citizens shall be Rs.
80,000. Further, The requirement to obtain a certificate from a Govt Hospital has been done
away with. Instead, certificate from a specialist doctor will have to be obtained.

7. U/s 80G Contributions to National Fund for Control of Drug Abuse, Swachh Bharat Kosh &
Clean Ganga Fund shall be eligible for 100% deduction.
AMENDMENTS SEMINAR/WIRC Prof. Siddharth N. Surana-9773300126
SOME CA FINAL AMENDMENTS OF A.Y. 15-16 & A.Y. 16-17
A) TAXATION OF BUSINESS TRUSTS
(newly introduced chapter in the act w.e.f. 01/10/2014)

The infrastructure sector of India is in a challenging phase with existing projects getting delayed and
diminishing attractiveness of new projects. In order to promote investment in the Real Estate sector, two
new form of Investment Vehicles have been introduced w.e.f. 01/10/2014 viz Real Estate Investment Trust
(REIT) and Infrastructure Investment Trust (Invit) together known as Business Trusts.
This chapter seeks to clarify the taxation aspects in respect of transactions related to such
Business Trusts.

1. Section 2(13): Business Trust (B.T.) means an Infrastructure Investment Trust or Real Estate
Investment Trust, the units of which are required to be listed on a recognized stock exchange, in
accordance with the regulations made under the SEBI Act, 1992 and notified by the Central
Government in this behalf.

2. Section 10 (23FC): Interest & Dividend income received by the BT from the Special Purpose
Vehicle (SPV) shall be exempt. Thus, the SPV shall not deduct any TDS while making payment
to the BT. However, the SPV will have to pay Dividend Distribution Tax. [EXEMPT INCOME]
Note: SPV means an Indian Co. in which the BT holds controlling/other interest as required
under the SEBI guidelines. [FURTHER U/S 10(23FCA) INSERTED W.E.F. A.Y. 16-17, Any
Income of a Real Estate Investment Trust by way of Rent in respect of immovable properties let
out which are directly owned by it shall be exempt.]
3. Section 10 (23FD): Dividend Income distributed by the BT to unitholders shall be exempt. However,
interest income distributed to unitholders shall be taxable at 5% for non resident unitholders and at 10%
for resident unitholders. [EXEMPT INCOME / TDS / SPECIAL RATES OF TAX]

4. Section 115A: Interest income received by non-residents from business trusts shall be taxable
at 5%. [TDS / SPECIAL RATES OF TAX]

5. Section 2(42A) & 47: Getting units of a BT in exchange of shares held in the SPV shall not be
regarded as a taxable transfer and thus there will not be any capital gains. These, capital gains
shall be taxable when the units are ultimately sold and the cost of acquisition shall be the cost of
shares. [CAPITAL GAINS]

6. Section 10 (38) & 111A: Sale of units of BT on a recognized stock exchange shall attract the
same levy of STT as equity shares of a company and thus preferential tax benefit i.e. LTCG-Exempt
and STCG-taxable at 15% shall be available on sale of such units. However, if such units were
received in exchange of shares of a SPV, the beneficial tax rates shall not be available. [CAPITAL
GAINS / STOCK MARKET DEALINGS] [However, w.e.f. A.Y. 16-17 even shareholders of the
SPV will be eligible for such benefit]

7. Section 139(4E): Every BT shall be required to furnish its Return of Income. [ASSESSMENT
PROCEDURE]

8. Sec 115UA: Income of a BT shall be taxed at maximum marginal rate. [BASIC CONCEPTS].
 AMENDMENTS SEMINAR/WIRC Prof. Siddharth N. Surana-9773300126
B) DIVIDEND DISTRIBUTION TAX / BUYBACK TAX / INCOME
DISTRIBUTION TAX / SECURITISATION INCOME TAX
1. Sec 115O - w.e.f. 01/10/2014, for the purpose of calculation of tax on distributed profits by a
domestic company, the amount of dividends on which liability has to be calculated shall be
increased to such amount as would after reduction of tax on such amount calculated at the
specified rate be equal to the net amount distributed to the shareholders.

2. Sec 115R - w.e.f. 01/10/2014, for the purpose of calculation of tax on distributed income by a
mutual fund, the amount of income on which liability has to be calculated shall be increased to
such amount as would after reduction of tax on such amount calculated at the specified rate be
equal to the net amount distributed to the unitholders.

C) MINIMUM ALTERNATE TAX(MAT) / ALTERNATE MINIMUM

TAX (AMT)
1) MAT - W.e.f. A.Y. 16-17 C.G. of FIIs excluding STCG on which STT is not levied shall be
immune from levy of MAT
2) AMT
1. Sec 115JC - W.e.f. A.Y. 15-16 the Adjusted Total Income (ATI) shall also be increased by the
deduction claimed u/s 35AD as reduced by the amount of depreciation allowable u/s 32 in
respect of assets on which deduction u/s 35AD is claimed.
2. Sec 115JEE- W.e.f. A.Y. 15-16 for non applicability of AMT provisions the assessee should
not have claimed deduction u/s 35AD also along with income related deductions under chapter
VI-A and SEZ deduction u/s 10AA.

D) ASSESSMENT OF CHARITABLE TRUSTS

1. If the registration of a trust u/s 12AA is in force it shall not be entitled for any exemption u/s
10 other than Section 10(1) and Section 10(23C). W.E.F. A.Y. 15-16

2. In order to provide reprieve for genuine cases w.e.f. 01/10/2014 if a trust has been granted
registration u/s 12AA, then exemption from income tax shall be available for all assessment
years in respect of which proceedings are pending before the Assessing Officer if other
conditions for exemption are satisfied for all those years and non registration merely will not
become a ground for not getting exemption. Further, in respect of assessment years before
registration became effective the A.O. shall not reopen any case u/s 147 merely on the ground
that the trust was not registered during those years. However, these beneficial provisions shall
not be available to those trusts where registration was earlier refused or granted but cancelled.

3. Where the cost of an asset, acquired for charitable purposes, is claimed as an application of
income, the trust shall not be eligible for depreciation on the same. W.E.F. A.Y. 15-16

4. W.e.f. 01/10/2014 in respect of following contraventions by a trust not only the exemption will
be lost but also the registration will be cancelled:
Created for private religious purposes, where benefits do not endure to general
public Where benefits are restricted to a particular caste, community, creed or
religion Where income is utilized for the benefit of certain specified persons
Income from non specified investments.
AMENDMENTS SEMINAR/WIRC Prof. Siddharth N. Surana-9773300126 5. Where a trust has
income from anonymous donations, earlier the total tax liability of a trust was calculated by
aggregating the tax calculated @ 30% on [Anonymous donations 5% of total donations or Rs.
1,00,000 whichever is higher] and the tax on other income as per normal provisions. However,
w.e.f. A.Y. 15-16 the total tax liability of a trust will be calculated by aggregating the tax
calculated on anonymous donations as above and the tax on other income as per normal
provisions, where other income shall also include the amount subtracted from anonymous
donations before charging tax at 30% i.e. 5% of total donations or 1,00,000 whichever is higher.

6. The activity of YOGA shall be considered as a charitable purpose w.e.f. A.Y. 16-17
7. W.E.F. A.Y. 16-17 advancement of any other object of general public utility shall not be a
charitable purpose if such activity does not involve actual carrying out of advancement of any
other object of general public utility and if receipts from such business activity exceed 20% of
total receipts of such trust.

E) INCOME TAX AUTHORITIES, THEIR POWERS

1. The following new posts will be created in the income tax department
hierarchy: Principal DGIT at DGIT level
Principal CCIT at CCIT level
Principal DIT at DIT level
Principal CIT at CIT level
Wherever in the Act the terms DGIT, CCIT, DIT, CIT are used the sections will be deemed
to be using the terms Principal DGIT, Principal CCIT, Principal DIT, Principal CIT respectively
also along with the existing terms.

2. W.e.f. 01/10/2014 in the course of survey proceedings u/s 133A the period of limitation for
impounding books of accounts and documents shall be increased to 15 working days to bring it
at par with Section 131.

3. W.e.f. 01/10/2014, an income tax authority may for the purpose of verifying that tax has been
deducted or collected as source as per the provisions of Chapter XII-B or Chapter XII-BB, as the
case may be, enter any office or place where business or profession is carried on, within his
jurisdictional limits or any other place where books of accounts or documents are kept for the
purpose of this section. Entry to such place should be after sunrise and before sunset. During
the course of the survey the I.T. authority may require the deductor or the collector to:
1) afford him facility to inspect books of accounts & other documents
2) furnish such other information as may be required
(Thus, power of survey is now available to TDS and TCS officers also)

4. Section 133C: (w.e.f. 01/10/2014): With a view to enable the income tax authority to verify the
information in its possession related to any person, prescribed income tax authority may issue a
notice to such person requiring him, on or before a date specified therein, to furnish information
or documents, verified in the manner specified therein which may be useful for or relevant to
any inquiry or proceeding under this Act.
AMENDMENTS SEMINAR/WIRC Prof. Siddharth N. Surana-9773300126
OTHER AMENDMENTS UNDER THE FINANCE BILL, 2015
1. Wealth Tax abolished. A bold and brave step by the Finance Minister. (The loss of revenue is
being set off by increasing the rate of Surcharge by 2%)

2. A scheme to curb tax evasion:

1. Concealment of income or wealth related to foreign exchange asset will be an offence
punishable with prosecution of 10 years. The offence will be non compoundable. Assessee
will not be allowed to approach Income Tax Settlement Commission.
2. Not mentioning forex asset in Income tax return will be punishable with 7years imprisonment.
3. Such concealed amount will be taxed at maximum marginal rate and no
exemption/deduction shall be available from such income.
4. It will be mandatory to file income tax return even if there is no taxable income
5. Date of opening foreign bank account has to be mentioned in income tax return.
6.Such offences will also be covered under Prevention of Money Laundering Act and Foreign
Exchange Management Act, to enable confiscation.
7. Confiscation of Benami properties and prosecution
8. For purchase of immovable property in respect of advance paid of 20,000 or more cash
payment will not be allowed
9. Quoting of PAN is mandatory in respect of sale> 1, 00, 000
10. CBDT & CBEC will have a joint database

3. General Anti Avoidance Rules (GAAR) have been deferred for 2 years.

4. Rate of tax on Royalty and Fees for Technical Services earned by Non Residents or Foreign
companies reduced to 10%.

5. Rate of tax on Royalty and Fees for Technical Services earned by non resident or foreign
companies reduced to 10%

6. Basic Customs Duty will be reduced on some Raw materials to enable Make in India.

7. Threshold limit for applicability of Domestic Transfer Pricing raised to 20crore from 5crore.

8. Rate of Basic excise duty increased to 12.5% (However, no Education cess will be levied).
However, on leather goods with Retail price of > 1, 000 it will be 6%.

9. Registration under Excise and Service tax can be done online within 2 working days.

10. Service Tax increased to 14%. (However, no Education cess will be levied )

11. No Service Tax on insurance premium paid by Senior citizens