1

TAX EVASION
INTRODUCTION

Tax Evasion entails the efforts that are made by trusts, individuals, firms, and
various other entities to avoid paying taxes by illegal and unfair means. The
Evasion of Tax usually takes place when taxpayers deliberately hide their
incomes from the tax authorities in order to reduce their liability of tax.

Evasion Tax takes place when the people report dishonest tax that includes
declaring less gains, profits, or income than what has been actually earned and
they even go for overstating deductions. The Evasion of Tax level depends on
certain factors such as fiscal equation which means that people's tendency to
pay less tax declines when the payment due from taxes becomes obvious. The
level of Tax Evasion is also dependent on the tax administration's efficiency
and corruption levels.

The level of Evasion Tax also depends on the chartered accountants and tax
lawyers who help companies, firms, and individuals evade paying taxes. Tax
Evasion is a crime in all major countries and the guilty parties are subjected to
imprisonment and fines. The various methods of Tax Evasion are:
1. Smuggling
2. Customs duty evasion
3. Value added tax evasion
4. I llegal income tax evasion
1. Smuggling is a method of Tax Evasion, following which people export or
import foreign goods through routes that are unauthorized. People resort to
smuggling for they want to avoid paying total customs duties that are
chargeable and also when they want to import items that are contraband.





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2. Customs duty evasion is another method of Tax Evasion under which the
importers evade paying customs duty by false declarations of the description of
the product and quantity. The importers in order to evade paying customs duty
also resort to under-invoicing.

3. Another method of Tax Evasion is value added tax evasion under which the
producers who collect from the consumers the value added tax evade paying
taxes by showing less sales amount.

4. Many people earn money by means that are illegal such as theft, gambling, and
drug trafficking and so they do not pay tax on this amount and thus this is
another method of Tax Evasion that is called illegal income tax evasion.

Tax Evasion results in the loss of revenue for the government and so ideally,
no one should be indulging in it and the I ndian government must also take
steps in order to stop Evasion of Tax by the people.







3

TAX EVASION PENALTIES


Under the Income - Tax Act, 1961, currently in force, the fine for concealing
particulars of income or furnishing inaccurate information ranges between one
and three times the amount sought to be evaded.

A person shall be liable to a penalty if he has under reported the tax bases for
any financial year. The penalty shall be a sum, which shall not be less than, but
which shall not exceed two times the amount of tax payable in respect of the
amount of tax bases under reported for the financial year, the code states.

So, if the tax due on an under-reported amount is Rs 100, then the maximum
penalty proposed to be levied is Rs 200 instead of a maximum of Rs 300 at present.

Under Direct Taxes Code (DTC), the tax department, however, intends to arm
itself with more sweeping powers to impose a penalty.

Under the I-T Act, a penalty is imposed for concealment of particulars of
income. It is now proposed to levy a penalty on under-reporting the tax base.

Tax experts said at present, if you are able to convince the government that your
intent was not to evade tax, you will be let off without a penalty. But under the
new legislation, even if there is a minor mistake in the calculation of taxable
income or tax liability, the government can impose a penalty for under-
reporting.

A finance ministry official, however, said that though a maximum penalty of
three times the tax sought to be evaded was allowed under the I-T Act, in
practice it was never levied. The official said the penalty is proposed to be
reduced under DTC, as the actual penalty imposed was 100-200 per cent in
most cases.

100 per cent penalty, which is the lower limit, is generally imposed in practice.
300 per cent penalty is imposed only in very serious cases.



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For willful falsification of books of accounts or documents, DTC has proposed
to lower the penalty. It has proposed a penalty ranging between Rs 25,000 and
Rs 300,000, apart from rigorous imprisonment.

At present, the penalty is at the discretion of the assessing officer. A similar
provision has also been made in case a person willfully attempts to evade tax.

Here, a penalty of Rs 50,000 to Rs 500,000 is proposed to be imposed if
the amount sought to be evaded is more than Rs 100,000, along with
imprisonment.

CONTROL OF EVASION

In the past, for checking evasion, stress had mostly been on legislative measures,
forgetting that equal importance is to be given to administrative aspects.
In the discussion to follow, some suggestions for checking evasion, through
legislation, and for improving compliance to tax laws are being mentioned. As
indicated earlier, the problems need to be tackled in two ways -- by legislation and
taking effective administrative measures.
A number of countries have incorporated provisions in their tax laws to check
unintended use of tax laws to avoid payment of legitimate taxes.
Laws of countries like Argentina and Australia contain provisions to check tax
avoidance through transfer pricing and cross-border transactions, which are not
arms length deals
In Malaysia, legislation permits the revenue authority to disregard or verify a
transaction that is believed to have the effect of tax avoidance. Some countries
follow 'group' taxation system to avoid tax pilferage.
The German income tax law has anti-abuse rules, which provide for ignoring
unjustified reduction brought about in withholding taxes under a treaty or directive
shopping.
In Hong Kong, wholly artificial or fictitious motivated transactions, including
cross-border big ticket leasing can be disregarded. Similar provisions can be
incorporated in our tax laws too to plug revenue leakage caused through crafty
manoeuvres.


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Other measures for checking tax evasion through legislation could be:-
1. Taxing big and prosperous agriculturists' incomes and wealth.
2. Introducing done-based gift tax.
3. Permitting tax officials to have power of door-to-door survey.
4. Claims for losses/expenses relating to undisclosed or illegal incomes should
not be recognised for tax assessments while taxing incomes from such
sources.
5. In countries like Belgium, Greece and France there is provision for
confiscation of personal rights like arms or driving licence of persons found
guilty of dealing with black money or resorting to tax evasion. Similar law
should be made in India too. Such persons should also be debarred from
holding any elective offices, including directorships in companies.
Among administrative aspects, strict measures can only create impact. Some
suggestions in this context are:
1. Tax laws should permit wide publicity through media regarding persons
found guilty of tax evasion.
2. Social conscience needs to be aroused amongst people against tax evasion,
for attaching social stigma for tax evaders and to work as sentinels for
identifying black marketers and tax dodgers.
The most important measure for checking evasion is to establish credibility of the
government regarding its own integrity before exhorting persons to pay their taxes
correctly. Some other measures, of an administrative nature, could be:
1. Disentitling tax evaders/defaulters to avail of the facility of payment of taxes
in the installments and getting credit facilities from banks.
2. Streamlining procedure for speedy determination of tax disputes. Special
courts for this need to be set up.
3. Paying special attention towards training for detection of tax frauds, evasion
and black money generation, including deputation of IT officers to other
countries for training to tackle cross border tax evasion.
4. Providing adequate security to tax officials, conducting search and surveys.
5. Improving morale of the tax department officials by providing them
adequate infrastructure and other facilities, by recognition of their merit and
giving them the place that they deserve in the overall government set up.



6

CASE STUDIES

CASE STUDY ON KINGFISHER- KINGFISHER
ACCUSED OF EVADING 35 CRORES TAX IN
PLANE DEAL




7

Kingfisher Airlines, owned by liquor baron and Rajya Sabha MP Vijay Mallya,
has come under the scanner of the state commercial tax department for tax evasion.
In an order, dated February 11, 2011, the department has asked Mallya to cough up
tax and interest amounting to Rs 35 crore on sale transaction of an Airbus A 319
133 CJ, a plush aircraft the MP has allegedly used personally.
Challenging the tax evasion notice, Mallyas firm moved the High Court of
Karnataka. When the case came up for hearing on April 4, Justice H G Ramesh
asked the commercial tax department to look into the matter afresh. He neither
upheld the tax evasion notice nor quashed it.

They (Kingfisher Airlines) have evaded tax on sale transaction of an Airbus
plane, KM Shivayogi Swami, advocate for the commercial tax department, told
Bangalore Mirror. The department has ordered the airline to pay tax for the
transaction carried out in the state.
The commercial tax department maintains that the sale transaction between
Mallyas firm and another company, identified as C J Leasing (Cayman) Limited,
took place in Bangalore, and the sale agreement was registered at a sub-registrars
office in the city. But Kingfisher Airlines, in its petition to the high court, has
stated that the transaction took place in Germany, and so it is not liable to pay any
tax to the state.

Case history

Kingfisher Airlines placed its order for the aircraft with Airbus Industries,
Hamburg, Germany, in 2006. The price of the aircraft was $61,093,550 its
standard equipment costing $33,321,040 and customised equipment $27,772,510.
An invoice, dated November 20, 2006, states that the airline bought the aircraft
with both standard and customised equipment. However, the aircraft remained in
the custody of the manufacturer until it was delivered to the airline on November
28, 2006.



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In the intervening period, Kingfisher entered into a sale and lease-back
arrangement with C J Leasing for the standard equipment. Accordingly, the
equipment was sold to C J Leasing (Cayman) Limited on November 23, 2006, and
subsequently to C J Leasing (Ireland) Limited. Later, the airline took back the
standard equipment by entering into a lease agreement with the latter.

Thus, the airline actually owned only the customised equipment of the aircraft. To
bring the aircraft to India, Mallyas firm obtained a certificate of airworthiness
from the German authorities on November 28, 2006. To induct the aircraft in the
Kingfisher fleet, it was necessary to register it with the DGCA. That was done on
November 29, 2006, and the aircraft got its registration marking VT-VJM the same
day.

Bone of contention

According to Kingfisher, the aircraft was not in India on November 23, 2006, but
the commercial tax department is claiming that it has records and bills to show that
the aircraft was imported to India on November 20, 2006, in the name of M/s
Kingfisher Airlines Pvt Limited, Bangalore.

The commercial tax department in its order has charged Kingfisher Airlines for not
paying tax on the sale transaction of Air Bus A 319 133 CJ conducted in the city
on November 23, 2006. The department has levied a total amount of
Rs.35,65,70,204 on the airline. It includes an interest of Rs 14,45,55,488, a penalty
of Rs 1,92,74,065 and value- added tax (VAT) of Rs 19,27,40,651.

The sale and purchase agreement between Kingfisher and C J Leasing (Cayman)
Limited, dated November 23, 2006 and registered in the office of sub-registrar,
Shivajinagar, is the ground for the commercial tax departments stand. The place
of entering the agreement is Bangalore, Swami said. Our contention is based on
the 20th Century Corporation Limited vs state of Maharashtra and others case. The
Supreme Court of India has held that the place of agreement is the place of sale


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irrespective of the location of goods.

The denial

Kingfisher Airlines has filed a writ petition in the high court, denying the charges
and seeking that the tax departments order be quashed. Their stand is different,
Swami said. They are claiming that the state commercial tax department cant
levy tax as the transaction took place in international space.

The high court, after taking into account both Kingfisher Airlines petition and
commercial tax departments objections, has directed the latter to pass an order
after a fresh inquiry. Commercial tax sleuths, however, are confident of that the
company would be asked to pay up.

When contacted, Prakash Mirpuri, chief of corporate communications, UB Group-
Kingfisher, said he would respond only if Bangalore Mirror posed its queries in
writing via e-mail. Accordingly, a mail was sent to him on Wednesday evening,
but it got no reply till it went to print on Thursday night.









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2
nd
Case Study - HASAN MOHAMMAD ALI





Rs 35,000 crores is the estimated size of what could be the biggest income tax
evasion scam in this country, reports CNBC-TV18. A six-storeyed building in
Pune's Koregaon Park area belongs to Hasan Mohammed Ali - an affluent business
man having interest in horse breeding, exports, and of course horse racing. But a
casual raid by the Income Tax department has opened up a can of worms on his
life style.

The IT Department smelled a rat and raided Ali's offices in Pune, Mumbai,
Hyderabad and Kolkata between 5th and 7th of January this year where they came
across Ali's computer. The hard disc contained details of transactions totalling to
Rs 35,000 crores in 10 Swiss bank accounts.




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"We can't confirm or deny anything right now," says DV Dharmik, Chief IT
Commissioner, Hyderabad. The Finance Ministry was informed immeditely and
they handed over the case to the Enforcement Directorate. Accordingly, a team of
four senior officers was sent to Switzerland between January 15-19. Details of
seven out of the 10 accounts were found matching and the Government of India
asked for the accounts to be frozen.

Ali has been questioned in this respect on various ocassions but has not been
arrested so far due to lack of evidence. The IT department, meanwhile, is being
tight lipped about the matter.
Sources say Hasan Ali may be charged with a penalty of nearly Rs 40000 crores.

What started as a random scrutiny is turning out to be the biggest case in the
history of income tax investigations. The Enforcement Directorate is now waiting
for details from the Swiss bank to finally nail Hassan Ali. But the real question is -
where did this huge amount of Rs 35,000 crore come from and who are the other
bigger players.














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3.Tax evasion case: Rs 50cr notice on
Delhi Tivoli Garden Resort.



The Tax department of Delhi government slapped a notice of Rs 50 crore on a
private resort in a tax evasion case in which city Lokayukta had recommended
sacking of PWD minister Raj Kumar Chauhan for trying to protect it.
Top officials said the notice has been served on Tivoli Garden Resort hotel asking
to pay the amount in the tax evasion case which has been pursued by the Value
Added Tax department of the government for the past 10 months.
"They have been served a demand notice of Rs 50 crore" a top Tax department
official told PTI.
The notice has been slapped for evading tax by the resort from the year 2006 to
2010.
When contacted, a Tivoli Garden official said they had not received any notice
from the government. In an unprecedented order, Delhi Lokayukta last month had
recommended sacking of Rajkumar Chauhan from Delhi Cabinet for trying to
protect the resort in the tax evasion case, holding him guilty of "misconduct of
grave nature".


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TAX AVOIDANCE
Tax Avoidance means the tax regime's legal use for one's own personal
advantage so as to lessen the tax amount that is payable to the government by
ways that are legal. The Avoidance of Tax is usually done by the people who
desire to keep their money with themselves and not give it to the government.

Avoidance Tax includes situations when people eliminate or reduce tax by
following a transaction or many transactions that are legal. The income tax
department provides many provisions through which the people can go for Tax
Avoidance such as refunds, credits, benefits, and many other kinds of
entitlements. The various methods of Tax Avoidance are:
1. Legal entities
2. Country of residence
3. Double taxation
1. Legal entities are a method that people follow when they want to go for Tax
Avoidance. Under this method of Avoidance Tax, people legally defer paying
personal taxes by creating a legal separate entity to which they donate their
property. The legal separate entity that is set up is often a foundation, company,
or trust. The properties are transferred to the trust or company, as a result of
which the income that is earned belongs to this entity and not by the owner.
Usually, people are taxed personally on earnings and property that they own
and thus by transferring property to a legal separate entity, individuals can
avoid personal taxation although certain taxes such as corporate taxes are still
applicable. In order to go for Tax Avoidance, the foundation, company, or trust
can also avoid corporate taxes if the entity is set up in a jurisdiction that
considered offshore.

2. Country of residence is another method that people adopt when they go for
Avoidance of Tax. Under this method of Tax Avoidance, the company or
person changes the tax residence to a place that is a tax haven in order to lower
the amount of taxes that they pay. Under this method, the person may also
become a regular traveler so that taxation can be avoided.





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3. Double taxation means that many countries charge taxes on the income that has
been earned inside that country without taking into consideration, the resident
country of the firm or person. So that people do not have to pay double taxes,
once in the country where the income has been earned and then again in the
resident country, many countries have gone for bilateral treaties of double
taxation with other countries. This helps tax-payers as they are able to avoid
paying double taxes. We will study about it in detail.

Tax Avoidance reduces the revenue of the government and also brings into
disrepute, the tax system. I deally, Avoidance of Tax should not be encouraged
and the government should also take measures in order to prevent it.








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Double taxation

Double taxation occurs when an individual is required to pay two or more taxes for
the same income, asset, or financial transaction in different countries. Double
taxation occurs mainly due to overlapping tax laws and regulations of the
countries where an individual operates his business.
When an Indian businessman makes a profit or some other type of taxable gain in
another country, he may be in a situation where he will be required to pay a tax on
that income in India, as well as in the country in which the income was made! To
protect Indian tax payers from this unfair practice, the Indian government has
entered into tax treaties, known as Double Taxation Avoidance Agreement
(DTAA) with 65 countries, including U.S.A, Canada, U.K, Japan, Germany,
Australia, Singapore, U.A.E, and Switzerland. DTAA ensures that India's trade and
services with other countries, as well the movement of capital are not adversely
affected.

Capital gain tax rates

Under Section 90 and 91 of the Income Tax Act, relief against double taxation is
provided in two ways:

Unilateral Relief

Under Section 91, the Indian government can relieve an individual from double
taxation irrespective of whether there is a DTAA between India and the other
country concerned. Unilateral relief may be offered to a tax payer if:
1. The person or company has been a resident of India in the previous year.
2. The same income must be accrued to and received by the tax payer outside
India in the previous year.
3. The income should have been taxed in India and in another country with
which there is no tax treaty.
4. The person or company has paid tax under the laws of the foreign country in
question.


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Bilateral Relief

Under Section 90, the Indian government offers protection against double
taxation by entering into a DTAA with another country, based on mutually
acceptable terms. Such relief may be offered under two methods:
1. Exemption method
2. Tax credit method

Exemption Method: This method is for the residence country to exclude foreign
income from its tax base and the exclusive right to tax such incomes goes to the
source country. This is known as complete exemption method and is sometimes
followed in respect of profits attributable to foreign permanent establishments or
income from immovable property. Indian tax treaties with Denmark, Norway and
Sweden are of this nature with respect to certain incomes.

Credit Method: It reflects the underline concept that the resident remains liable in
the country of residence on its global income, however as far the quantum of tax
liabilities is concerned credit for tax paid in the source country is given by the
residence country against its domestic tax as if the foreign tax were paid to the
country of residence itself.












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Tax EVASION and Tax AVOIDANCE

DIFFERENCEs
Tax avoidance and tax evasion are terms so frequently referred to in economic
and business relationships today that they constitute part of our conversational
language and people in general use these terms even without knowing their exact
meaning and difference.
1.Whereas tax avoidance implies a situation in which the taxpayer reduces his tax
liability by taking advantage of the loop-holes and ambiguities in the legal
provisions, in the case of tax evasion, facts are deliberately misinterpreted and the
tax liability is understated.
2.While tax avoidance is perfectly legal and is, at times, referred to as tax
planning, tax evasion is illegal and, therefore, carries with it the risk of penalties
and prosecutions under the tax laws.
3. As such, the black economy comprises the sum total of all the various methods
of tax evasion but does not include tax avoidance. This means that Tax Evasion is
a part of Black Money Economy but Tax Avoidance is not.
4. Tax avoidance is good. In contrast to tax avoidance, which is recommended and
is a dignified good-sense business, tax evasion is cheating and often referred to as a
crime.
SIMILARITY
Accordingly, whereas the consequences of the two phenomena are different for the
taxpayers, both reduce the revenue of the Exchequer and consequently need to be
checked to the greatest extent possible.




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TAX PLANNING
What is Tax Planning ?
Tax planning is an essential part of your financial planning. Efficient tax planning
enables you to reduce your tax liability to the minimum. This is done by
legitimately taking advantage of all tax exemptions, deductions rebates and
allowances while ensuring that your investments are in line with your long term
goals.

What tax planning is not...
Tax Planning is NOT tax evasion. It involves sensible planning of your
income sources and investments. It is not tax evasion which is illegal under
Indian laws.
Tax Planning is NOT just putting your money blindly into any 80C
investments.
Tax Planning is NOT difficult. Tax Planning is easy. It can be practiced by
everyone and with a very little time commitment as long as one is organized
with their finances.
Salaried individuals in India are not fully aware of the tax planning exercise which
is why they rush at the end of the tax-planning season and make investments to
reduce their tax liability. This has negative effect on tax payable by them and they
eventually end up paying more taxes than they are required to.








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METHODS OF TAX PLANNING

Some Tax-planning tips that can assist salaried people to reduce their tax
accountability are :-
1. Make full use of the entire Section 80C deduction - The maximum reduction
available in Section 80C is ` 100,000 and salaried citizens whose gross salary
is ` 250,000 or more are entitled to use the full ` 100,000 limit.

Individuals who make monetary infusions of over ` 100,000 in Section 80C in
selected areas fail to understand that the advantages are limited. In spite of
investing ` 70,000 and ` 40,000 in Public Provident Fund and ELSS
respectively, the amount entitled by the investor is only ` 100,000.

Following investments/contributions meet the criteria for Section 80C
reduction:

Public Provident Fund
Accrued interest on National Saving Certificate
Life Insurance Premium
National Saving Certificate
Tuition fees paid for children's education (maximum 2 children)
Principal component of home loan repayment
5-Year fixed deposits with banks and Post Office
Equity Linked Savings Schemes (ELSS)

2. Reduction of tax liability beyond Section 80C deductions - If your salary
surpasses ` 250,000 pa and the reductions under Section 80C are not enough to
minimize the general tax liability consider the following:
Home loan: Interest payments of upto ` 150,000 pa are entitled for
reduction under Section 24.
Medical insurance: A deduction of upto ` 15,000 pa under section 80D
is applicable under this.
Donations: Tax advantages under Section 80G entitle the donations to
particular funds/institutions.


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3. Assert tax advantages on house rent paid - If HRA is not included in the salary
structure then the salaried individuals can asset rent paid by them for residential
lodging. This reduction is accessible under Section 80GG and is smallest
amount of the following:
25% of the total earnings or,
2,000 every month or,
Surplus of housing charge paid over 10% of total salary.
4. Reorganize the salary - Reorganizing the salary and incorporating certain
apparatus can help in the long run in minimizing the tax liability. In order to
assert tax benefits salary reform is a more competent measure. The following
can be included in an individual's salary structure:
Food coupons can release up to ` 60,000 per year from tax.
Medical expenses which are compensated by the employer spare up
to ` 15,000 per year.
House Rent Allowance (HRA) should be incorporated in the salaries of
individuals who stay in rented houses
Transport allowance discharge upto ` 800 per month.
5. Go for a combined home loan - The primary reimbursement on a home loan is
entitled for a reduction of up to 100,000 pa and the interest rewarded is entitled
for a reduction of up to 150,000 pa. When a home loan is for a considerable
amount then the interest and chief reimbursement surpass the allotted limit. A
salaried individual can go for a combined joint home loan with his parent,
spouse or sibling, to guarantee the best utilization of tax advantages.
In this way both the owners can assert tax reductions in the percentage of their
stake holding in the loan.








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TAX
PLANNING
TAX
AVOIDANCE
TAX
EVASION
1. DEFINITION It is a way to
reduce tax liability
by taking full
advantages
provided by the
act through
various
exemptions,
deductions,
rebates
and relief.

It is an exercise by
which the assessee
legally takes
advantage of
the loopholes in
the Act.

It is the illegal way
to reduce tax
liability by
deliberately
suppressing
income or sale or
by increasing
expenses etc.,
which
results in reduction
of total income of
the assessee.

2. OBJECT To reduce tax
liability by
applying script
and moral of law.

To reduce the tax
liability to the
minimum by
applying the
script
of law only.

To reduce tax
liability by
applying unfair
means.
3. BENEFIT Generally, arises
in long run.
Generally, arises
in short run.
Generally, benefits
do not arise but it
causes penalty and
prosecution.

4. TREATMENT
OF LAW
It uses benefits of
the law.
It uses loopholes
in the law.

It overrules the
law.

5. PRACTICE It is tax saving.

It is tax hedging.

It is tax
concealment.

6. NEED It is desirable. It is avoidable. It is objectionable.

7. MORALITY It is moral in
nature.
It is immoral in
nature.
It is immoral in
nature.




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CONCLUSION

There is nothing which hurts more than payment of taxes. One question that goes
through every tax payers mind is how can I reduce my tax liability?
Reducing tax liability is not always a bad or illegal exercise. There are legitimate
ways to reduce taxes through proper tax planning and such methods are always
encouraged. But unfortunately, there is also a tendency to reduce tax through
illegal methods. They are not accepted practice and can invite problems.
After making the project, this is what we have understood as the meaning of all the
three concepts explained in detail earlier :-
1. Tax Evasion- Dishonest taxpayers try to reduce their taxes by concealing
income, inflation of expenses, falsification of accounts and willful violation of
the provisions of the Income-tax Act. Such unethical practices often create
problems for the tax evaders. Tax department not only imposes huge penalties
but also initiates prosecution in such cases.

2. Tax Avoidance- Tax avoidance is minimizing the incidence of tax by adjusting
the affairs in such a manner that although it is within the four corners of the
laws, it is done with a purpose to defraud the revenue. It is the act of dodging
without directly breaking the law. For example if A gives gift to his wife, the
income from the asset gifted will be clubbed in the hand of A. But to avoid this
clubbing provision A decides to give gift to Bs wife and B reciprocates it by
giving gift to As wife. This is not tax planning but tax avoidance.

3. Tax Planning- Tax planning is arrangement of financial activities in such a
way that maximum tax benefits, as provided in the income-tax act are availed
of. It envisages use of certain exemption, deductions, rebates and
reliefs provided in the act.





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BIBLIOGRAPHY