Section 28 - Insertion of new sections 115BBH and 115BBI.

Virtual digital asset taxation: flat-rate tax on transfers with denial of deductions and loss set-off, plus institutional specified income rules.

Imposes a separate taxation mechanism taxing income from transfer of virtual digital assets at a flat thirty per cent and then recalculating tax on the remaining income as if that income were excluded; disallows deductions, allowances, set-off of losses (except cost of acquisition) and carry-forward of losses for such transfers. Similarly, treats certain institutional accumulations and deemed incomes as specified income subject to a thirty per cent tax with no deductions or set-offs, and defines specified income to include excess accumulations and incomes rendered non-exempt by applicable provisions.