Tax on Accreted Income - Section 352 (New) / Section 115TD, 115TE, 115TF (Old)

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....additional income-tax on accreted income at the maximum marginal rate in the cases specified in the Table under section 352(4). The levy is therefore distinct from the normal tax liability on the total income of the specified person. Section 352(2) - Computation of Accreted Income Accreted income is computed according to the formula: A = B − C where: • A = accreted income; • B = aggregate fair market value of the total assets of the specified person as on the relevant specified date; and • C = total liability of the specified person as on that specified date. The fair market value of assets and the liabilities are to be determined in accordance with the method of valuation....

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....pecified person has not preferred an appeal: • Specified date: date of the order cancelling registration. • Due date: date on which the period for filing an appeal under section 362 expires. Table Sl. Nos. 3 to 5 - Modification of Objects These entries deal with a specified person that: • adopts or undertakes modification of its objects during a tax year; and • the modified objects do not conform to the conditions of registration. The consequences depend upon whether the specified person: • does not apply for fresh registration; • applies for fresh registration, the application is rejected and an appeal is preferred; or • applie....

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....l. No. 7 - Conversion into an Ineligible Form Where a specified person converts itself into a form which is not eligible for grant of registration during a tax year: • Specified date: date of conversion. • Due date: end of that tax year. Table Sl. No. 8 - Impermissible Merger The tax applies where the specified person merges with: • an entity other than a registered non-profit organisation; • a registered non-profit organisation having the same or similar objects, where prescribed merger conditions are not fulfilled; or • a registered non-profit organisation which does not have the same or similar objects. Both the specified date and due date are the date....

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....er section 352. The following persons are deemed to be assessees in default: Section 352(7)(a) • the specified person; and • the principal officer or trustee of the specified person. Section 352(7)(b) The person to whom an asset forming part of the computation of accreted income has been transferred, where the tax becomes payable under Table Sl. No. 9, i.e., the dissolution case. Section 352(8) - Limitation of Recipient's Liability In the dissolution case, the liability of the person receiving the transferred asset is limited to the extent to which the asset received is capable of meeting the tax liability. Comparative Analysis: Section 115TD, 115TE, 115TF of the Income-tax Act, 1961 vs....

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....nces where the prescribed application for registration is not made. Table Sl. No. 6 expressly covers failure to make specified applications under the 1961 Act and section 332(3) of the 2025 Act. Conversion Provides for consequences where the entity is converted into a form which is not eligible for registration. Table Sl. No. 7 expressly covers conversion into an ineligible form. Merger Contains provisions concerning merger in specified circumstances. Table Sl. No. 8 specifically deals with impermissible mergers with other entities or NPOs having dissimilar objects or failing prescribed conditions. Dissolution Provides for tax on accreted income where assets are not transferred upon dissolution in a....