Provisions Relating to Expenditure Disallowance for Non-Taxable Income: comparing Clause 14 of Income Tax Bill, 2025, with Section 14A of Income-tax Act, 1961

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....n to such income. Income Tax Bill, 2025 1. Introduction Both provisions deal with the disallowance of expenditure incurred in relation to income that doesn't form part of total income under respective Acts. The provisions aim to ensure that expenses related to tax-exempt income are not claimed as deductions against taxable income. 2. Structural Analysis 2.1 Basic Framework * Both provis....

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....thods, but the 2025 Bill's language is more direct 3.3 Sub-section (3): Temporal Application Key Differences: * The 2025 Bill incorporates the essence of the Explanation from the 1961 Act into the main provision * Uses "tax year" instead of "previous year" * Removes the deeming fiction present in the 1961 Act's Explanation 4. Significant Omissions in 2025 Bill * 1. Proviso regar....