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Taxation of Interest Income for Financial Institutions: Clause 56 of Income Tax Bill, 2025 vs. Section 43D of the Income Tax Act, 1961

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....x Bill, 2025 Introduction Clause 56 of the Income Tax Bill, 2025, introduces a special provision concerning the taxation of interest income related to bad or doubtful debts of specified financial institutions. This clause aims to delineate the conditions under which such interest income is to be taxed, marking a significant shift in how financial institutions report and manage their tax obligati....

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....ed Analysis Key Provisions * Tax Year Determination: Interest income related to bad or doubtful debts is taxable in the year it is credited to the profit and loss account or actually received, whichever is earlier. This provision ensures that financial institutions cannot defer tax liabilities indefinitely by delaying the recognition of income. * Definition of Specified Financial Institutions....

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....nterpretation of what constitutes "bad or doubtful debts" and the specific categories of NBFCs that might be notified by the Central Government. These areas may require further clarification through subsequent notifications or guidelines. Practical Implications Clause 56 has significant implications for financial institutions. By mandating the earlier of credit or receipt for tax purposes, insti....

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....s (with certain exclusions), State Financial Corporations, and State Industrial Investment Corporations. * Alignment with RBI Guidelines: Both provisions require the classification of bad or doubtful debts to be consistent with RBI guidelines. Differences * Scope of NBFCs: Clause 56 allows for the inclusion of additional classes of NBFCs as notified by the Central Government, whereas Section ....