Comparison of Section 49 "Site Restoration Fund" between the Income-Tax Act, 2025 (as passed) and the Income-Tax Bill, 2025 (as originally introduced)

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....tment timing: Not stated in the document. Background & Scope Statutory hooks: Clause 49 in the Income Tax Bill, 2025 (old version) falls under Profits and gains of business or profession. The clause establishes a Site Restoration Fund mechanism for entities carrying on prospecting, extracting, or producing petroleum or natural gas in India who have an agreement with the Central Government. The clause provides for (a) deduction for deposits into a special account or the site restoration account computed as per Schedule X; (b) taxation on amounts withdrawn or transferred; and (c) a deeming provision for sale/transfer of assets acquired under the scheme within eight years. Definitions or further explanations are not provided in the clause it....

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....riod. The clause expressly ties computation and timing rules to Schedule X, indicating legislative intent to set detailed procedural and computational matter in the schedule. The eight-year holding period in Sub-section (3) is an explicit anti-abuse/time-based recapture rule. Exceptions/Provisos Not stated in the document. Illustrations * Example 1 (deposit and later withdrawal): An assessee deposits sums into the site restoration account and claims a deduction under Sub-section (1). If the assessee later withdraws funds from the account at closure, the withdrawn amount will be charged to tax in the year of withdrawal in accordance with Schedule X. (This is a direct reading; numerical computation method is Not stated in the document.....

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....the basis of deposit to special account or site restoration account and computed as per the provisions of the Schedule X." The Bill used slightly different punctuation and included the phrase "the site restoration account." * Practical impact: Largely stylistic; both link computation and deduction to Schedule X. No substantive difference beyond form. * The Bill (Clause 49(3)) contains a specific deeming rule: if an asset acquired under "the scheme or the deposit scheme" is sold or transferred by the assessee within eight years from the end of the tax year of acquisition, then "such part of the cost of such asset as is relatable to the deduction allowed under sub-section (1) shall be deemed to be the profits and gains of business or prof....

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....e details; under the Bill some essential consequences were available in the clause itself. This changes where practitioners will look for operative rules and may affect transitional, interpretive and timing questions. Practical Implications * Compliance and risk areas: Taxpayers must maintain clear records evidencing deposits into the special/site restoration account and any subsequent withdrawals or transfers, and must track the acquisition date of assets purchased under the scheme to determine whether the eight-year recapture window applies. Calculation of the "part of the cost relatable to the deduction" is a material compliance issue; the clause presumes such computation but does not prescribe a method (computation rules are delegate....