Comparison of Section 92 "Income from other sources." between the Income-Tax Act, 2025 (as passed) and the Income-Tax Bill, 2025 (as originally introduced)

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....ot stated in the document. Background & Scope Statutory hook: Clause 92 of the Income Tax Bill, 2025 (F. - Income from other sources). The clause provides a non-exhaustive list of items chargeable under the head "Income from other sources" where such receipts are not chargeable under other specified heads (section 13(a)-(d) referenced). The provision contains definitions and exclusions to determine when particular receipts-dividends, gambling winnings, gifts, insurance proceeds, certain receipts by unit holders, compensation and interest-fall within this head. Specific definitions for terms such as "assessable", "card game and other game of any sort", "fair market value", "jewellery", "lottery", "property", "relative" and "unit linked ins....

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....market value", "specified banking or electronic modes" via other sections). The presence of detailed subclauses and defined terms indicates an intent to reduce ambiguity by specifying categories and valuation/payment mechanics. Interpretive principles indicated by the text: literal application of specified tests (thresholds, modes of payment, valuation dates) and deference to cross-references for technical definitions. Exceptions/Provisos Key carve-outs and conditions include: * Life insurance receipts: unit linked policies and Keyman insurance receipts are excluded from clause (l) (treated separately); excess over aggregate premiums (not claimed as deduction) is taxable, "computed in such manner, as prescribed." * Gifts and property ....

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.... the resulting amount is taxable under this clause subject to exceptions for items characterised under Schedule V or section 223(2). Interplay The clause expressly interacts with multiple other provisions: section 13(a)-(d) (other heads), Schedule II (insurance tables), Schedule V, section 223(2) (tax treatment of certain distributions), section 278(1) (compensation interest), section 66(32) or equivalent (specified banking/online modes - Bill defines payment modes explicitly), section 70(1) (transactions not regarded as transfer), sections 78(2) and 288 (valuation procedures), section 355 (definition/conditions for non-profit organisations), and other undefined prescribed rules for valuation and computation. The clause therefore operates....

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....yment modes compared with the Bill's enumerated list and will centralise future changes in the definition rather than amending section 92 each time. * Formatting and drafting differences in subsection (3)(f)/(g) proviso cross-references: The Bill's proviso (3)(f) refers to section 355(g) and excepts when received by any person referred to in section 355(i). The Act refers to section 355(g) and excepts when received by any person referred to in section 355(h). * Practical impact: if sections 355(h) and 355(i) denote different classes, the scope of the exemption for registered non-profit organisations will change; one must consult the final Act's section 355 to determine which persons remain taxable. * Subsection (3)(g) list....

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....differences; the Act appears intended to clarify inclusions, which reduces disputes on familial coverage for gifts/exemptions. Practical Implications * Compliance hotspots: accurate identification of the head under which a receipt is taxable (e.g., business profits v. other sources v. salaries), documentation to prove payment modes for immovable property agreements, and adherence to thresholds for gifts/property to avoid unintended taxation. * Record-keeping/evidence: retain agreements, payment instrument records (account payee cheques/drafts, ECS or prescribed electronic mode confirmations), valuation reports or stamp duty valuation records, records of unit issue price and earlier taxed amounts (for business trust calculations), insur....