Comparison of Section 93 "Deduction" between the Income-Tax Act, 2025 (as passed) and the Income-Tax Bill, 2025 (as originally introduced)

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....ctive date or decision date: Not stated in the document. Background & Scope Statutory hook: Clause 93 of the Income Tax Bill, 2025 - dealing with computation of taxable income under the head "Income from other sources." Context: Specifies permissible deductions and limitations when computing taxable income under that head. Coverage: Enumerates deductions for (a) amounts paid as commission/remuneration for realising dividends or interest on securities; (b) particular incomes referenced in section 92(2)(c) with reference to section 29(1)(e); (c) incomes referenced in section 92(2)(f) and (g) with reference to sections 28(1)(a),(b),(d), 28(2) and 33; (d) family pension with specified amounts limited by whether tax is computed u/s 202(1); (e)....

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....u/s 202(1); (ii) one-third of such income or Rs. 15,000, whichever is less, in any other case. * Clause (e): Any other expenditure (not capital) laid out wholly and exclusively for making or earning such income. * Clause (f): For income of the nature in section 92(2)(i) - deduction equal to 50% of such income and no other deduction shall be allowed under this section. * Sub-section (2)(a): For dividend income of the nature in section 2(40)(f), no deduction allowed. * Sub-section (2)(b): For other dividend income or income from specified mutual fund units or units of a specified company under the Unit Trust of India (Transfer of Undertaking and Repeal) Act, 2002 - only deduction allowed is interest expense limited to 20% of such inco....

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....mission to realise dividend from listed securities (not covered by section 2(40)(f)). That reasonable commission is deductible under clause (a). (No numerical figures stated in the text; the allowance depends on reasonableness.) * Example 2 - Family pension: A family pensioner receives Rs. 30,000 in the year and tax is not computed u/s 202(1). The allowable deduction under clause (d)(ii) is one-third of Rs. 30,000 = Rs. 10,000, subject to the cap of Rs. 15,000; therefore deduction is Rs. 10,000. (This example uses the numerical caps provided in the text.) * Example 3 - 50% deduction: An assessee receives income of the nature in section 92(2)(i) amounting to Rs. 100,000. Under clause (f) deduction allowed equals 50% = Rs. 50,000, and no ....

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....e Bill's old text. * Clarification of clause (a) punctuation/scope: In the enacted Section 93 clause (a) the bracketed exclusion is placed as "for dividends [excluding those referred to in section 2(40)(f)] or interest on securities, any reasonable sum..." In the Old Version clause (a) the bracket appears to run "for dividends [excluding those referred to in section 2(40)(f) or interest on securities, any reasonable sum..." - which creates a punctuation/parenthetical ambiguity. * Practical impact: The enacted text more clearly excludes only the dividends referred to in section 2(40)(f) from the deduction-qualifying income, while the Old Version's punctuation could be read ambiguously to exclude "interest on securities" from the ....