Comparison of Section 143 "Special provisions in respect of certain undertakings in North-Eastern States." between the Income-Tax Act, 2025 (as passed) and the Income-Tax Bill, 2025 (as originally introduced)

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....sinesses for ten consecutive tax years starting from the initial tax year. It matters to taxpayers operating eligible businesses/units in the specified North-Eastern States and to the tax administration. Effective date or enactment date: Not stated in the document. Background & Scope Statutory hooks: Clause 143 (Bill) proposes a special deduction in respect of profits and gains of certain undertakings in the North-Eastern States. The provision references other statutory provisions - notably section 140(4), (5) and (6) (for re-establishment/reconstruction) and the second proviso to section 80-IB(4) of the Income-tax Act, 1961 - for interaction and limiting rules. Coverage: manufacturing/production of "eligible article or thing", substantia....

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....onditional quantitative benefit (100% deduction) subject to temporal, geographic and formation criteria. The text indicates legislative intent to incentivise industrial and service activity in the North-Eastern States for undertakings started in a discrete historical window (2007-2017). The reference to section 140(4) suggests Parliament intended to align the relief with pre-existing rules governing re-established undertakings, preventing arbitrary exclusion. The exclusivity clause (no deduction under any other section of this Chapter in relation to the profits and gains) evinces an intent to avoid double counting of deductions within the same Chapter. Exceptions/Provisos Carve-outs and conditions in the clause include: * Ineligibility ....

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....he qualifying period would begin the ten-year deduction period from the "initial tax year" defined as the tax year in which substantial expansion is completed. Interplay The clause expressly invokes sections 140(4)-(6) for treatment of certain formational exceptions and re-established entities, and it cross-refers to the second proviso to section 80-IB(4) of the Income-tax Act, 1961 for aggregate duration limits. No other Rules/Notifications/Circulars are cited in the clause text. Potential interpretive issues (from the text): the precise effect of the cross-reference to section 140 provisions and operationalising the ten consecutive years where an undertaking previously claimed another relief are to be determined by reference to those pr....

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....3)(a) (mirroring section 140(4) language). * Practical impact: Substantively similar, but drafting differs-Document 2 expresses the exception as a standalone clause, which may be clearer in the bill form; the Act embeds the exception within clause (3)(a). No clear substantive divergence in eligibility is evident from the texts themselves. * Typographical/wording differences: Document 2 contains a typographical truncation ("bio-technolog;") and slightly different punctuation/word order in certain subsections (e.g., placement of commas and "and"). * Practical impact: Primarily drafting/typographical; the Act text corrects such errors. Absent substantive amendments, these do not alter legal effect other than clarity. * Other difference....

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....he document.) Key Takeaways * The provision grants a 100% deduction of profits and gains from eligible activities in North-Eastern States for ten consecutive tax years starting from the "initial tax year". * Eligibility is confined to undertakings begun (or substantially expanded) within a discrete window (1 April 2007 to 1 April 2017 as per the Bill text) - timing is determinative; any variance in the terminal date materially affects eligibility for undertakings commencing on 1 April 2017. * Formation conditions bar benefits to undertakings formed by splitting/reconstruction or by transfer of used plant/machinery, subject to exceptions aligning with section 140 provisions. * Certain goods (tobacco, pan masala, specified plastic ba....