Comparison of Section 200 "Tax on income of certain domestic companies." between the Income-Tax Act, 2025 (as passed) and the Income-Tax Bill, 2025 (as originally introduced)

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....clause (e.g., capital gain or certain Chapter VIII deductions). Effective date or decision date: Not stated in the document. Background & Scope The clause situates itself within the Income Tax Bill, 2025 and creates an elective new tax regime at a flat rate of 22% for domestic companies, subject to specified Parts of the Bill (Parts A, B and this Part) and excluding applicability to companies covered by sections 199 and 201. Definitions of terms used in this clause are Not stated in the document beyond the express cross-references to other sections (e.g., sections 45, 47, 116, 146, 205). The clause also addresses carry-forward and deemed deductions, and contains special provision for Units in International Financial Services Centres (IFSC....

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....efits-thereby broadening the tax base for opted companies. The text uses negative delineation (list of exclusions) rather than a positive list of allowed deductions. Interpretive principles indicated by the text: strict compliance with the timing and manner of option; causation for carry-forward restrictions (only losses attributable to excluded deductions are barred from set-off); permanence of the election once made (no subsequent withdrawal). Exceptions/Provisos The clause contains carve-outs: certain provisions under Chapter VIII (section 146) remain available despite the opting requirement. For IFSC Units, a modification ensures specific deductions (referred to elsewhere) remain available subject to that section's conditions. Pro....

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....r than sections 199 and 201) of this Chapter," whereas the Bill old version (Document 2) refers only to "Parts A, B and this Part, other than sections 199 and 201." * Practical impact: the Act expands the stated applicability by expressly adding "Part E" into the list of Parts that remain applicable. This could bring additional provisions in Part E into play for companies exercising the option; taxpayers and advisers must therefore check Part E for relevant constraints or qualifications that were not explicitly captured in the Bill text. * Differences in specific clause wording regarding deductions: Sub-clause (a)(i) in the Act omits the parenthetical "(c)" found in the Bill: the Bill lists "sections 45(2)(c) and 47(1)(b);" the Act list....

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....e base for an opting company. * Minor drafting and grammatical changes: Sub-section (4) in the Bill uses the phrase "the deduction under the said section shall be available"; the Act specifies "the deduction as referred to in section 147 shall be available." * Practical impact: the Act is more explicit in cross-referencing section 147. While this is clarificatory, it reduces uncertainty about which deduction is intended for IFSC Units. * Prescriptive/formatting differences in subsection (5): The Bill reads "in the such manner as prescribed"; the Act reads "in such manner as may be prescribed." * Practical impact: the Act's phrasing aligns with standard legislative drafting and avoids odd grammar; it retains the same substantive ....