Comparison of Section 201 "Tax on income of new manufacturing domestic companies." between the Income-Tax Act, 2025 (as passed) and the Income-Tax Bill, 2025 (as originally introduced)

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.... domestic companies engaged in manufacture/production and the tax administration. Effective/decision date: Not stated in the document. Background & Scope The clause is framed as part of an Income Tax Bill, 2025. Statutory hooks referenced within the clause include Parts A, B and this Part of the Chapter (with an express exception for sections 199 and 200), and multiple provisions across the Income-tax enactment (sections 45(2)(c), 47(1)(b), Chapter VIII except sections 146 and 148, section 205(1)(a) to (g), section 116(1), section 205(4), section 205(2), and section 263(1) for due dates). The provision is limited to "a domestic company engaged in business of manufacture or production of any article or thing," and creates an option for suc....

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....ons. The "irrespective of anything contained in this Act" opening indicates a stand-alone/comprehensive computation model, constrained only by specified Parts and sections. The requirement that certain incomes be taxed at fixed percentage rates, and the prohibition in clause (b) on any deduction or allowance for the 22% category, indicate an intent to simplify/compress the tax base for qualifying incomes. The option mechanism and the non-withdrawable nature (sub-section (2)(c)) suggest a durable election once validly made. Exceptions/Provisos Key carve-outs and conditions include: * Temporal eligibility: set-up and registration on or after 1 October 2019; commencement of manufacturing/production on or before 31 March 2024. * Computati....

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....teracts with multiple other sections and Parts: it disapplies general provisions except as noted and requires computation "as per the provisions of sub-section (3)" which cross-references sections 45(2)(c), 47(1)(b), Chapters and specified parts of section 205, and section 116(1). It also refers to section 205(4) for deemed income at the 30% rate and to section 205(2) in eligibility. The option exercise due date is linked to section 263(1). The Bill itself does not include other notifications, rules or circulars; if any such instruments exist, they are Not stated in the document. Differences between the two provided provisions and Practical Impact Comparison of the two documents (Section 201 - final statute as shown at Document 1, and Cla....

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....nding on whether specific rates are in Parts A/B/E. * Specific cross-references and subsection numbering: The Bill lists "sections 45(2)(c) and 47(1)(b)" while the later text lists "section 45(2) or 47(1)(b)." The Bill cites "Chapter VIII other than sections 146 and 148" (plural) while the later text says "Chapter VIII other than section 146 or 148" (singular/or). The Bill refers to "section 205(1)(a) to (g)" (as a range) whereas the later text uses "sections specified in 205(1)(a) to (g)." The Bill cites "section 116(1)" whereas the later text cites "section 116." * Practical impact: These are drafting/precision differences. Where a specific sub-clause is cited in the Bill (e.g., 45(2)(c)), that confines the exclusion to that sub-claus....

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....ishing the nature of income (manufacturing versus non-manufacturing), allocation studies to show whether losses or depreciation are attributable to excluded deductions, and records evidencing exercise of the option within the prescribed manner and deadline. Specific forms/procedures for exercise are Not stated in the document. Key Takeaways * Clause 201 offers an elective concessional tax computation for newly set-up domestic manufacturing companies with fixed percentage tax rates for categories of income. * The option is time-sensitive, irrevocable once exercised, and may be invalidated upon failure to meet conditions in any year. * Certain deductions and set-offs are excluded when computing total income for purposes of the regime; ....