Comparison of Section 206 "Special provision for minimum alternate tax and alternate minimum tax." between the Income-Tax Act, 2025 (as passed) and the Income-Tax Bill, 2025 (as originally introduced)

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.... Minimum Tax (AMT) for non-company persons, prescribing deemed total income and minimum rates, computation mechanics for book profit/adjusted total income, credit, carry-forward, exclusions, and compliance obligations (accountant's certificate). Definitions related to convergence to Indian Accounting Standards (IND AS), transitional adjustments, "Unit" (IFSC), "Tribunal", "Adjudicating Authority", and others are included. The text supplies procedural and substantive items to be added to or reduced from book profit or adjusted total income. Statutory Provision Mode Text & Scope The provision makes the following principal rules: (a) where tax computed under general provisions is less than a prescribed percentage of book profit (company....

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....rovisos The Bill lists multiple exceptions: exclusions for certain companies (life-insurance business), taxpayers who opted under various procedural sections (200(5), 201(2), 203(5), 204(2)), taxpayers assessed u/s 202(1), small taxpayers with adjusted total income not exceeding INR 20 lakh, specified funds (Schedule VI), foreign companies meeting certain treaty/residence/PE criteria, and conversions to LLP where successor LLP is exempt from carry-forward rules. Specific carve-outs exist for transactions involving business trusts, demergers, insolvency cases, and sick industrial companies. Where missing details (e.g., prescribed form specifics, prescribed manner of recomputation) the text states procedural application "as prescribed" and d....

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....Overall, the Act text (Document 1) is a finalized and more detailed statutory enactment, while the Bill text (Document 2) is an earlier draft with a different structural presentation and some substantive drafting differences. The principal differences and their practical impacts are summarised below. * Presentation of rates and scope: The Bill (Document 2) presents taxpayers and rates in a consolidated table (Sl. Nos. 1-5) tying percentages directly to categories of assessees (companies, units in IFSC, co-operative societies, others). The Act (Document 1) separates company provisions (sub-section (1)(a)-(c)) and non-company AMT (sub-section (2)), specifying different rate sets (companies: 15%/9%; non-companies: 18.5%/15% for co-ops/9% for....

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....ions differ; practitioners will need to follow the enacted provision (Act) which may have slightly different mechanics for the "transition amount" and IND AS items. * AMT for non-companies - deductions included/excluded: The Bill's Note 1 (to the main Table) lists deductions to be added back (including section 144) whereas the Act's sub-section (2)(b)(i) lists Chapter VIII-C deductions (other than section 149) and section 46 as reduced by depreciation. Document 1 does not mention section 144 in that clause; Document 2 explicitly includes section 144. * Practical impact: inclusion or exclusion of section 144 (carry-forward type provisions under specific heads) affects which taxpayers are caught by AMT and the quantum of adjusted ....

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....ss tax paid and specify 15-year limitation; both disallow interest on credits and ignore excess foreign tax credits. The placement and cross-reference numbering differ (Act uses clauses (m)-(p) for company MAT credit; Bill uses sub-sections (13)-(16)). * Practical impact: no substantive divergence on credit mechanics, but cross-referencing and procedural nuance is governed by the enacted text. * Additional miscellaneous drafting differences: The Act contains specific additional sub-clauses addressing corporate insolvency, Tribunal nominations, demerger/LLP conversion exceptions, and explicit definitions in clause (t). The Bill contains analogous provisions under sub-section (19). * Practical impact: largely parallel, but small textual....