Comparison of Section 212 "Interpretation." between the Income-Tax Act, 2025 (as passed) and the Income-Tax Bill, 2025 (as originally introduced)

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.... Background & Scope Statutory hook: the definitions are expressly stated to apply "In sections 213 to 218" (Bill/Act). The provision supplies definitional scaffolding for Chapter XIII-E (as the Bill notes) or the corresponding enacted sections. The clause/section enumerates defined terms: "foreign exchange asset", "investment income", "long-term capital gains", "non-resident Indian" and "specified asset". The texts otherwise mirror each other except for the statutory cross-reference used in sub-clause (e)(iv): the Bill (old version) cites section 2(c) of the Public Debt Act, 1944; the enacted Section cites section 2(f) of the Government Securities Act, 2006. No further definitions or interpretive guidance appear in the documents. Statutor....

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....isition to the asset's classification. "Investment income" is defined very broadly as any income derived from a foreign exchange asset, without qualification or sub-categorisation in the text. "Long-term capital gains" are defined by reference to the head "Capital gains" and the usual short-term/long-term distinction (i.e., a foreign exchange asset that is not a short-term capital asset). The definition of "non-resident Indian" follows a residency-plus-identity formulation (not resident + citizen or person of Indian origin), rather than a residency-only test. Legislative intent beyond the literal definitions is Not stated in the document. Exceptions/Provisos There are no provisos, carve-outs, or thresholds in the text other than the ....

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....-the Bill's Public Debt Act reference or the Act's Government Securities Act reference. The documents do not state the substantive difference between those definitions. Interplay The text expressly interacts with other statutes by reference: the Companies Act, 2013 (definition of "private company") and either the Public Debt Act, 1944 or the Government Securities Act, 2006 for the definition of Central Government securities. There is also an express delegation to the Central Government via notification for adding assets to the list. Interaction with rules, notifications, or circulars beyond the notification power is Not stated in the document. Differences Between the Two Texts and Practical Impact * Sub-clause (e)(iv) differs. ....

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....cial provisions in sections 213-218. The documents do not state transitional rules; therefore transitional or retrospective implications are Not stated in the document. * Record-keeping/evidence: Because "foreign exchange asset" is predicated on acquisition "with, or subscribed to in, convertible foreign exchange", taxpayers should retain contemporaneous evidence of the currency and source of funds used to acquire specified assets (e.g., remittance records, forex conversion documents, bank receipts). The text itself does not set out required records or documentary tests; those procedural requirements are Not stated in the document. * Notification risk: Clause (e)(v) permits the Central Government to augment the list of specified assets ....