Comparison of section 225 "Income from business of operating qualifying ships." between the Income-Tax Act, 2025 (as passed) and the Income-Tax Bill, 2025 (as originally introduced)

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....art (the tonnage/ship scheme) and to deem that income as profits and gains of business or profession. The enacted version, however, adds an express carve-out-"except 50 and 53"-to the non-application clause. The provisions affect companies in the shipping industry; the effective date/decision date is Not stated in the document. Background & Scope Statutory hooks: Clause/Section 225 is placed under "G.- Special provisions relating to income of shipping companies" within the Income Tax Bill/Income-tax Act, 2025. The provision addresses computation and characterization of income from the business of operating qualifying ships. Definitions or explanations for the terms "qualifying ships", "this Part", or the referenced sections (26 to 54, and....

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....on method for ship-operating companies and to ensure that income so computed is treated as business income. The phrase "Irrespective of anything contained in sections 26 to 54" indicates that the special computation is intended to displace ordinary provisions applicable to computation and heads of income in that range, subject to the stated exceptions in the enacted version. The express deeming of such income as "profits and gains of business or profession" clarifies classification for charging to tax. Exceptions/Provisos Enacted text: expressly excludes sections 50 and 53 from the non-application clause ("except 50 and 53"). Bill old version: no such exception. The documents do not state the contents or subject matter of sections 50 and ....

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....ective pathway for computation. Taxpayers must determine whether to exercise the option. The documents do not state any procedural conditions, timelines for election, or interaction with returns-Not stated in the document. The enacted exception for sections 50 and 53 means that certain provisions in the range 26-54 may continue to apply even where the tonnage/ship scheme is chosen; the exact compliance risks depend on the subject-matter of those sections (Not stated in the document). * Record-keeping/evidence: The text does not prescribe record-keeping requirements, but the deeming of income as business income suggests taxpayers should maintain records adequate to support computation under "this Part". Specific documentary requirements, s....

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....xt, sections 50 and 53 continue to apply to companies electing the ship regime, preserving whatever substantive rules those sections contain. Under the bill old version those sections would have been wholly overridden for ship operators. Because the content of sections 50 and 53 is Not stated in the document, the concrete operational consequences of the exception cannot be specified here. * Explanatory note: The Bill old version includes a short explanatory sentence describing the purpose (tonnage tax option). The enacted text omits this note. * Practical impact: The explanatory sentence in the bill provides legislative context that may aid interpretation, but its absence in the enacted provision does not alter the substantive legal eff....