Comparison of section 243 "Power to transfer cases." between the Income-Tax Act, 2025 (as passed) and the Income-Tax Bill, 2025 (as originally introduced)

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....nt are affected. Effective dates: Not stated in the document. Background & Scope Statutory hooks: Clause/Section 243 (Power to transfer cases); related references to sections 241 and 242. The provision governs intra-departmental transfer of "cases" among Assessing Officers by a "specified income-tax authority". The Bill and the enacted text define "specified income-tax authority" as the Principal Director General or Director General or Principal Chief Commissioner or Chief Commissioner or Principal Commissioner or Commissioner. Definitions/explanations in the text: "case" is defined for purposes of section 241 and this section in both texts; the Bill lists three temporal categories in sub-clause (6) while the enacted section rephrases an....

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....ng after the order/direction in respect of any year. Sub-section (7) lists the offices that qualify as "specified income-tax authority". Interpretation Legislative intent and interpretive principles indicated by the text: Not stated in the document. The text itself emphasizes administrative flexibility (transfer at any stage), continuity of proceedings (no need to re-issue notices), and a measure of procedural fairness (reasonable opportunity to be heard "wherever it is possible to do so" and requirement to record reasons). The exception in sub-section (4) suggests a legislative intent to permit administrative convenience for local transfers. Any purposive interpretation must be grounded in the statutory wording provided. Exceptions/Prov....

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....the Board may notify. No cross-references to procedural rules for recording reasons or formats for hearings are provided in the text. Differences between the Clause 243 of the Income Tax Bill, 2025 (Old Version) and Section 243 of the Income-tax Act, 2025 * Sub-section (6) drafting: The Bill (Document 2) sets out three enumerated temporal categories for "case" - (a) pending on the date of the order/direction; (b) completed on/before such date; (c) be commenced after the date of such order or direction in respect of any year. The enacted Section (Document 1) restates the same substance in a single sentence: "means all proceedings under this Act in respect of any year, which may be pending on the date of such order or direction or whi....

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.... Practical impact: reduces risk of litigation over punctuation/interpretive anomalies, but does not change the operational ambit of what constitutes a "case". * Insertion of "in this behalf" (2)(b): This clarifies administrative competence of the Board to specify an alternative authority by notification. Practical impact: slightly strengthens the formal delegation language, but does not alter the Board's effective power; it may, however, assist in administrative delegation processes and in judicial review focused on vires/competence questions. * Stylistic wording changes (deemed/considered; punctuation): Likely no substantive effect. Practical impact: may marginally affect textual interpretation exercises, but courts will read the p....