Comparison of section 267 "Tax on updated return." between the Income-Tax Act, 2025 (as passed) and the Income-Tax Bill, 2025 (as originally introduced)
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....d the tax department administering collection. Effective or operative dates are not stated in the document beyond a temporal limit for guideline issuance (two years from 1 April, 2026). Background & Scope Statutory hook: Clause 267 of the Income Tax Bill, 2025, dealing with "Tax on updated return" and interaction with proposed section 263 (filing of returns and processing). Coverage: situations where a taxpayer has not previously furnished a return u/s 263(1) or (4) or where an earlier return u/s 263(1), (4) or (5) has been furnished but a later updated return under 263(6) results in tax being payable. The text establishes payment obligations, the set-off of certain amounts, computation of an "additional income-tax" as a percentage of tax....
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....dicating an intent to secure revenue before allowing assessment processes to proceed. The cross-references to reliefs and credits show an intent to net off amounts already allowed or claimed so that additional tax is computed on the net tax liability arising on the updated return. Exceptions/Provisos The clause contains several carve-outs and conditions: certain credits or relief already claimed in an earlier return are to be taken into account (sub-section (4) lists such items) and tax already paid as advance tax, TDS/TCS, and foreign tax reliefs are to be deducted (sub-section (2)). Interest paid in an earlier return reduces the additional income-tax computation (sub-section (3)(b)). There is an administrative proviso conferring power o....
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....ared in the updated return after taking into account specified credits and as increased by any refund on the earlier return. The Board's guideline power (with a two-year issuance window) will affect administration of these interactions. Differences between the two provisions and practical impact * Reference to tax credit provisions (206(1)(m)-(p), 206(2)(e)-(h) versus section 206(13)) - Document 1 (Section 267) refers specifically to tax-credit provisions in sections 206(1)(m) to (p) and 206(2)(e) to (h) in sub-sections (2)(f), (4)(e) and (7)(a)(v). Document 2 (Clause 267, Bill) instead refers broadly to "section 206(13)" in the parallel places. * Practical impact: the Bill's cross-reference condenses multiple specific sub....
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....inor drafting and terminological differences - Document 1 uses expressions such as "amounts referred to in sub-section (2)" and "the amounts referred to in sub-section (3)" while Document 2 alternates with "The sums referred to in sub-section (3)" and retains "amounts" elsewhere. * Practical impact: largely drafting in style only; no substantive legal change apparent from these wording differences alone. * Order and numbering of subsections toward the end - Document 1 contains provisions numbered through (11), with distinct mechanics in sub-section (10) and (11). Document 2 extends numbering to (12) (with comparable content but slightly different clause-lettering at the end). * Practical impact: numbering differences could a....