Comparison of section 288 "Other amendments" between the Income-Tax Act, 2025 (as passed) and the Income-Tax Bill, 2025 (as originally introduced)

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....ive dates or decision dates: "From the end of the financial year" or "from the end of the year" as specified in each table entry (exact effective dates tied to triggering events are stated per row). Background & Scope Clause 288 (Other amendments) interacts with section 287(8) (limitation), sections 35, 67-71 (capital gains), sections 78 (stamp duty valuation), 111-115 (carry forward and set off provisions), section 144 (deduction for income received in foreign exchange), section 270(1) (intimations), section 279 (recomputation), section 166 and 275 (transfer pricing), Chapter XIX-B (TDS), and the Patents Act, 1970. The clause supplies a table enumerating specific actions an Assessing Officer may take, the conditions triggering those acti....

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....s are tied to concrete events (end of the financial year in which the subsequent order was passed; end of the year in which a conversion/cessation occurs; three-month windows for TP recomputation). The text indicates Parliament's intent to permit retrospective alignment of assessments where downstream developments (court orders, reassessments, valuation revisions, patent revocation, settlement of foreign tax disputes) alter the factual or legal basis of earlier assessments. The provision repeatedly applies the procedural safeguards of section 287 "so far as may be" to the listed amendments. Exceptions/Provisos Explicit provisos include time-limits: generally within four years referred to in section 287(8) reckoned from specified event....

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....nformity with the TPO's arm's length determination within the prescribed three-month window. Interplay The Clause cross-references numerous assessment, revision and recomputation provisions (sections 279, 287, 166, 165, 270, 275) and the Patents Act. It expressly subjects amendments to the procedural rules of section 287 "so far as may be" and signals interaction with Chapter XIX-B (TDS) and Chapter IX-B (specified territories for foreign tax credit). Potential procedural dependencies (for example, the effect of an order u/s 245D(4) of the Income-tax Act, 1961) are incorporated as triggering events for amendment. Differences between (Document 1) Section 288 of the Income-tax Act, 2025 and (Document 2) Clause 288 of the Income Tax....

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.... case of the firm" for other entries and, for Serial No.4, "From the end of the financial year in which the order revising the value was passed..." and similar. There is slight variation in wording (year vs financial year) across entries. * Practical impact: The distinction between "year" and "financial year" can affect the limitation period reckoning. Clarity that the reckoning is from end of the financial year is important for time-bar considerations; any inconsistency may create interpretive disputes on when the four-year window starts. * Serial numbering and an added/modified serial (Serial No.12 in Bill): Document 2 (Bill old) contains a Serial No.12 expressly dealing with recomputation for two consecutive tax years following a Tra....

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....of conditions (for example, Document 2 often uses dashes and parentheses differently). These are drafting-level changes rather than clear substantive shifts. * Practical impact: Mostly interpretive/clarificatory; however, precise punctuation or connective language in tax statutes can affect interpretation in edge cases, so practitioners should rely on the enacted (Act) text for authoritative application. Practical Implications * Compliance and risk areas: Taxpayers with inter-party allocations (partners, AOP/BOI members), carry forwards for losses/depreciation, foreign income or foreign tax credits, patents, and those involved in compulsory acquisition or government/RBI price approvals face targeted reassessment risk when downstream or....