Comparison of section 295 "Undisclosed income of any other person." between the Income-Tax Act, 2025 (as passed) and the Income-Tax Bill, 2025 (as originally introduced)

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.... & Scope Statutory hooks: Clause 295 appears under the heading "Special procedure for assessment of search cases" in the Income Tax Bill, 2025 (Old Version). The clause deals with handover of seized items and consequent assessment of a person other than the one in respect of whom search or requisition was made. Definitions or explanations: Not stated in the document beyond the operative wording; the clause does not define "other person" or "specified person" explicitly within the text presented. Statutory Provision Mode Text & Scope The clause applies where an Assessing Officer is satisfied that any undisclosed income "belongs to or pertains to or relates to any person, other than the person with respect to whom search was initiated or ....

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....ocument.) Exceptions/Provisos Carve-outs, thresholds, conditions: Not stated in the document. The clause contains no provisos, conditions, timelines or thresholds governing the handover, transfer, or scope of assessment in the Old Version provided. Illustrations * Example 1: A search at A's premises yields jewellery that the AO is satisfied belongs to B. Under Clause 295, the jewellery and related documents shall be handed to the AO having jurisdiction over B, and B shall be assessed u/s 294. (The clause gives the procedural instruction; details of valuation, timing or abatement are Not stated in the document.) * Example 2: Digital wallets seized from C contain virtual digital assets tied to D. The seized assets and any books or ....

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....ay affect interpretive emphasis when deciding what must be handed over. * Destination of seized material and procedural detail: Both versions require handing over seized items to the Assessing Officer (AO) having jurisdiction over the "other person." The enacted Section 295 (Document 1) adds procedural sequencing: the AO of the other person "shall proceed u/s 294" (similar to Bill) but the enacted text explicitly states "and the provisions of this part shall apply accordingly." The Bill used "the provisions of this Chapter shall apply accordingly." * Practical impact: Change from "Chapter" to "part" is terminology-may affect internal cross-references within the statute but does not materially change the procedural effect unless "part" a....

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....ginal search/requisition date-provides a new, objectively ascertainable date for limitation calculations for the other person's assessment. * Cross-reference precision: The enacted version refers to "section 247" and "section 248" as the search/requisition provisions; the Bill's text refers generically to "with respect to whom search was initiated or requisition was made." * Practical impact: Minimal, but the enacted text's explicit cross-references aids legal clarity and statutory navigation. Practical Implications * Compliance and risk areas: The clause mandates AOs to identify whether seized items pertain to persons other than the searched person and to hand over such items. AOs must be careful in making the factual sa....