Comparison of section 337 "Specified income." between the Income-Tax Act, 2025 (as passed) and the Income-Tax Bill, 2025 (as originally introduced)
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....ound & Scope Statutory hook: Clause 337 of the Income Tax Bill, 2025 (Old Version). The clause sets out a table enumerating categories of "specified income" of a registered non-profit organisation and prescribes the tax year in which each category is to be taxed. Definitions: The text does not provide standalone definitions for "registered non-profit organisation," "specified income," or other terms beyond the entries in the table. Not stated in the document: legislative purpose, explanatory notes, or effective date. Statutory Provision Mode Text & Scope Clause 337 lists 11 categories of income that qualify as "specified income" for registered non-profit organisations and assigns the taxable year for each category. The categories includ....
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....re expected. Not stated in the document: any legislative history or materials explaining the choice of triggers. Exceptions/Provisos The clause contains limited carve-outs: the anonymous donation rule excludes donations up to Rs.1,00,000 or 5% of total donations (whichever is higher) and exempts anonymous donations received by organisations "created or established wholly for religious purposes." No other explicit exceptions or provisos appear in Clause 337. Not stated in the document: any special thresholds for other items, or transitional provisions. Illustrations * Example 1: A registered non-profit organisation receives an anonymous donation of Rs.50,000 in a tax year and total donations in that year are Rs.10,00,000. Threshold (Rs.....
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....act: * Broader exclusion for religious organisations (anonymous donations): Document 1 excludes anonymous donations for organisations "created or established,- (i) wholly for religious purposes, or (ii) wholly for charitable and religious purposes (excluding anonymous donation made with a specific direction that such donation is for any university or other educational institution or any hospital; or other medical institution run by such registered non-profit organisation)." Document 2 excludes only organisations "created or established wholly for religious purposes." * Practical impact: Document 1 provides a narrower exception (it adds a carve-out for organisations "wholly for charitable and religious purposes" but then expressly exclud....
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....3 (fair market value of non-specified asset held beyond one year; any deemed application u/s 341(5) not actually applied within the period specified in section 341(6)). Document 2's table ends at item 11. * Practical impact: Document 1 expands the list of specified income events, creating additional contingencies where income will be taxed (e.g., failure to hold assets in specified forms/modes, failure to actually apply deemed application amounts abroad/time limits). This increases compliance exposures for registered non-profit organisations. * Variation in language for accumulated income utilisation (item 8): Document 1 describes "if it is not applied as per the provisions of section 341(1) to (4) for which it is accumulated or set....