Comparison of section 352 "Tax on accreted income." between the Income-Tax Act, 2025 (as passed) and the Income-Tax Bill, 2025 (as originally introduced)

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....ssolution, etc.), affecting registered non-profits, their trustees/principal officers and transferees of assets. Effective date or decision date: Not stated in the document. Background & Scope Statutory hooks: Clause 352 of the Income Tax Bill, 2025. Context: the clause proposes a special charging provision titled "Tax on accreted income" targeting specified persons when certain triggering events occur (e.g., cancellation/withdrawal of registration, modification of objects inconsistent with registration, failure to apply for registration, conversion, merger, dissolution, and prescribed non-compliances). Coverage includes the specified person and principal officer or trustee; in limited circumstances, asset transferees can be deemed assess....

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....ication of objects, failure to seek registration, disqualifying mergers, and incomplete transfers on dissolution as events triggering a wealth-like charge (an anti-abuse/exit taxation on net assets). The use of fair market value and prescribed valuation methods signals an intent to tax economic accrual rather than book results. The provision of a hearing via the Assessing Officer before charging suggests a procedural safeguard consistent with principles of natural justice in tax assessment. Exceptions/Provisos No express exceptions or provisos beyond the reduction of accreted income "attributable to specified assets, and liabilities, if any, related to such assets." Specific carve-outs, thresholds or exemptions are Not stated in the docum....

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....e of existing recovery and default mechanisms. Differences between the two texts and practical impact Comparison of Section 352 (Document 1 - Income-tax Act, 2025) and Clause 352 (Document 2 - Income Tax Bill, 2025 - Old Version) reveals the following material differences and likely practical impacts: * Authority to compute accreted income: Document 2 (Bill, old version) expressly empowers the Assessing Officer to compute accreted income after affording a reasonable opportunity of being heard (sub-section (2) of the Bill). Document 1 (enacted Section) omits any express provision vesting computation with the Assessing Officer or the hearing requirement; it directly prescribes the formula and computation by reference to dates and val....

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....on/wording: Several clauses show small differences in phrasing, e.g., "computed in accordance with such method of valuation, as prescribed" (Bill) vs "computed in accordance with such method of valuation, as may be prescribed" (Act). * Practical impact: negligible substantive difference. * Overall structure and sequencing: The Bill contains an express step granting the AO authority and specifying a hearing; the enacted provision removes that explicit adjudicatory step and frames the computation and payment obligations directly on the specified person and principal officer/trustee. * Practical impact: substantive procedural change that may affect natural justice guarantees, dispute resolution process, and litigation risk regarding retr....