Comparison of section 384 "Procedure on receipt of application." between the Income-Tax Act, 2025 (as passed) and the Income-Tax Bill, 2025 (as originally introduced)

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....vance rulings (taxpayers or their authorised representatives) and the income-tax administration (Principal Commissioner/Commissioner and the Board). Effective date or enactment timing: Not stated in the document. Background & Scope Statutory hooks: Clause 384 (Income Tax Bill, 2025) - Procedure on receipt of application; cross-references to sections 380 and 515(3)(a). The clause concerns the Board for Advance Rulings' processing of applications and its interaction with the Principal Commissioner or Commissioner. Definitions: "authorised representative" is defined by reference to section 515(3)(a) "as if the applicant were an assessee." No further definitional material or legislative history is provided in the text. Statutory Provisio....

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....ects an application; and (iv) require prompt disposition by mandating a six-month limit for issuing a ruling once the application is allowed. The reference to "as may be prescribed" in relation to certification points to delegated legislation for procedural particulars. Exceptions/Provisos Clause 384(3) identifies three grounds for mandatory rejection (subject to the enumerated exceptions): * (a) The question is already pending before any income-tax authority or Appellate Tribunal except in the case of a resident applicant falling in section 380(b)(iv) or any court. * (b) The question involves determination of fair market value of any property. * (c) The question relates to a transaction or issue which is designed prima facie for th....

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....n in the order, which is then sent to the applicant and Principal Commissioner. (Consistent with text.) * Example 3: An applicant raises a question already pending before an income-tax authority. The Board may reject the application under Clause 384(3)(a), unless the applicant qualifies under the exception in section 380(b)(iv). (Consistent with text.) Interplay Clause 384 cross-refers to section 380(b) and to section 515(3)(a). The exact scope and effect of the exceptions hinge on the content of section 380(b) (sub-clauses iv and v in the Old Version) and the definition in section 515(3)(a). Clause 384 also contemplates delegated detail through "as may be prescribed" and "in the manner, as prescribed" for certification and formality, i....

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....anner, as may be prescribed" vs "certified in the manner, as prescribed"), and sub-section (9) (opening phrase "For the purposes of this section" vs "In this section"). * Practical impact: These are stylistic and do not, on their face, change substantive rights or procedures. They may, however, reflect finalisation of legislative drafting. No change to timelines, appellate pathways or duties of the Board are expressed by these wording variations. * Other substantive provisions: The core procedural framework-forwarding the application to Principal Commissioner or Commissioner, calling for records, power to allow or reject after examination, requirement of statement of reasons and hearing before rejection, six-month period for pronouncing....