Comparison of section 524 "Presumption as to assets, books of account, etc." between the Income-Tax Act, 2025 (as passed) and the Income-Tax Bill, 2025 (as originally introduced)

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....use 524 (Document 2). The provisions affect taxpayers, investigating officers and the Department; effective/decision date is Not stated in the document. Background & Scope Statutory hooks: references in the texts to searches u/s 247, surveys u/s 253 and requisitioning officer u/s 248. Both texts set out presumptions that may be drawn "in any proceeding under this Act" where specified items are found in the possession or control of a person during search or survey. Definitions or extended explanations are Not stated in the document beyond the explicit list of items and the cross-references to sections 247, 248 and 253. Statutory Provision Mode Text & Scope Coverage and elements (as stated in the Bill version, Document 2): Clause 524 pro....

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....es the provision as providing "a rebuttable presumption." The operative context for the presumptions is "in the course of a search u/s 247 or survey u/s 253" and in "any proceeding under this Act." Exceptions/Provisos No exceptions, provisos, thresholds, or conditions beyond the cross-references to sections 247, 248 and 253 are specified in the Bill text. Any carve-outs or procedural safeguards are Not stated in the document. Illustrations * Example 1: If during a search u/s 247, an assessor finds physical ledgers and jewellery in X's premises, Clause 524 permits a presumption that the ledgers and jewellery belong to X and that the ledger contents are true. (This follows from sub-clauses (a) and (b) of the Bill text.) * Example 2....

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....) providing that "exchange of such information in electronic form, or on such computer system purported to be exchanged between any parties, is exchanged between the parties thereto." Document 2 lacks an equivalent clause. * Expanded specification of covered items: Document 1 repeats the list and explicitly connects "such information or computer system" to the presumptions in sub-clauses; Document 2 lists tangible/digital assets but does not incorporate electronic information/computer systems in the text of presumptions. * Stylistic/typographical differences: Document 2's clause (d) contains a textual anomaly-an apparent duplication or misplacement at the end ("...attested article or thing belong or belongs to such person"); Documen....

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....ices (the text does not prescribe procedures; those are Not stated in the document). Practical Implications * Compliance and risk areas: Under the Bill text, material found during searches/surveys attracts statutory presumptive weight for ownership, truth of ledger contents and authenticity of signatures. Taxpayers and their advisors should be aware that discovery of books/documents/assets during official actions can trigger presumptions in subsequent proceedings. The Bill version does not address electronic information specifically; the enacted text does-see the Differences section above. * Record-keeping/evidence points: The Bill text does not prescribe custody, notice, or forensic procedures; therefore, documentation of chain of cus....