Comparison of SCHEDULE X "DEDUCTION FOR SITE RESTORATION FUND FOR COMPUTING INCOME UNDER THE HEAD "PROFITS AND GAINS OF BUSINESS OR PROFESSION"." between the Income-Tax Act, 2025 (as passed) and the Income-Tax Bill, 2025 (as originally introduced)

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....hook: "(See section 49)" - the Schedule is linked to section 49. The Schedule is limited to computing income under the head "Profits and gains of business or profession" and creates a specific deduction mechanism for amounts deposited in designated site restoration accounts/special accounts. Coverage: persons carrying on business of prospecting for, extraction or production of petroleum or natural gas in India who have an agreement with the Central Government. Definitions provided in paragraph 6 include "amount standing to the credit of the assessee," "deposit scheme," "specified account," "special account," "special scheme," "site restoration account," and "State Bank of India." The Schedule therefore contemplates scheme instruments (special scheme, deposit scheme) to be approved or made by the Ministry of Petroleum and Natural Gas and deposited in SBI accounts. Statutory Provision Mode Text & Scope * Paragraph 1 sets the quantum of deduction: an assessee may claim either the amount deposited in the specified account maintained with SBI (paragraph 2) or 20% of the profits of the business under the head "Profits and gains of business or profession" before claiming the paragraph....

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....tion of the asset's cost attributable to the earlier deduction is deemed profits and taxed. Exceptions include transfers to specified persons (Government, local authority, statutory corporation, Government company) and firm-to-company succession where specified conditions are met (para 5(2)). Interpretation The legislative intent indicated by the text is to incentivise ring-fencing of funds for site restoration by allowing a deduction for specific deposits, subject to strict conditions, audit, and restrictions on withdrawal and use. The Schedule balances incentive with anti-abuse measures: disallowance or deeming provisions punish diversion of funds to asset purchases or non-designated purposes, and clawback via deemed income on account closure or sale of assets benefiting from the deduction. Exceptions/Provisos Key carve-outs: (i) paragraph 2(2) permits audit compliance under other statutory law in place of the separate form if the requisite reports are furnished by the specified date; (ii) paragraph 5(2) provides exceptions to clawback on asset sale where transfers are to specified public bodies or upon firm->company succession meeting strict continuity and shareholder pa....

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....nt but places it in paragraph 2(b)(i). Substantive effect appears negligible - both versions confine the qualifying special account to SBI - but drafting location of the requirement changes emphasis and may affect ease of literal reading and compliance guidance. * Audit-report wording and formality: The Bill in paragraph 2(1)(c) requires audit and the furnishing of an audit report "in such form and manner, as prescribed and verified by such accountant" whereas the Act's corresponding text in paragraph 2(1)(c) uses "as may be prescribed and verified by such accountant." * Practical impact: difference is stylistic; both confer rule-making power to prescribe form and manner. No material change in taxpayer obligation is evident from the texts provided. * Treatment where funds are used to purchase "specified articles or things": This is the clearest substantive divergence. The Bill (Document 2), at paragraph 3(2)(a), provides that if amounts standing to the credit are released/withdrawn and utilised for purchase of specified articles/things, "then, whole of such amount so utilised shall be deemed to be the profits and gains of business of that tax year and shall accordingly be....

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....ed under other law: The Bill uses "such person" in paragraph 2(2) while the Act uses "such assessee." * Practical impact: purely terminological; no substantive change in obligation apparent. * Minor drafting/formatting and consistency differences: Several wording changes (e.g., "whole of such amount so utilised shall be deemed..." in the Bill versus "such amount shall not be allowed as deduction..." in the Act; small syntactic differences in para numbering and punctuation) appear throughout. * Practical impact: largely drafting; however, where the Bill explicitly creates deeming of income on utilisation (Bill 3(2)(a)) versus mere disallowance (Act 3(2)(a)), there is a non-trivial tax consequence difference as described above. Overall practical consequence: Most differences are drafting refinements. The principal material difference is the Bill's explicit deeming of amounts utilised for certain purchases as taxable income (immediate tax charge), whereas the Act's parallel provision focuses on disallowing deduction for such utilisation. That difference may change taxpayers' computation of taxable profits and the timing/amount of tax payable when site restoration fu....