Total income aggregation requires inclusion of exempt receipts to protect the tax base and prevent erosion through exclusions.
Clause 101 mandates that computation of Total income include income exempt under the identified sub part of Chapter provisions, converting such exempt receipts into an affirmative component of total income to protect the tax base and prevent erosion from otherwise excluded income streams.

Income attribution: clarifies tax liability of the legal owner and joint-and-several responsibility for income included in another's return.
Clause 100 assigns tax liability to the person in whose name an asset stands or whose firm membership produces attributed income, imposes joint and several liability for jointly held assets allowing recovery from any co-owner for the whole tax due, applies existing procedural recovery mechanisms to enforce the liability, and overrides contrary provisions in other laws to ensure primacy in determining tax obligations arising from income attribution.

Clubbing of income: new clause expands inclusion of spouse, minor child and transferred-asset income in assessee's taxable income.
Clause 99 attributes to the individual income arising to a spouse from employment or remuneration in concerns where the individual has a substantial interest, income from assets transferred to a spouse or a son's wife without adequate consideration, and income of a minor child except earnings from the child's manual work or personal skill; it also prescribes a formula for income attributable when transferred assets are invested and treats conversion of individual property to HUF as income of the individual.

Revocable transfer definitions broaden tax reach, treating arrangements that preserve transferor control as attributable income to transferor.
Clause 98 of the Income Tax Bill, 2025 and Section 63 of the Income Tax Act define transfer to include settlements, trusts, covenants, agreements or arrangements, and define revocable transfer to cover provisions enabling direct or indirect re transfer of income or assets or re assumption of power by the transferor. Both provisions attribute income to the transferor where economic substance shows retention of control or benefit, broadening the tax net over arrangements that preserve transferor influence.

Chargeability of income in asset transfers: revocable transfers taxed to transferor, with narrow irrevocable-transfer exceptions.
Clause 97 treats income from a revocable transfer of assets as taxable in the hands of the transferor, while providing exceptions for truly irrevocable transfers where the transferor derives no direct or indirect benefit; if a power to revoke later arises the income becomes chargeable to the transferor, thereby aligning taxation with economic control and preventing tax avoidance through strategic transfers.

Transfer of income without asset transfer: such income is taxed in the transferor's hands to prevent tax avoidance.
Clause 96 and Section 60 provide that income arising by virtue of a transfer, whether revocable or irrevocable and irrespective of timing, is chargeable to tax in the transferor's hands if the asset generating that income has not been transferred, thereby preserving the link between income and its source asset to prevent tax avoidance.

Remission of liabilities taxable - forgiven debts and other benefits must be included as income when received under revised charge rules.
Clause 95 of the Income Tax Bill, 2025, treats any benefit obtained from the remission or cessation of a liability for which a deduction was previously allowed as taxable in the year received, applying principles from Section 38(1)(a) to non business income heads. Section 59 of the Income tax Act, 1961, applies Section 41(1) similarly to ensure forgiven liabilities are included in taxable income, but both provisions present valuation and timing ambiguities for non cash benefits and assessment year determinations.

Disallowance of deductions: withholding compliance ties deductibility for cross border payments and personal expenses.
Clause 94 disallows deductions from income from other sources for personal expenses and for interest or salaries payable outside India where tax has not been paid or deducted under the withholding framework; it extends selected business-income deduction rules to other sources, prescribes computation rules for foreign companies, disallows deductions for gambling and lotteries while excepting horse racing maintenance, and links deductibility to compliance with withholding obligations.

Deductions for income from other sources clarified, aligning allowable expenses and curbing dividend-related deduction claims.
Clause 93 of the Income Tax Bill, 2025 prescribes deductions for Income from other sources, allowing reasonable sums for realising dividends or interest on securities, deductions for specified income categories via cross references, a capped family pension deduction, non capital expenditures wholly and exclusively for earning such income, a 50% concession for certain incomes, and targeted restrictions limiting deductible interest tied to certain dividend incomes to a proportion of that income.

Taxation of miscellaneous income broadens taxable sources to include modern streams like digital assets and trust distributions.
Clause 92 establishes a residual charging rule that any income not charged under other heads and not excluded is taxable under Income from other sources, enumerating a non exhaustive list of receipts-dividends, gambling winnings, employee fund contributions, specified insurance proceeds, interest including on compensation, rental of machinery or furniture, forfeited advances, employment termination compensation, business trust distributions, life insurance sums outside specified products, and gifts or property transfers-while providing exemptions for transfers from relatives, on marriage, under wills and certain local authority receipts, and setting valuation and definition rules including treatment of digital assets.

Valuation officer referral: a statutory mechanism to address discrepancies between declared asset values and fair market value.
Clause 91 empowers the Assessing Officer to refer a capital asset's valuation to a Valuation Officer where an assessee's declared amount appears inconsistent with the fair market value, applying to assets valued by registered valuers and to other cases meeting prescribed thresholds or circumstances, and adopts procedural modifications by reference to Section 269(3)-(8).

Cost of acquisition rules clarified: FMV option and acquisition cost deemed nil when indeterminable, affecting capital gains computation.
Clause 90 defines cost of improvement as nil for intangible assets and permits post reference date expenditure for other assets; sets cost of acquisition as purchase price or previous owner's purchase price and deems cost nil where indeterminable; provides tailored rules for financial assets to avoid taxing non economic gains; and allows a fair market value option as cost of acquisition for earlier acquisitions to reflect market and inflationary changes.

Extension of time for reinvesting capital gains tied to receipt of compensation preserves exemption eligibility after compulsory acquisition.
Where an original asset is compulsorily acquired and compensation is delayed, the period for acquiring a new asset or depositing or investing capital gains is calculated from the date of receipt of compensation rather than the date of transfer; Clause 89 of the Income Tax Bill, 2025, states this rule and declares it to operate irrespective of conflicting timelines in specified sections, and Section 54H of the Income-tax Act, 1961, operates on a comparable principle tied to specified reinvestment provisions.

Capital gains exemption for industrial relocations to SEZs conditions relief on reinvestment in new SEZ assets and deposit rules.
Clause 88 grants a capital gains exemption when assessees transfer assets while shifting an industrial undertaking from an urban area to an SEZ, conditional on reinvesting gains into new SEZ assets within the prescribed investment window; unutilized gains must be deposited in a specified account and any excess of gains over the cost of new assets is taxable. Eligibility centers on assets used in the undertaking and utilisation for notified SEZ investments, with deposits treated as part of the new asset's cost for calculating the exemption.

Capital gains exemption for industrial relocation to non urban areas conditional on reinvestment and deposit requirements.
Exemption of capital gains on transfer of assets for industrial undertakings shifting from urban to non urban areas is subject to reinvestment in qualifying assets (machinery, plant, buildings, land or rights therein) acquired within the prescribed timeframe; any shortfall between capital gains and cost of new assets is taxable, and unutilised gains must be deposited in a specified bank or institution before filing the return, with untapped deposits taxed after the statutory period; the definition of urban area and scheme specified expenditure govern eligibility.

Capital gains exemption for residential reinvestment preserved with clearer compliance and monetary caps under the 2025 proposal.
Clause 86 provides a capital gains exemption for individuals and HUFs who reinvest long-term capital gains from specified asset transfers (excluding residential houses) into a residential house in India within prescribed purchase or construction timeframes. The exemption is proportional when net consideration exceeds the replacement cost and full when replacement cost equals or exceeds net consideration. Unutilised gains must be deposited under a notified government scheme before filing returns, and exempted gains become taxable if the replacement asset is transferred within three years. Ownership of multiple residential houses or acquisition of another house within specified periods disqualifies the exemption.

Capital gains deferral on compulsory acquisition permits tax relief when compensation is reinvested in similar industrial assets.
Clause 84 provides a deferral regime for capital gains on compulsory acquisition where compensation reinvested in similar industrial land or buildings within three years is either exempt or adjusts the cost basis: excess gains over new asset cost are taxed as income and the new asset's cost is set to nil for future computations, while gains equal to or below cost reduce the asset's cost. Unutilised gains must be deposited by the return filing due date and are treated as part of the deemed cost; unutilised amounts after the specified period are charged as income and subject to notified withdrawal rules.

Capital gains exemption for reinvestment in specified bonds preserves non taxability subject to retention and anti abuse rules.
Clause 85 provides that capital gains from transfer of long term assets are not charged if the assessee reinvests whole or part of such gains in government notified bonds within six months, subject to a per year investment ceiling and a specified retention period; transfers, conversions, or loans against the new asset within the lock in are treated as taxable events and investments claiming this exemption cannot simultaneously claim alternative deductions.

Capital gains exemption for agricultural land: reinvest sale proceeds in new agricultural land within two years to defer tax.
Capital gains on transfer of agricultural land are not charged if proceeds are reinvested in new agricultural land within two years by individuals or HUFs who used the land for agriculture in the two years prior. Unutilised gains at filing must be deposited in a specified bank account and applied under a government-notified scheme; unused deposits after the prescribed period are taxed and may be withdrawn per the scheme. Excess gains are taxed under the bill's taxing provision and the new asset's cost is treated as nil for subsequent gains if sold within three years; otherwise the cost basis is reduced by the capital gains.

Capital gains reinvestment relief: deferral for gains when proceeds are reinvested in residential property with deposit safeguards.
Clause 82 permits deferral or exemption of capital gains from sale of residential property where proceeds are reinvested in another residential property, treating gains exceeding the new asset's cost as taxable. Unutilized gains must be deposited in a specified bank or institution under a notified scheme and such deposits count toward the new asset's cost. Deposited amounts not applied within the prescribed period become taxable though the clause provides for withdrawal of unused sums. The clause allows a one time option to invest in two houses subject to a gain threshold and imposes caps on eligible cost and gains to target relief.