Advance money treatment: deduction from cost of acquisition barred where the advance was included in total income.
Clause 81 requires that advance money retained during negotiations for transfer of a capital asset be deducted from the cost of acquisition (original cost, written down value, or fair market value) but prohibits that deduction where the advance has already been included in the assessee's total income under the statutory provision referenced, aligning with Section 51's objective while differing in the cross references and raising compliance and interpretive issues.

Fair market value deemed consideration: FMV used to compute capital gains when actual consideration is indeterminate.
Where actual consideration for transfer of a capital asset is not ascertainable, the fair market value (FMV) of the asset on the transfer date is to be deemed the full value of consideration for capital gains computation. Determination may use comparable sales, income, or cost approaches, but unique or illiquid assets and absence of standardized methods create practical valuation disputes. Taxpayers must substantiate FMV and authorities need valuation frameworks to ensure consistent application and prevent understatement of taxable gains.

Fair market value deemed consideration for unquoted share transfers to prevent undervaluation and ensure correct capital gains computation.
Deemed full consideration for transfer of unquoted shares is the fair market value when actual consideration is lower; fair market value must be determined by prescribed valuation procedures, with exemptions available for specified classes or conditions, and compliance requires documentation, qualified valuation and potential administrative guidelines to resolve disputes.

Full value of consideration deemed to stamp duty valuation; safe harbor permits minor discrepancies and valuation review.
Where declared consideration for transfer of land or buildings is less than the stamp duty valuation, the stamp duty value is deemed the full value of consideration for capital gains purposes; the stamp duty value as at the agreement date may apply if consideration is received through prescribed banking channels before the agreement date. A limited safe harbor accepts declared consideration within a narrow margin above stamp duty valuation. Assessing Officers may seek Valuation Officer review where the stamp duty value is disputed, and Clause 78 defines assessable as the value adopted for stamp duty purposes.

Capital gains treatment for slump sales clarified: net worth valuation and accountant certification required for tax computation.
The computation treats the net worth of the transferred undertaking-aggregate assets less liabilities, excluding revaluation increases-as the cost of acquisition; where lump sum consideration diverges from market values, the fair market value of assets on the transfer date is deemed the full value of consideration. Depreciable assets use written down value, certain goodwill and specified assets are valued at nil, and an accountant's report certifying the net worth computation is required.

Market Linked Debenture tax treatment: gains treated as short-term capital gains irrespective of holding period.
Clause 76 mandates that gains on Market Linked Debentures and specified debt instruments be treated as short-term capital gains irrespective of holding period, prescribes computation as full consideration less cost of acquisition and transaction expenditure (X = A - B - C), disallows deduction for Securities Transaction Tax, and defines covered assets and specified mutual funds to determine applicability.

Cost of acquisition adjustment: depreciable assets' acquisition cost tied to written down value, altering capital gains computation.
Clause 75 treats the written down value of a depreciable asset, where depreciation has been claimed, as the cost of acquisition for capital gains purposes and directs that set-off and carry forward provisions apply subject to this modification, thereby aligning gain or loss on disposal with the asset's depreciated value.

Computation of capital gains on depreciable assets: revised short term treatment under an overriding block based formula.
Clause 74 creates an overriding framework for computing capital gains on depreciable asset blocks: if consideration from transfer exceeds transfer expenses plus the block's written down value at the year's start and additions during the year, the excess is treated as short term capital gains; on complete cessation of a block, acquisition cost is the opening written down value adjusted for acquisitions and resulting income is treated as short term capital gains.

Cost of acquisition rules designate deemed cost for non purchase transfers, preserving prior owner's cost with specified formulas.
Clause 73 prescribes the deemed cost of acquisition for assets received by gift, will, inheritance or similar transfers as the cost incurred by the previous owner, adjusted for improvements; it prescribes fair market value for assets declared under the Income Declaration Scheme and specific formulae for units in mutual funds, business trusts and segregated portfolios, and ties cost continuity to original assets in corporate reorganisations.

Mode of computation of capital gains: updated indexation, tightened deductible items, and rules for business trusts and non-residents.
Clause 72 updates the mode of computation of capital gains by retaining deductions for expenditure and cost of acquisition or improvement while specifying a Cost Inflation Index tied to the Consumer Price Index (urban) for indexation. It expressly disallows certain interest payments and securities transaction tax, sets out reduction rules for cost of acquisition involving business trusts and specified entities, and provides detailed computation rules for non-residents addressing foreign currency and rupee appreciation, alongside definitions for indexed cost concepts.

Withdrawal of exemption: non compliance with transfer conditions triggers taxation of capital gains and successor liability.
Clause 71 requires withdrawal of exemption and taxation of capital gains when a transferee converts a capital asset into stock in trade or when shareholding continuity of a parent/holding company in a subsidiary is broken within the prescribed period, and it makes successor entities or shareholders liable where specified conditions are not met, aligning functionally with the triggers and successor liability mechanisms in Section 47A of the Income tax Act.

Capital gains exemptions for specified restructurings preserve tax neutrality and facilitate cross-border and corporate reorganisations.
Clause 70 of the Income Tax Bill, 2025 designates specified classes of transactions as not regarded as transfer for capital gains purposes, exempting partitions of Hindu undivided families, transfers by will, gift or irrevocable trust, transfers between parent and subsidiary companies, amalgamations and demergers (including foreign company reorganisations), conversions and exchanges of securities, securities lending, reverse mortgage arrangements, mutual fund consolidations, transfers involving art and cultural institutions, and succession of business entities, thereby aligning with and expanding the scope of existing non-transfer provisions in Section 47 of the 1961 Act.

Capital gains on share buy backs: updated rules tax the gain, deem certain consideration nil, and align definitions with corporate law.
Clause 69 taxes the difference between acquisition cost and consideration on company repurchase of its own shares or specified securities, prescribes that certain forms of consideration under clause 2(40)(f) are deemed nil for tax purposes, and adopts the Companies Act definition of specified securities, thereby aligning tax treatment with current corporate law and updating statutory cross references.

Capital gains on liquidation distributions: shareholders taxed on market value gains with dividend adjustment applied.
Distributions of assets on company liquidation are not treated as transfers by the company; shareholders receiving money or assets are taxable under Capital gains, with gain measured by the market value of assets received less any part assessed as dividend, and that net amount deemed the full value of consideration for capital gains computation. Clause 68 parallels Section 46 in substance but changes the statutory cross reference used for calculation mechanics.

Capital gains modernization clarifies valuation and timing for taxation, including insurance recoveries and conversions to stock in trade.
Clause 67 retains the principle that gains from transfer of capital assets are taxable in the year of transfer and refines valuation and timing for specified situations: insurance recoveries are treated as capital gains with fair market value deemed as full consideration; unit linked insurance receipts are aligned with capital gains rules where exemptions do not apply; conversion to stock in trade uses fair market value at conversion as consideration and taxes gains when sold; beneficial interests in securities are attributed to the beneficial owner with FIFO cost and holding period rules.

Tax deductions in co operative bank reorganisations: allocation rules and book value transfers ensure continuity and fairness in taxation.
Clause 65 and Section 44DB set a special provision for computing tax deductions in co operative bank reorganisations by allocating deductions between predecessor and successor based on days before and after reorganisation, requiring transfers at book values, defining covered reorganisations by asset/liability transfer and continuity criteria, and providing for Central Government notification in specified cases to ensure genuine business purposes.

High-turnover businesses must provide prescribed electronic payment facilities to increase transaction traceability and tax transparency.
Clauses 64 and 187 of the Income Tax Bill, 2025 require persons carrying on business above the prescribed turnover threshold to provide facilities for accepting payments through prescribed electronic modes, in addition to any other electronic methods offered. These clauses parallel Section 269SU of the Income Tax Act, 1961, aiming to promote digital transactions, enhance traceability, and reduce tax evasion by imposing infrastructure and compliance obligations on high-turnover businesses.

Tax audit thresholds updated to emphasise digital transactions, altering audit triggers and filing timing for taxpayers.
Clause 63 updates mandatory tax audit triggers by revising turnover and receipt thresholds and by making the intensity of banking or online transactions decisive for higher audit thresholds; it maintains an audit requirement for professionals, preserves exemptions where declared profits align with deemed profit provisions, requires audit reports signed by an accountant and filed by the defined specified date, and allows reliance on audits under other laws if submitted on time.

Maintenance of books of account: updated thresholds and technological recordkeeping govern taxpayer record obligations for income verification.
Clause 62 modernizes maintenance of books of account by applying to specified professions and notified persons, updating income and turnover thresholds (with special treatment for individuals and HUFs), defining specified professions broadly, and empowering the Board to prescribe the types, form, manner and retention periods of records while encouraging technological methods of record-keeping to facilitate income verification and tax administration.

Presumptive taxation for non-residents fixes sectoral deemed profit rates and permits audit-based lower profit declaration.
Clause 61 establishes a special presumptive computation regime for specified non-resident business activities-shipping (including demurrage), cruise ships, aircraft operation, turnkey power project construction, mineral-oil services, and specified electronics services-by prescribing sectoral deemed profit rates as the taxable base, permitting non-residents to elect audit-based lower declared profits if they maintain detailed books and undergo audit, and restricting allowance of losses, deductions, and depreciation against the presumptively computed income.