Non-deductibility of excessive payments: reinforces banking-mode payment rules and limits unreasonable related-party deductions.
Clause 36 empowers disallowance of deductions for payments deemed excessive or unreasonable to specified persons by reference to fair market value and business need, treats related disallowed deductions as income where previously claimed, and conditions deductibility on payments above prescribed thresholds being made through specified banking or online channels while providing limited exceptions for business expediency.

Business deductions clarify allowable expenses, limiting interest capitalization and setting conditions for reserves and bond discounting.
Clause 32 specifies allowable business deductions including bona fide bonuses or commissions, capitalization of interest until asset use, pro rata discount deduction for zero coupon bonds, conditional deductions for contributions to credit guarantee funds and statutory corporation expenditures, limits on special reserves for financial entities, deduction of marked to market losses under prescribed standards, phased family planning capital deductions, agricultural purchase deductions within government price limits, animal loss adjustments, and transaction tax deductions where trading forms part of business income.

Non-deductibility of expenses: new clause tightens TDS compliance, equalisation levy and partnership deduction limits.
Clause 35 of the Income Tax Bill, 2025 prescribes categories of business or professional expenditures that are non-deductible, confirming taxes on income and related imposts are not deductible, disallowing deductions where TDS was not deducted or paid (subject to later allowance upon payment), denying deduction for cross-border salary payments lacking TDS compliance, treating equalisation levy and state-imposed charges as non-deductible, and conditioning deductions in partnerships and associations on authorization and prescribed limits to reinforce compliance and prevent tax avoidance.

Apportionment of deductions clarifies business use limits and streamlines depreciation rules under the new income tax framework.
Clause 28 limits deductions for rent, local taxes, insurance and repairs to amounts wholly and exclusively for business use and permits apportionment by the Assessing Officer where use is mixed; Clause 33 creates a structured depreciation regime for tangible and intangible assets (excluding goodwill) including block of asset calculations, special provisions for new machinery and power generation assets, short use treatment, and rules on successor transactions.

Business expenditure deductions: exclusions tightened to bar CSR, political ads, and payments tied to unlawful conduct.
Clause 34 requires that only expenditures incurred wholly and exclusively for business purposes, not of a capital or personal nature and not falling within specified exclusions, are deductible. It expressly disallows deductions for expenditures linked to offenses or prohibited activities, corporate social responsibility obligations, and political-advertisement costs, and clarifies that benefits, perquisites, compounding payments, and settlements related to unlawful conduct are non-deductible.

Business income deductions clarified and modernized, expanding allowable items and tightening conditions for claiming them.
Clause 32 prescribes a list of allowable other deductions for business income computation, covering employee bonuses and commissions, interest on borrowed capital (with exclusions until assets are in use), contributions to specified credit guarantee funds, pro rata discount on zero coupon instruments, amounts carried to special reserves by defined financial entities, non-capital expenditure by notified statutory corporations, cooperative society purchase expenditure, marked to market or expected losses, family planning expenditures by companies, cost of animals used in business adjusted for carcass receipts, and transaction taxes where income is included in business profits.

Bad debt deductions: new limits and conditions for financial institutions, distinguishing rural-advance treatment and recovery rules.
Clause 31 of the Income Tax Bill, 2025 creates a structured regime for deductions for provisions for bad and doubtful debts and for bad debts written off, prescribing percentage-based deduction limits for specified financial institutions with an additional allowance for rural-branch advances; it requires that write-offs be reflected in income computations, provides for partial recovery treatment, and distinguishes provisions from actual bad debts while aligning deductions with accounting and disclosure standards.

Search and seizure powers expanded to permit access to digital records, enhancing tax enforcement while raising privacy concerns.
Clause 247 expands search and seizure authority to electronic media and digital records, authorising officers to access and seize emails, social media, trading and bank accounts where information indicates non production of documents or undisclosed assets; it modernises enforcement by treating digital records equivalently to physical evidence while raising privacy and misuse concerns that require procedural safeguards.

Insurance premium deductions permit tax relief for business stock, cattle insurance, and employer-paid health cover via non-cash payments.
Clause 30 permits deduction for premiums paid for insurance against damage or destruction of business stocks, for premiums by federal milk cooperative societies to insure the life of cattle of primary society members engaged in milk supply, and for employers' premiums for employee health insurance provided payment is made through non-cash modes under approved schemes.

Employee welfare deductions clarified: new limits, timing and eligibility for employer contributions under Clause 29.
Clause 29 prescribes conditions and limits for deducting employer contributions to recognized provident funds, approved superannuation funds, pension schemes (subject to a uniform percentage of salary including dearness allowance), and approved gratuity funds, sets the due date rules for employee contributions, and restricts deductions for provisions or contributions unless expressly authorised, thereby clarifying and refining the deductibility regime compared with current Sections 36 and 40A.

Employee welfare deductions clarified: permitted employer contributions to approved funds subject to prescribed limits and arm's-length scrutiny.
Deductions for employer contributions to specified employee welfare vehicles are permitted only when made to recognised or approved funds and in accordance with prescribed limits, timing and conditions; provision-only gratuity reserves are generally non-deductible unless conditions are met, and contributions to other funds or trusts are disallowed except as expressly allowed or required by law.

Tax deduction for agricultural and skill development projects streamlines incentives while barring duplicate claims under the Act.
Clause 47 permits deductions for expenditures on agricultural extension projects and for companies' skill development projects, excluding land and building costs, subject to Board notification and requisite documentation. It includes an express prohibition on claiming the same expenditure under any other provision of the Act for the same or any other tax year, consolidating and streamlining prior separate incentives while imposing compliance obligations to substantiate eligibility.

Site restoration fund deductions limited and conditional; misuse of withdrawals treated as taxable income under new regime.
Clause 49 and Schedule X create a Site Restoration Fund regime allowing deductions for deposits into specified accounts subject to caps and conditions: claims require a government agreement and audited accounts, deposits must be made by year-end, withdrawals are restricted to scheme purposes and misuse is taxed as income, expenditures funded by withdrawals are nondeductible, and disposals tied to the scheme within a set period reverse deductions and are taxed.

Capital expenditure deduction for specified businesses enables immediate full write-off, subject to eligibility, exclusivity and usage conditions.
Clause 46 permits full deduction of capital expenditure for a specified business in the year incurred, including pre-operational capitalized expenditure, subject to conditions: no splitting or reconstruction of existing businesses, prohibition on previously used machinery or plant, and, for certain sectors, fulfillment of regulatory approval and operational criteria; it bars claiming other deductions for the same expenditure and requires assets to be used exclusively for the specified business for at least eight years.

Amortization of preliminary expenses enables staged tax relief for businesses under the new income tax provision.
The clause permits staged deduction of specified preliminary expenses by allowing an Indian company or resident individual to deduct one fifth of eligible preliminary expenses in each of five successive tax years, subject to an overall ceiling computed at the option of the taxpayer against either project cost or capital employed; eligible expenditures include feasibility and project reports, market and engineering studies, legal charges and other prescribed preparatory costs, and a statement of expenditure must be furnished to the prescribed authority.

Amortisation of expenditure: Tax treatment extended to telecommunications, amalgamation, demerger and voluntary retirement schemes clarified.
Clause 52 provides for amortisation of expenditures: amalgamation or demerger costs and voluntary retirement payments are amortisable over five tax years from the tax year of the event or payment; spectrum and licence fees for telecommunication services are amortisable over the period the rights remain in force, beginning in the later of business commencement or payment year. It further addresses tax consequences on transfer of such rights and empowers the Assessing Officer to rectify income where deductions were incorrectly claimed.

Research expenditure deductions expanded under new clause; certification and continuity rules affect pre commencement and institutional payments.
Clause 45 allows deductions for capital and revenue scientific research expenditures related to business, excluding land acquisition; permits certified pre commencement expenditures up to three years; allows payments to research associations, universities and approved companies; conditions claims on prescribed documentation and compliance; protects deductions when approvals are later withdrawn; and contains provisions on non duplication of deductions, depreciation applicability, and amalgamation asset treatment.

Depreciation rules modernized to clarify asset categories and additional allowances, affecting business tax deductions and compliance.
Clause 33 creates a unified regime for depreciation on tangible and intangible assets used in business or profession, excluding goodwill; mandates written down value treatment for a block of assets with proportional deductions for partial business use; halves rates for assets used less than 180 days; provides pro rata apportionment on succession, amalgamation and demerger; treats leasehold improvements as depreciable buildings; permits late claims and carry forward of unabsorbed depreciation; allows disposal deductions for written down value shortfalls; and grants additional depreciation for new machinery and plant in manufacturing and power generation.

Deductions for rent and repairs clarified: proportionate claims allowed for partial business use under new clause.
Clause 28 consolidates deductions for premises, machinery, plant, and furniture used wholly and exclusively for business or profession, allowing deductions for insurance premiums, local taxes, rent, and current (non-capital) repairs. It preserves tenant-specific rent and repair claims and imposes an explicit apportionment rule: where assets are not wholly used for business, deductions are limited to a fair proportionate part as determined by the Assessing Officer, thereby centralising assessment discretion and requiring supporting documentation for partial-use allocations.

Business income taxation modernisation clarifies taxable receipts and expands scope to include government-related compensations and non-monetary benefits.
Clause 26 restates chargeability of income under the head "Profits and gains of business or profession" for the tax year, replacing the term "previous year," and refines categories of taxable receipts by expressly including compensation for termination or contract vesting with government bodies, consolidating export incentives, recognizing non-monetary benefits, and preserving existing treatments for partner receipts, Keyman insurance proceeds, inventory-to-capital conversions, capital-asset sums, speculative transactions, and the exclusion of residential letting income.