Pass-through of AIF losses: business losses retained at fund; certain non-business losses deemed to eligible unit holders and carried forward.
Amendment to section 115UB provides that AIF business losses remain at the fund and are carried forward under Chapter VI and not passed to unit holders; non-business losses tied to units not held by a unit holder for at least twelve months are ignored for pass-through; non-business losses accumulated at the fund as on 31 March 2019 are deemed to be the losses of unit holders who held units on that date and may be carried forward and set off by them under Chapter VI, and those deemed losses will not be available to the fund.

Relief under section 89 to be included in tax computation, making amended computation provisions effective retrospectively for affected assessment years.
Proposed amendments require that tax liability be computed after allowing the relief under section 89, so that existing computation and interest provisions explicitly accommodate credit for this relief; the amendments operate retrospectively and apply to earlier assessment years to address hardship for eligible taxpayers.

TDS on life insurance income: withholding will target the income component to align taxable reporting and reconciliation.
The amendment requires withholding tax to be deducted on the income component of non-exempt life insurance payouts rather than on the gross payout, to facilitate automatic matching of deductor TDS returns with recipients' tax returns because the payer can ascertain the premium paid by the policyholder, and specifies a commencement date for the change.

Accounting year definition clarified to follow ultimate parent's year for alternate reporting entities, with retrospective effect.
For an alternate reporting entity resident in India whose ultimate parent is not resident in India, the reporting accounting year for Country-by-Country Reporting shall be the accounting year applicable to that ultimate parent entity rather than the Indian ARE's own previous year; this clarificatory amendment is retrospective to 1 April 2017 and applies to assessment year 2017-18 and thereafter.

Transfer pricing documentation expanded: constituent entities must maintain and furnish group information even without transactions.
The amendment mandates that a constituent entity of an international group must keep and maintain prescribed group-level information and documents and file the required form even if the constituent entity has undertaken no international transaction. It further requires the constituent entity to furnish the prescribed information to the designated authority, with the amendment effective from 1 April 2020 for the relevant assessment year.

Tax treatment of excess consideration on share issues: conditional exemptions; non compliance converts excess into taxable deemed income.
The measure makes conditional exemptions from tax on excess consideration for share issues subject to specified compliance conditions and provides that any failure to comply will result in the excess consideration over face value being treated as deemed income of the company, chargeable to income tax in the previous year in which the non compliance occurred.

Statutory reference correction in tax law: interest on compensation aligned with amended valuation provision, applied retrospectively.
An amendment will correct the statutory reference in section 56 of the Income tax Act to cite section 145B(1) instead of section 145A(b), ensuring that interest on compensation or enhanced compensation is chargeable to tax under the revised provisions introduced by the Finance Act, 2018. The correction is retrospective to the start of the applicable fiscal period and applies to the relevant assessment years.

Penalty computation for under-reported income clarified for returns filed during reassessment, applied retrospectively to relevant assessment years.
Amendments prescribe the method to compute the quantum of penalty where a taxpayer under-reports income and furnishes a return for the first time during reassessment proceedings; they address the existing absence of such a computation mechanism and apply retrospectively to cover specified assessment years.

Prosecution threshold for late tax returns broadened to include self-assessment tax and tax collected at source.
Determination of tax liability under section 276CC will include pre-paid taxes, specifically tax collected at source and self-assessment tax paid before the expiry of the assessment year, when deciding whether the tax payable falls below the prosecution threshold. The amendment also increases the monetary threshold applicable for prosecution and applies to the relevant subsequent assessment years.

Tax recovery under international agreements expanded to allow enforcement based on residency when property details are unavailable.
Amendments permit recovery of tax under agreements with foreign countries where property details are unavailable by allowing enforcement when the target person is a resident in India, and reciprocally where an assessee in default is a resident in a foreign country despite lack of property details, thereby enabling treaty-based recovery through residency-based enforcement.

Refund claims must be filed as tax returns, simplifying refunds and extending limitation for sale of attached property.
Claims for refund under Chapter XIX must now be made by furnishing a return under the statutory return-filing provisions, replacing the prior prescribed claim form and verification procedure, effective 1 September 2019. The limitation for sale of immovable property attached for recovery of tax is extended from three to seven years from the end of the financial year in which the demand becomes final, and the Board may further extend that period by three years for reasons recorded in writing; this amendment is also effective 1 September 2019.

Residence-based taxation clarified: expanded assessee definition and reassessment provisions to capture undisclosed foreign income and assets.
Amendments expand the definition of assessee to include residents in the relevant previous year and certain non-residents or not-ordinarily-residents who were resident either in the year the income relates to or in the year an undisclosed foreign asset was acquired, with acquisition year determined without applying a carry-forward provision; they also add "re-assess" and "reassessment" terminology and make reassessment procedure from the income-tax framework applicable with modifications, while clarifying that the appellate authority may both increase and decrease penalties.

Post-deadline payment relief: notified declarants may pay outstanding tax with monthly interest and possible refunds after review.
Amendments permit the Central Government to notify classes of declarants who may make outstanding tax, surcharge and penalty payments after the due date by a notified date, with interest at one per cent per month or part-month from the day after the due date until payment. The Government may also notify classes of persons entitled to refunds of amounts paid in excess under the Scheme; the refund provision is made retrospective to 1 June 2016.

Securities transaction tax change: levy on exercised options now measured by the strike settlement price difference, affecting option sales.
The taxable value for sale of an option in securities where the option is exercised is redefined to be the difference between the strike price and the settlement price, replacing the previous measure of the settlement price for STT calculations; this legislative amendment is enacted by Clause 193 of the Finance (No.2) Bill, 2019 and takes effect from 1st September, 2019.

Benami transaction enforcement: amendments streamline initiation, attachment timing, evidence admissibility and penalties.
Amendments clarify that Initiating Officer need not obtain prior Approving Authority approval once notice under section 24(1) is issued; fix that the 90 day periods for provisional attachment and passing of orders run from the end of the month of notice and exclude court stays; introduce a penalty for failure to comply with summonses or furnish information; permit admissibility of certified authority records as evidence; and replace prior sanction by the Board with sanction by the competent authority.

Tax exemption extension for SUUTI preserves income-tax immunity retrospectively, extending the concession for an additional two-year period.
The Finance Bill (Clause 186) proposes to extend SUUTI's income-tax and related tax exemption for an additional two-year period, maintaining its immunity in relation to income, profits, gains or amounts from the specified undertaking, and to give the amendment retrospective effect from the start of the relevant fiscal year.

Customs duty definitions clarified under Finance Bill, setting scope and an enactment date effectiveness for amendments.
Amendments in the Finance (No. 2) Bill, 2019 clarify that Basic Customs Duty means the customs duty under the Customs Act, 1962; Export duty means the customs duty on goods in the Second Schedule to the Customs Tariff Act, 1975; and Road and Infrastructure Cess means the additional duty under section 111 of the Finance Act, 2018. Amendments become effective on enactment unless otherwise specified, and clause numbers are shown in square brackets.

Verification of identity through biometric identifiers enables customs to verify individuals and suspend benefits for non-compliance.
Amendments broaden customs powers: departure manifests may be furnished to notified persons; a new verification chapter permits identity checks through Aadhaar or alternatives with regulatory exemption and penalties for non-compliance; authorised screening and body scans may be reported to a magistrate. Arrest powers extend beyond territorial waters, specified offences are made cognizable or non-bailable, and custody rules for seized goods are clarified. Officers may provisionally attach bank accounts with limited extension and adjudicatory release. New penalties address fraudulent procurement or use of instruments and increase monetary caps; the Board may make related regulations.

Anti circumvention measures for countervailing duty introduced, and appeals on safeguard determinations moved to appellate tribunal.
An amendment inserts an anti circumvention provision into the Customs Tariff Act to prevent evasion of countervailing duty, and another amendment channels appeals against determinations or reviews about increased import volume for imposition of safeguard duty to the Customs Excise and Service Tax Appellate Tribunal.

Customs duty revisions: targeted increases and reclassification to align tariff lines, affecting specific goods and book treatment.
The Finance (No. 2) Bill, 2019 revises Basic Customs Duty rates for specified tariff headings across construction materials, precious metals, automobile parts and electronics effective 06.07.2019 by virtue of a provisional collection declaration, and inserts Chapter Note 7 to exclude printed books for personal use from heading 9804 so they attract applicable merit rates. Clause 87(b) directs creation of specific tariff lines and rectification of classification errors to align the First Schedule with HSN, effective on a date to be notified in the Official Gazette.