Charge of tax on firms: statutory source choice alters which central enactment prescribes the applicable rate for a year.
Both texts charge tax on a firm's total income but differ in the statutory source for the applicable rate: the Bill points to the annual tax statute as the operative source, while the Act uses a broader reference to any Central Act for the relevant year, potentially expanding the range of enactments that may prescribe the rate and introducing additional interpretive and administrative considerations.

Director liability: personal joint and several responsibility for unrecoverable company tax, unless director disproves gross neglect or misfeasance.
Section 323 imposes joint and several liability on persons who were directors of a private company during the relevant tax year where tax due (including penalty, interest and fees) cannot be recovered, operating irrespective of the Companies Act, 2013. A director is exempt only if he proves the non-recovery cannot be attributed to gross neglect, misfeasance or breach of duty. The Act omits a narrow conversion-to-public-company saving that appeared in the original Bill, thereby broadening potential director exposure.

Taxation of AOPs/BOIs: unknown member shares trigger top personal rates on aggregate income; known shares require apportioned taxation.
Where members' shares in an AOP/BOI are indeterminate or unknown, the entity's total income is taxed at the maximum marginal rate or at any higher rate applicable to a member's total income; where shares are determinate, each member's other income is tested against the Finance Act's non taxable threshold and portions attributable to higher rate members are taxed at those rates while the balance is taxed at the maximum marginal rate, with a deeming rule treating indeterminacy at formation or thereafter as sufficient.

Oral trust taxation: trustee receipts are taxed at the maximum marginal rate, shifting compliance and liability to trustees.
Tax on income connected to an oral trust is charged at the maximum marginal rate when a trustee receives or is entitled to receive income on behalf of or for the benefit of any person under an oral trust (per section 303(3)), irrespective of other provisions; the Bill had instead charged the income of the person appointed under an oral trust.

Tax on unallocated trust income risks top marginal taxation unless beneficiaries and shares are expressly stated and ascertainable.
Representative assesses holding income for beneficiaries with unspecified or indeterminate shares are taxable at the maximum marginal rate unless a court order, trust instrument or wakf deed expressly identifies beneficiaries and their ascertainable shares on the relevant date; limited exceptions allow taxation at association of persons rates where beneficiaries lack other significant income, where the trust is a sole testamentary trust, where a bona fide historical non testamentary trust for dependants exists, or for bona fide employee benefit funds, and business profits are normally subject to the top rate unless the narrow will trust exception applies.

Representative assessee recovery rights secure retention via Assessing Officer certificate limiting recoverability at final settlement.
A representative assessee who pays any sum under the Act may recover it from the principal or retain an equivalent amount in his representative capacity; a person who apprehends such assessment may retain estimated liability from monies payable to the principal; on dispute the Assessing Officer may issue a certificate authorising retention pending final settlement; recoverability is capped by the certificate amount, except where the representative holds additional assets of the principal, and the enacted text ties that cap to the time of final settlement.

Representative assessee liability: treated as beneficial owner for assessment, with revenue able to reach beneficiaries directly.
Section 304 treats a representative assessee as if the income were beneficially his for duties, liabilities and assessment; it places assessment liability on the representative in his own name, contains an exclusivity rule preventing assessment of the same income under other provisions, preserves the Assessing Officer's power to assess or recover tax directly from the beneficial owner, prescribes a pro rata formula for beneficiaries' share of a chargeable trust income, and grants the revenue equivalent remedies against property under the representative's control.

Block period definition governs temporal scope for assessing undisclosed income, including virtual digital assets and documents.
Clause 301 defines the block period as the six tax years preceding the tax year of a search or requisition plus the portion of that tax year to the date of the last authorisation, and deems the last authorisation executed on the conclusion recorded in the last panchnama for searches or on actual receipt for requisitions. It defines undisclosed income in two limbs: tangible and intangible items or entries representing undisclosed income (including virtual digital assets), and expenses/exemptions/deductions/allowances claimed under the Act that are found incorrect, and it lists books, documents and valuables as requisitioned or seized items.

Levy of interest and penalty in search cases: interest accrues and an administrative penalty may attach to undisclosed income when returns are not furnished.
Where a return required by a search notice is not filed, the provision charges interest on tax determined in the search assessment for the period from the day after the notice deadline until assessment completion, and permits an administrative penalty measured by reference to the tax leviable on undisclosed income determined in that assessment. A conditional bar prevents penalty for the block period if the return is filed, tax is paid with evidence, and no appeal is filed against the returned portion; any undisclosed income in excess of declared amounts remains penalizable. Procedural safeguards include a hearing, higher level approval for large penalties, and specified limitation and exclusion rules.

Time-limit for completion of block assessment: statutory period anchored to quarter-end with specified exclusions and minimum remaining period.
Time-limit for completion of block assessment fixes a statutory period for passing orders under the special search/block assessment procedure, anchors computation to a calendar endpoint, prescribes enumerated excluded periods (including custody of seized items, court stays, information exchange references, audit and valuation processes, references to valuation or appellate authorities, penalty and avoidance arrangement references, and Advance Rulings proceedings), provides a minimum remaining period protection after exclusions, and includes month end rounding; the enacted text shifts the anchor from month end to quarter end and refines exclusion wording and cross references.

Undisclosed income transfer to other person's AO triggers block assessment and fixes abatement reference to receipt date.
When an Assessing Officer is satisfied that seized money, assets, books, documents or any information therein pertain to a person other than the person searched, those materials must be handed to the Assessing Officer having jurisdiction over that other person, who shall proceed under section 294 and apply the block assessment provisions; for abatement under section 292 the reference date for the other person is the date the receiving AO obtains the seized materials or information.

Block assessment procedure: time limited compelled return after search, limits revision rights and prescribes applicable procedural and penalty provisions.
Section 294 compels a time limited special return of undisclosed income following a search or requisition, treats that return as within a specified return regime, precludes revised returns, prescribes which procedural and penalty provisions shall apply or be excluded, and requires prior approval by senior officers before issuing the notice.

Total undisclosed income: rules for block-period computation, exclusions for short-period transfer-pricing transactions and loss restrictions.
Computation of the total undisclosed income of the block period aggregates undisclosed income declared under the statutory declaration mechanism and undisclosed income determined by the Assessing Officer from seized material, survey or requisition results, and other material coming to the AO's notice; it prescribes temporal windows for book-based computation, excludes certain international and specified domestic transactions in the short inter-authorisation period from block computation to be assessed separately, and restricts set-off of brought-forward losses and unabsorbed depreciation against undisclosed block income while allowing carry-forward post-block period.

Block assessment procedure centralises search-related assessments, abating parallel year-wise proceedings where initiated and enabling revival on annulment.
Assessing Officers must assess or reassess the total undisclosed income of the block period under the Part, with those proceedings taking priority over ordinary year wise assessments; pending assessments for years in the block period abate (and may be deemed to have abated on the date certain notices were issued), non undisclosed income of the year of last authorisation is assessed separately, multiple searches are sequenced with timing extensions where needed, and abated proceedings may be revived if Part proceedings or specified orders are annulled.

Intimation of loss: mandatory written notification to assessee when loss is established and eligible for carry forward and set-off.
Section 291 requires the Assessing Officer to notify the assessee by an order in writing the amount of loss as computed by him when (a) a loss is established in assessment and (b) the assessee is entitled to carry forward and set off that loss for the purposes of the listed statutory provisions. The duty is mandatory and procedural, linking the notification obligation to both the establishment of loss in assessment and the assessee's statutory entitlement to carry forward and set-off.

Recomputation of assessments tied to triggering events allows targeted amendments within specified limitation periods.
Clause 288 permits an Assessing Officer to amend or recompute completed assessments in a limited set of scenarios triggered by downstream events-such as reassessment or recomputation orders, valuation or compensation revisions, patent revocation, settlement of foreign tax disputes, or validated transfer pricing determinations-with timelines generally governed by a four year limitation reckoned from the end of the relevant financial year or specified event, and subject to procedural safeguards and cross references to amendment and limitation provisions.

Rectification of mistake: tax authorities may amend orders and intimations, with notice and hearing before raising liability.
Section 287 authorises specified income tax authorities to amend orders and intimations to rectify mistakes apparent from the record, excluding matters considered and decided in appeal or revision. Amendments that increase liability require notice of intention and a reasonable opportunity of being heard; reductions in liability require refund by the Assessing Officer and increases require service of a notice of demand. A four year outer limitation from the end of the financial year of the original order or intimation applies, subject to section 288, and taxpayer applications must be disposed within six months of the relevant month end.

Time limits for tax assessments impose short limitation windows, with tolling for procedural delays and transfer pricing processes.
Section 286 prescribes specific limitation periods for assessments, reassessments and recomputations linked to dates in a statutory table, generally imposing one year windows with limited shorter periods; it provides a 12 month extension where a Transfer Pricing Officer reference is made, enumerates discrete exclusion/tolling events (including hearings, stays, audit and valuation references, advance ruling applications, exchange of information references, declarations under anti avoidance provisions and search/requisition periods), and supplies minimum residual time and remedial extension rules to ensure Assessing Officers retain a baseline time to conclude proceedings.

Mandatory cessation of reassessment proceedings when taxpayer demonstrates assessed amount meets correct liability, limiting assessing officer discretion.
Section 285 fixes tax in section 279 proceedings at rates as if escaped income were included, conditions mandatory cessation of those proceedings on two cumulative showings by the assessee (assessment not lower than correct liability or properly made assessment/computation, and absence of any impugnment under specified challenge provisions), and renders final that cessation by barring reopening of matters concluded by listed orders; procedural modalities and evidentiary standards are not specified.

Assessment notices to implement appellate orders may be issued at any time, subject to existing time-bar exceptions.
Clause 283 permits issuance of a section 280 notice at any time to make assessments, reassessments or recomputations to give effect to appellate orders or Approving Panel directions, but it does not apply where, at the time the triggering order or reference occurred, other statutory time-limiting provisions already precluded assessment for the tax year concerned; the enacted text narrows the express override language compared with the Bill, potentially limiting displacement of constraints within the omitted procedural provision.