TDS on contractor payments upheld with clarified scope, invoice rules and procedural reporting for targeted exemptions.
Clause 393(1)[Table: S.No. 6(i)] applies TDS to sums for carrying out work, including supply of labour, payable by a designated person, preserving differential rates for individuals/HUFs and others, applying deduction at credit or payment, allowing exclusion of material where separately invoiced, and aggregating payments for threshold purposes, subject to specified exceptions and procedural requirements.

TDS on horse-race winnings: single-transaction threshold triggers deduction at payment, integrated into unified TDS framework.
Clause 393(3)[Table: S.No. 3] mandates TDS on horse-race winnings by bookmakers or licensed operators at prevailing rates where winnings in a single transaction exceed the threshold, requires deduction at payment irrespective of mode, and integrates these obligations into Clause 393's unified procedural framework while leaving open interpretive issues such as the definition of "single transaction," aggregation risk, and valuation of non-cash payouts.

TDS on online gaming winnings: mandatory source deduction on net winnings, requiring payer compliance, reporting, and collection for noncash prizes.
Clause 393(3)[Table: S.No. 2] mandates TDS on "any income by way of winnings from online game" payable or credited by "any person," requiring deduction at "rates in force" on net winnings (as per Note 1) at the time of payment or credit, irrespective of mode of payment including cash, kind, credits or digital assets; payer obligations include computation, deduction, remittance, certification and reporting, with standard consequences for non-compliance.

TDS on gaming winnings: tax must be deducted at payment with a single-transaction threshold and special rules for non-cash prizes.
Clause 393(3)[Table: S.No.1] requires payers to deduct tax at source at rates in force on winnings from lotteries, puzzles, card games, other games, gambling and betting at the time of payment. The provision applies to cash and in-kind prizes and uses a single-transaction threshold to trigger TDS; payers must ensure tax is paid before releasing non-cash prizes. Online gaming winnings are excluded from this sub-clause and treated separately. General TDS reporting and deposit obligations apply.

TDS on interest: Bill raises senior citizen threshold and consolidates exemptions, altering deductor obligations and clarifying procedures.
Clause 393(1)[Table: S.No. 5(ii) & 5(iii)] prescribes TDS on interest other than on securities by distinguishing banking companies, co operative banks and post offices (subject to higher thresholds) from other specified payers (subject to a lower threshold), fixing time of deduction as credit or payment whichever is earlier, retaining branch wise aggregation where core banking is absent, and allowing intra year adjustment; Clause 393(4)[Table: S.No. 7] lists exemptions mirroring institutional and co operative carve outs with turnover conditions and freezes new ad hoc notifications after the stipulated cutoff.

TDS on dividends: new Bill mandates deduction before distribution, retaining specified institutional and small-holder exemptions.
Clause 393(1) requires TDS on all dividends (including preference shares) paid by domestic companies to resident shareholders at a flat rate, deducted before any distribution; Clause 393(4) lists conditional exemptions for specified institutional investors, notified persons, and small individual shareholders receiving dividends by non-cash modes, with exemptions contingent on payee type, payment mode, and aggregate amounts during the tax year.

TDS on interest on securities: consolidated exemptions and clearer procedural rules to streamline withholding compliance.
The Bill reaffirms TDS on interest on securities payable to residents, requiring deduction at the earlier of credit or payment at prevailing rates, subject to an aggregate annual threshold. It consolidates instrument based and entity based exemptions in a notified table, preserves the government's notification power to add exemptions, and modernizes language to reflect current financial instruments. Procedural rules permit declarations for non deduction with clearer delivery and reporting timelines for payers, require documentation to justify non deduction, and emphasize tracking aggregate payments and timely reporting and deposit to improve compliance and reduce disputes.

Tax deduction at source on provident fund withdrawals ensures immediate withholding at payment for taxable lump sum withdrawals.
Clause 392(7) requires trustees or authorised persons of recognised provident funds to deduct tax at source at a uniform rate when paying accumulated balances that are includible in the employee's income because exemption conditions under the relevant schedule do not apply; the obligation arises at the time of payment and only where the aggregate payment exceeds a prescribed threshold, with trustees responsible for deposit, recordkeeping and issuing withholding certificates.

Tax Deduction at Source on Salaries modernizes employer TDS obligations and clarifies perquisite and reporting requirements.
Clause 392 modernizes Tax Deduction at Source on salaries by retaining the employer duty to deduct tax at the average rate on estimated salary payments, preserving the employer option to pay tax on non monetary perquisites (treated as TDS), providing special timing for start up equity perquisites, and requiring employers to consider specified employee declarations (other salary, reliefs, house property loss, other income, and tax deducted elsewhere) subject to limitations on reductions. It mandates prescribed statements, evidence, record keeping, and permits intra year TDS adjustments, with procedural details to be set by rules.

Direct payment obligation makes the recipient liable where TDS is absent, with deductor deemed in default if both parties fail.
Clause 391 requires the recipient to pay income tax directly where TDS is not applicable or has not been deducted, includes a deferred payment mechanism for specified securities and sweat equity issued by eligible start-ups as per the Bill's timelines, and creates a deeming fiction rendering the deductor or employer an assessee-in-default if both deductor and assessee fail to discharge the liability, while preserving interest, penalty and crediting consequences.

Tax Collection at Source: payment obligations arise with income receipt and stand independent of later assessments.
Clause 390 mandates three modes of tax payment-deduction or collection at source, advance payment, and payment under section 392(2)(a)-to be effected "as per this Chapter," establishes that these obligations arise irrespective of later assessment proceedings, and includes a savings provision preserving the substantive charge to tax under section 4(1), thereby ensuring collection mechanisms do not affect the underlying tax liability.

Continuity of tax liability: dissolved firms treated as continuing for assessment, penalties, and recovery under new clause.
Clause 330 treats a dissolved or discontinued firm as continuing for assessment and recovery, empowering tax authorities to assess total income, impose penalties, and apply all Act provisions; it imposes joint and several liability on partners and legal representatives and permits continuation of proceedings at the stage they stood at dissolution, while preserving other relevant statutory provisions through a saving clause.

Joint and several liability of partners: partners and estates may be pursued for firm tax and related penalties under the new Bill.
The Bill imposes joint and several liability on every person who was a partner during the tax year and on the legal representatives of deceased partners for tax, penalty and other sums payable by the firm, allowing recovery from the firm or any partner and applying the Act's assessment, recovery and penalty machinery to such liabilities.

Succession of partnership firms requires separate assessments to apportion tax between predecessor and successor periods.
Clause 328 mandates separate assessments where a firm is succeeded by another: income up to succession is assessed in the predecessor's hands and income thereafter in the successor's hands, with procedural rules to be applied as per Section 313; the clause excludes cases covered by the provision addressing change in constitution, preserving the distinction between succession and mere partner changes.

Change in constitution of a firm: assessment on the firm as constituted at assessment time, preserving tax continuity.
Change in constitution of a firm provides that assessment shall be on the firm as constituted at the time of assessment where partners cease, new partners are admitted (with at least one pre existing partner continuing), or shares change; an exception preserves dissolution on the death of a partner. The clause modernizes language and cross references to updated assessment provisions, maintains continuity in tax liability, and places emphasis on partnership deeds, record keeping, and potential factual disputes over reconstitution versus succession.

Procedural compliance in partnership taxation: noncompliance bars firm deductions for partner payments while avoiding partner double taxation.
Clause 326 of the Income Tax Bill, 2025, applies where a partnership firm fails to comply with Clause 325 procedural requirements; it invokes a non-obstante override to disallow deductions for payments to partners described as interest, salary, bonus, commission or remuneration, and concurrently excludes those disallowed amounts from taxation in the hands of partners, mirroring the substantive effect of the earlier statute while updating cross-references and structure.

Firm assessment requirements: written certified partnership instrument needed, with non compliance causing denial of partner deductions.
Clause 325 requires that a partnership be evidenced by a written instrument specifying each partner's share and that a certified copy accompany the return when assessment as a firm is first sought; certification must be by all partners (excluding minors) or relevant predecessors/representatives on dissolution. Once assessed as a firm, continuity of assessment applies unless the firm's constitution or shares change, in which case a revised certified instrument must be filed and the conditions reapply. Failure to comply triggers denial of deductions for payments to partners and prevents those payments from being taxed in the partners' hands.

Director liability for unpaid company taxes: joint and several personal exposure subject to defence of absence of gross neglect.
Clause 323 imposes joint and several personal liability on every person who was a director at any time during the relevant tax year where tax due from a private company cannot be recovered, with "tax due" including penalty, interest, fees and other sums; the director may avoid liability only by proving that non recovery was not attributable to gross neglect, misfeasance or breach of duty, and the provision overrides contrary company law provisions.

Liquidator personal liability: enforced civil responsibility to secure tax dues during liquidation while aligning with insolvency priorities.
Clause 322 requires any liquidator or receiver to notify the assessing officer within thirty days of appointment and, after the assessing officer notifies an amount sufficient to cover tax liabilities (within three months), to set aside that sum and refrain from disposing of assets without leave; exceptions permit payment of tax, secured creditors with legal priority, and reasonable winding up expenses. Non compliance attracts personal civil liability for the liquidator, capped at the notified amount where applicable, and obligations are joint and several, with Clause 322 subject to the primacy of the Insolvency and Bankruptcy Code.

Assessment continuity: Dissolution of an AOP does not prevent assessment, penalty imposition, or recovery from members.
Clause 321 permits assessment of an association of persons as if no discontinuance or dissolution had taken place, applying all statutory provisions including penalties and other sums. It empowers original and appellate officers to impose penalties specified in the penalty chapter, imposes joint and several liability on members and their legal representatives, and allows continuation of proceedings already commenced against such persons from the stage they stood at dissolution. A saving clause preserves interaction with specified cross referenced provisions.