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Tax Deduction at Source clarifies withholding obligations on cross border bond and GDR payments to non residents, including DTAA interaction.
Clause 393(2) Table S. No. 13 and 14 requires withholding on payments to non residents of interest or dividends and long term capital gains from bonds and GDRs referred to in section 209, mandates deduction at the earlier of credit or payment by any person responsible for the payment, prescribes fixed concessional withholding rates, integrates general TDS machinery including declarations and higher deduction for missing PAN, and preserves DTAA relief and exceptions where income is not chargeable.
Act Rules Bills
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TDS on offshore fund income and capital gains: withholding at credit or payment, with higher exit withholding and treaty considerations.
Clause 393(2) requires any person paying income in respect of specified units or long term capital gains on transfer of such units to deduct tax at source at the prescribed rates at the time of credit or payment, without any monetary threshold; the provision cross refers to definitions in section 208, deems credits to suspense accounts as payment for TDS, and is subject to subsections dealing with exceptions, declarations and specified exclusions, while raising interpretative issues on definitions, treaty interaction, gross up obligations and transitional treatment compared with the prior Section 196B regime.
Act Rules Bills
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Withholding tax on non-resident unit income: consolidation preserves treaty relief and UTI exemption under prescribed conditions.
Clause 393 consolidates TDS on income in respect of units paid to non-residents: Clause 393(2) requires deduction by any payer on units of specified mutual funds and specified companies paid to non-resident individuals and foreign companies at rates per Note 2 with DTAA benefits subject to prescribed documentation; Clause 393(4) exempts income on Unit Trust of India units payable to NRIs and non-resident HUFs subject to prescribed conditions and FEMA compliance, thereby retaining the legacy UTI carve-out while delegating exemption details to subordinate rules.
Act Rules Bills
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TDS exemption for specified public entities prevents withholding on interest, dividends and other income, simplifying payer compliance.
Clause 393(5) provides an overriding TDS exemption for payments to the Government, the Reserve Bank of India, statutorily tax exempt corporations established by or under a Central Act, and mutual funds specified in Schedule VII, covering interest, dividends (in respect of securities or shares owned by or in which they have full beneficial interest) and any other income accruing or arising to them, with the non obstante language ensuring the exemption prevails over other withholding obligations.
Act Rules Bills
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Grossing-up requirement preserves tax base where payer bears recipient's tax liability, altering TDS computation and compliance.
Clause 393(10) mandates a grossing-up requirement where the payer bears the recipient's tax: taxable income must be increased so that, after deduction of tax at the rates provided in the Chapter (including applicable surcharge and cess), the net amount equals the contractual payment. The clause applies to TDS payments under the Chapter except specified salary cases, covers residents and non residents, and requires use of the applicable DTAA rate when beneficial. Key practical issues include computation of add ons, allocation across composite payments, currency fluctuation effects, and contract drafting to evidence net of tax obligations.
Act Rules Bills
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TDS on payments to non-residents: a table-based framework modernizes withholding obligations and aligns rates with treaty benefits.
Clause 393(2) Table S.No.17 imposes a residuary TDS obligation on interest (excluding specified categories) and any other sum chargeable under the Act, excluding salaries, payable to non-residents or foreign companies; deduction is by "any person" at the earlier of credit or payment at the "rates in force," with treaty rates available subject to procedural compliance, and operates alongside exemptions, lower/nil deduction certificates, suspense-account deeming rules and grossing-up anti-avoidance provisions.
Act Rules Bills
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TDS on partner payments: mandatory withholding on specified firm-to-partner payments with prescribed threshold and compliance duties.
Mandatory withholding applies to sums in the nature of salary, remuneration, commission, bonus or interest paid or credited (including to the capital account) by a firm to a partner, deductible at ten per cent at the earlier of credit or payment, with a per-partner annual threshold exemption and declaration-based non-deduction mechanisms; the firm bears the deduction obligation and normal TDS procedures apply.
Act Rules Bills
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TDS on virtual digital assets imposes withholding obligations with targeted exemptions for small-value and small-taxpayer transfers.
The Bill requires withholding on any benefit or perquisite arising from business or profession whether cash or non-cash, obliges the provider to deduct tax and, if consideration is wholly or partly in kind with insufficient cash, to ensure tax payment before release. A parallel VDA withholding regime mandates deduction on transfers of virtual digital assets with specified exemptions for small-value transactions and small taxpayers, similar safeguards for non-cash consideration, and procedural rules addressing timing, aggregation and crediting for compliance.
Act Rules Bills
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TDS on non-monetary benefits: providers must withhold tax on in-kind and indirect business advantages, affecting compliance and valuation.
Clause 393(1)[Table: S.No. 8(iv)] and section 194R require the provider of any benefit or perquisite arising from business or profession to deduct tax at source on the value or aggregate value of such benefits, covering cash and non-cash advantages, with specified thresholds and exemptions for smaller providers; the Bill consolidates this obligation, clarifies anti-overlap treatment with other TDS provisions, links timing of deduction to credit or payment, and preserves reliance on administrative guidance for valuation and operational issues.
Act Rules Bills
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TDS on purchase of goods: buyer withholding required, with precedence rules to avoid overlap with other withholding provisions.
Clause 393(1)[Table: S.No. 8(ii)] imposes a TDS obligation on the buyer to deduct tax on purchases of goods from resident sellers once aggregate purchases from a seller in a financial year exceed the specified threshold, with deduction due at credit or payment, and a broad exclusionary clause preventing application where tax is deductible or collectible under any other provision of the Act.
Act Rules Bills
Show AI Summary
TDS on specified senior citizens centralises tax deduction at banks, relieving return filing when tax is correctly deducted at source.
Specified banks are required to compute a specified senior citizen's total income after allowing Chapter VIII deductions and rebate, deduct tax at rates in force with a nil threshold, and remit TDS; an express precedence clause ensures this provision overrides other TDS provisions. The mechanism centralises compliance with banks obtaining declarations, maintaining evidence and records, thereby relieving eligible senior citizens from return filing provided the bank correctly applies deductions and remits tax.
Act Rules Bills
Show AI Summary
TDS on e-commerce: operators must withhold on gross platform-facilitated sales, with a small-seller exemption on conditions.
E-commerce operators must withhold TDS on the gross amount of sales or services facilitated through their platforms, with withholding due at the earlier of credit or payment and including direct buyer payments as deemed payments by the operator. Deductions apply on a gross basis without netting fees, exclude operator receipts for unrelated services such as advertising, and take precedence over other TDS provisions. Individual and HUF participants with annual turnover below the legislated threshold who furnish PAN or Aadhaar are exempt from withholding.
Act Rules Bills
Show AI Summary
TDS on large cash withdrawals: deduction at payment with exemptions for banks and regulated intermediaries, non filer rule absent here.
Clause 393(3) requires banks, co operative societies engaged in banking and post offices to deduct two per cent TDS at the time of cash payment where aggregate withdrawals from one or more accounts of a recipient exceed prescribed thresholds, with a higher threshold for co operative societies; Clause 393(4) exempts payments to the Government, banks, post offices, regulated business correspondents and authorised white label ATM operators. The Bill mirrors the existing framework but, in the extracted text, omits an explicit non filer regime and express central government notification powers, creating potential operational and interpretive uncertainty.
Act Rules Bills
Show AI Summary
TDS on high-value payments by individuals/HUFs expands withholding obligations for contractual, professional and commission disbursements.
Clause 393(1)[Table: S.No. 6(ii)] requires TDS by individuals or HUFs (not otherwise liable under specified TDS entries) on payments to a resident for carrying out work (including supply of labour), fees for professional services, or commission/brokerage (excluding insurance commission) where aggregate payments to the payee in a tax year exceed a prescribed threshold; deduction is at the time of credit or payment and the clause is integrated into a tabular TDS framework necessitating aggregation, with definitions and certain procedural relaxations left to rules or guidance.
Act Rules Bills
Show AI Summary
TDS on interest for foreign borrowings consolidated under new clause, keeping concessional framework but raising definitional and transition issues.
Clause 393(2) consolidates concessional TDS treatment for interest to non residents on foreign currency borrowings, rupee denominated bonds and IFSC listed bonds, aligning mechanics and cut off windows with Section 194LC while differing in presentation and reliance on external definitions; Central Government approval remains a condition for specified instruments and drafting gaps on limits, definitions and transitional treatment may require subordinate rules to avoid interpretive disputes.
Act Rules Bills
Show AI Summary
TDS on securitisation trust distributions: uniform 10% for residents, treaty rates for non-residents, no threshold.
Clause 393 mandates TDS on distributions by a securitisation trust: Clause 393(1) imposes 10% TDS on any income paid to resident investors with no threshold, deducted at the earlier of credit or payment by the trust; Clause 393(2) requires withholding on non-resident investors at rates in force, permitting treaty relief. Both provisions treat credits (including to suspense accounts) as TDS events and require trusts to maintain documentation of payee status and treaty claims.
Act Rules Bills
Show AI Summary
TDS on investment fund distributions: withholding applies, with treaty relief and exemptions for non taxable income.
TDS on distributions by investment funds requires withholding at applicable resident and non resident rates at the earlier of credit or payment, excluding any portion of income that is statutorily exempt. Funds must determine and segregate taxable versus exempt portions of mixed income, apply treaty or domestic rates for non residents upon proper documentation, and maintain records to support exemptions or reduced rates, while coordinating these obligations with other TDS provisions to avoid double deduction.
Act Rules Bills
Show AI Summary
TDS on business trust distributions: differentiated resident/non resident rates and SPV contingent exemptions under the Income Tax Bill, 2025.
Clause 393 of the Income Tax Bill, 2025 mandates 10% TDS on distributed income to resident unitholders, differentiated rates for non-resident unitholders (including lower rates for certain interest-type distributions and "rates in force" for others), and exempts specified distributions from TDS where the underlying SPV has not opted for the concessional tax regime, thereby tying withholding obligations to the SPV's tax-regime choice.
Act Rules Bills
Show AI Summary
TDS on infrastructure debt fund interest: concessional withholding retained for non-resident investors, deducted at credit or payment.
Clause 393(2)[Table: S.No. 5] retains a concessional TDS regime for any income by way of interest paid by an infrastructure debt fund listed in Schedule VII to a non resident (including foreign companies), requiring deduction at source at the specified concessional rate at the earlier of credit or payment, with no monetary threshold, and integrated within the Bill's harmonised TDS framework that addresses procedural rules, exceptions, grossing up, and interaction with double taxation treaties.
Act Rules Bills
Show AI Summary
TDS on land acquisition compensation maintained; threshold and RFCTLARR Act exemptions preserved, procedural consolidation introduced.
Clause 393 of the Income Tax Bill, 2025 mandates TDS at 10% on any sum in the nature of compensation or enhanced compensation, or consideration or enhanced consideration, for compulsory acquisition of immovable property (other than agricultural land), when amounts paid or credited to a resident exceed Rs. 5,00,000 in a financial year; Clause 393(4) exempts awards or agreements exempt from income-tax under the RFCTLARR Act, and deduction is required at the earlier of payment or credit.

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AMENDMENTS TO DUTY RATES IN FIRST SCHEDULE TO THE CUSTOMS TARIFF ACT, 1975

1 February, 2025

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Union Budget 2025-26 (Full) + Finance Bill, 2025

III. AMENDMENTS TO DUTY RATES IN FIRST SCHEDULE TO THE CUSTOMS TARIFF ACT, 1975

A.

Increase in Tariff rate (to be effective from 02.02.2025) * [Clause 98 (a) of the Finance Bill, 2025] *Will come into effect immediately through a declaration under the Provisional Collection of Taxes Act, 2023

Rate of Duty

S. No.

Tariff item

Commodity

From

To

 

 

Textile

 

 

1.

6004 10 00

6004 90 00

6006 22 00

6006 31 00

6006 32 00

6006 33 00

6006 34 00

6006 42 00

6006 90 00

Knitted Fabrics

20%/10%

20% or Rs115/kg,

whichever is

higher

 

 

IT & Electronics sector

 

 

2.

8528 59 00

Interactive Flat Panel Displays (Completely Built Units)

10%

20%

B.

Decrease in Tariff rate (to be effective from 01.05.2025 unless otherwise specified) * [Clause 98 (b) of the Finance Bill, 2025] Note: These changes will be effective from 2nd

February, 2025 by issuance of notification.

Rate of Duty

S. No.

Heading, subheading,

tariff

item

Commodity

From

To

1.

25151100

2515 12

Marble and travertine, crude or roughly trimmed, merely cut into blocks, slabs and other

40%

20%

2

2516 11 00

2516 12 00

Granite, crude or roughly trimmed,

merely cut into blocks, slabs and

other

40%

20%

3.

2933 59

Other compounds containing a pyrimidine ring (whether or not hydrogenated) or piperazine ring in the structure

10%

7.5%

4.

3302 10

Synthetic flavouring essences and

mixtures of odoriferous substances

of a kind used in food and drink

industries

100%

20%

5.

3406

Candles, tapers and the like

25%

20%

6

3822 90

Reference Materials

30%

10%

7

3824 60

Sorbitol other than that of subheading

2905 44

30%

20%

8

3920

Other, plates, sheets, films, foil and

strip, of plastics, non-cellular and

not reinforced, laminated,

supported or similarly combined

with other materials

25%

20%

9.

3921

Other plates, sheet, film, foil and strip of plastics

25%

20%

10.

6401

Waterproof Footwear with outer soles and Uppers of Rubber or of plastics, the uppers of which are neither fixed to the sole nor assembled by stitching, riveting, nailing, screwing, plugging or similar processes

35%

20%

11.

6402

Other footwear with outer soles and uppers of rubber or plastics

35%

20%

12.

6403

Footwear with outer soles of rubber, plastics, leather or composition leather and uppers of leather

35%

20%

13.

6404

Footwear with outer soles of rubber, plastics, leather or composition leather and uppers of textile materials

35%

20%

14.

6405

Other Footwear

35%

20%

15.

6802 10 00

6802 21 10

6802 21 20

6802 21 90

6802 23 10

6802 23 90

6802 29 00

6802 91 00

6802 92 00

6802 93 00

Worked monumental or building stone

40%

20%

16.

7113

Articles of Jewellery and parts thereof

25%

20%

17.

7114

Articles of goldsmiths’ and silversmiths’ ware’s and parts thereof

25%

20%

18.

7404 00 12 7404 00 19

7404 00 22

Copper Waste and Scrap

2.5%

Nil

19.

8002

Tin Waste and Scrap

5%

Nil

20.

8101 97 00

Tungsten Waste and Scrap

5%

Nil

21.

8102 97 00

Molybdenum Waste and Scrap

5%

Nil

22.

8103 30 00

Tantalum Waste and Scrap

5%

Nil

23.

8105 30 00

Cobalt Waste and Scrap

5%

Nil

24.

8106 90 10

Waste and Scrap of Bismuth and Bismuth alloys

5%

Nil

25.

8109 31 00, 8109 39 00

Zirconium Waste and Scrap

10%

Nil

26.

8110 20 00

Antimony Waste and Scrap

2.5%

Nil

27.

8112 13 00

Beryllium Waste and Scrap

5%

Nil

28.

8112 41 20

Rhenium Waste and Scrap

10%

Nil

29.

8112 61 00

Cadmium Waste and Scrap

5%

Nil

30.

8541 42 00

Solar Cells

25%

20%

31.

8541 43 00  8541 49 00

Solar Module and Other semiconductor devices and photovoltaic cells

40%

20%

32.

8702

Motor vehicles for transport of 10 or more persons

40%

20%

33.

8703

Motor cars and other motor vehicles principally designed for the transport of persons (other than those of heading 8702)

125%

70%

34.

8704

Motor vehicles for transport of goods

40%

20%

35.

8711

Motorcycles and cycles fitted with an auxiliary motor with or without side-car

100%

70%

36.

8712 00 10

Bicycles

35%

20%

37.

8903

Yachts and other vessels for pleasure or sports; rowing boats and canoes

25%

20%

38.

9028 30 10

Electricity meters for alternating current (Smart meter)

25%

20%

39.

9401

Seats (other than those of headings 9402), whether or not convertible into beds, and parts thereof

25%

20%

40.

9403

Other furniture and parts thereof

25%

20%

41.

9404

Mattress supports, articles of bedding and similar furnishing etc.

25%

20%

42.

9405

Luminaries and lighting fittings including searchlights and spotlights and parts thereof etc.

25%

20%

43.

9503 00 91

Parts of electronic toys

70%

20%

44.

9802 00 00

Laboratory Chemicals

150%

70%

45.

9803 00 00

All dutiable articles, imported by a passenger or a member of a crew in his baggage

100%

70%

46.

9804 00 00

All dutiable goods imported for personal use.

35%

20%

C.

Tariff rate changes (without change in existing effective rate of duty) to be effective from 01.05.2025 unless otherwise specified [Clause 98 (b) of the Finance Bill, 2025]

Rate of Duty

S. No.

Heading, sub- heading tariff item

Commodity

From

To

1.

1520 00 00

Glycerol Crude, glycerol waters, glycerol lye

30%

20%

2.

2603 00 00

Copper Ores and concentrates

2.5%

Nil

3.

2605 00 00

Cobalt Ores and concentrates

2.5%

Nil

4.

2609 00 00

Tin Ores and concentrates

2.5%

Nil

5.

2611 00 00

Tungsten Ores and concentrates

2.5%

Nil

6.

2613 00 00

Molybdenum Ores and concentrates

2.5%

Nil

7.

2615 10 00

Zirconium Ores and concentrates

2.5%

Nil

8.

2615 90 10

Vanadium Ores and concentrates

2.5%

Nil

9.

2615 90 20

Niobium or Tantalum Ores and concentrates

2.5%

Nil

10.

2617 10 00

Antimony Ores and Concentrates

2.5%

Nil

11.

2711 12 00

Liquefied Propane

15%

2.5%

12.

2711 13 00

Liquefied Butane

15%

2.5%

13.

27 11 19 10

LPG (for non-automotive purpose)

15%

5%

14.

2711 19 20

LPG (for automotive purpose)

15%

5%

15.

2711 19 90

Other liquified petroleum gas

15%

5%

16.

2809 20 10

Phosphoric Acid

20%

7.5%

17.

2810 00 20

Boric Acid

27.5%

7.5%

18.

3824 99 00

Other – Prepared Binders, chemical products and preparations of chemical or allied industries

17.5%

7.5%

19.

7210 12 10

OTS/MR type-flat rolled products of thickness less than 0.5 mm

27.5%

15%

20.

7210 12 90

Other flat rolled products of thickness less than 0.5 mm

27.5%

15%

21.

7219 12 00

Hot-rolled products in coils of thickness greater than or equal to 4.75 mm, but not exceeding 10 mm

22.5%

15%

22.

7219 13 00

Hot-rolled products in coils of thickness greater than or equal to 3 mm but less than 4.75 mm

22.5%

15%

23.

7219 21 90

Flat rolled products of stainless steel of width 600 mm or more - Other nickel chromium austenitic type

22.5%

15%

24.

7219 90 90

Flat rolled products of stainless steel of width 600 mm or more - Other sheets and plates

22.5%

15%

25.

7225 11 00

Flat-rolled products of other alloy steel - grain oriented, silicon electrical steel

20%

15%

26.

7307 29 00

Other tube or pipe fittings of stainless steel

25%

15%

27.

7307 99 90

Other fittings of iron or steel, non- galvanised

25%

15%

28.

7308 90 90

Other structure and parts of structures of iron and steel

25%

15%

29.

7310 29 90

Others-tanks and drums etc.

25%

15%

30.

7318 15 00

Other screws and bolts whether or with nuts or washers

25%

15%

31.

7318 16 00

Threaded nuts

25%

15%

32.

7318 29 90

Other non-threaded articles

25%

15%

33.

7320 90 90

Other springs and leaves of iron/steel

25%

15%

34.

7325 99 99

Other cast articles of iron or steel

25%

15%

35.

7326 19 90

Others - forged or stamped articles of iron or steel but not further worked

25%

15%

36.

7326 90 99

Miscellaneous other articles of iron/steel

25%

15%

37.

8001

Unwrought Tin

5%

Nil

38.

8101 94 00

Unwrought tungsten, including bars and rods obtained simply by sintering

5%

Nil

39.

8102 94 00

Unwrought molybdenum, including bars and rods obtained simply by sintering

5%

Nil

40.

8103 20

Unwrought tantalum, including bars and rods obtained simply by sintering, powders

5%

Nil

41.

8105 20 20

Cobalt, unwrought

5%

Nil

42.

8106 10 10

Bismuth, unwrought

5%

Nil

43.

8109 21 00

Unwrought zirconium, powders, containing less than 1 part hafnium to 500 parts zirconium by weight

10%

Nil

44.

8110 10 00

Unwrought antimony, powders

2.5%

Nil

45.

8112 12 00

Beryllium unwrought, powders

5%

Nil

46.

8112 31

Hafnium unwrought, waste and scrap, powders

10%

Nil

47.

8112 41 10

Rhenium unwrought

10%

Nil

48.

8112 69 10

Cadmium unwrought, Powders

5%

Nil

49.

8112 69 20

Cadmium, wrought

5%

Nil

 


Full Text:

Union Budget 2025-26 (Full) + Finance Bill, 2025

Topics

Acts Income Tax