Concessional Taxation for Manufacturing Domestic Companies : Clause 199 of Income Tax Bill, 2025 Vs. Section 115BA of Income-tax Act, 1961

Concessional tax regime for manufacturing companies requires irrevocable option and prohibits set off of attributable losses.

Clause 199 creates a concessional tax regime for qualifying domestic manufacturing companies, available at the taxpayer's option, conditioned on exclusive engagement in manufacturing related activities and computed without specified deductions. It precludes set off of losses attributable to those disallowed deductions by deeming such losses to have been fully given effect to. The option must be exercised in the prescribed manner by the due date for the first return and, once exercised, is irrevocable for subsequent years except where a statutory switch is permitted, thereby trading lower tax rates for forfeiture of targeted incentives and necessitating clear procedural compliance.