Evolving Tax Deduction at Source Framework for Business Trusts in India : Clause 393(1)[Table: S.No. 4(ii)], Clause 393(2)[Table: S.No. 6 & 7], and Clause 393(4)[Table: S.No. 5, 13] of the Income Tax Bill, 2025 Vs. Section 194LBA of the Income-tax Act, 1961

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.