Modernizing Withholding Tax on Non-Resident Unit Income : Clause 393(2)[Table: S.No. 10] and Clause 393(4)[Table: S.No. 15] of the Income Tax Bill, 2025 Vs. Section 196A of the Income-tax Act, 1961

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.