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of <h1>Income Tax Bill 2025 Clause 438 allows tax authorities to set off refunds against outstanding liabilities with procedural safeguards</h1> The Income Tax Bill 2025's Clause 438 empowers tax authorities to set off refunds against outstanding tax liabilities and withhold refunds when assessment proceedings are pending. The provision requires written intimation before set-off and limits withholding to sixty days from assessment completion, with recorded reasons and higher-level approval required. This largely mirrors Section 245 of the Income-tax Act 1961, but removes the subjective 'adverse effect on revenue' criterion for withholding, creating greater objectivity and predictability. The clause balances revenue protection with taxpayer rights through procedural safeguards including mandatory written intimation and time-bound withholding periods.
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