Loading...

⚠ ✕
❮ Top
☎ Help
☰
×

By creating an account you can:

Logo TaxTMI
Call Us / Help / Feedback✕

Contact Us At :

✉ E-mail: [email protected]

✆ Call / WhatsApp at: +91 99117 96707

For more information, Check Contact Us

FAQs :

To know Frequently Asked Questions, Check FAQs

Most Asked Video Tutorials :

For more tutorials, Check Video Tutorials

Submit Feedback/Suggestion :

Email :
Please provide your email address so we can follow up on your feedback.
Category :
Description :
Min 15 characters 0/2000
Make Most of Text Search ✕
  1. Checkout this video tutorial: How to search effectively on TaxTMI.
  2. Put words in double quotes for exact word search, eg: "income tax"
  3. Avoid noise words such as : 'and, of, the, a'
  4. Sort by Relevance to get the most relevant document.
  5. Press Enter to add multiple terms/multiple phrases, and then click on Search to Search.
  6. Text Search
  7. The system will try to fetch results that contains ALL your words.
  8. Once you add keywords, you'll see a new 'Search In' filter that makes your results even more precise.
  9. Text Search
╳
Add to...
You have not created any category. Kindly create one to bookmark this item!
✕
Create New Category
Hide
Title :
Description :
❮❮ Hide
❮ Default View
Expand ❯❯
Close ✕
🔎 Filters / Advanced Search ❯
TEXT

Press 'Enter' to add multiple search terms. Rules for Better Search

Search In
Main Text + AI Text ❯
  • Main Text
  • Main Text + AI Text
  • AI Text
Law:
---- All Laws---- ❯
  • ---- All Laws----
  • Benami Property
  • Bill
  • Central Excise
  • Companies Law
  • Customs
  • DGFT
  • FEMA
  • GST
  • GST - States
  • IBC
  • Income Tax
  • Indian Laws
  • Money Laundering
  • SEBI
  • SEZ
  • Service Tax
  • VAT / Sales Tax
Types:
---- All Types ---- ❯
  • ---- All Types ----
  • Act Rules
  • Case Laws
  • Circulars
  • Manuals
  • News
  • Notifications
Sort By: ?
In Sort By 'Default', exact matches for text search are shown at the top, followed by the remaining results in their regular order.
Relevance Default Date
    Act Rules Income Tax
    Comparison of Section 21 "Determination of annual value" between the Income-Tax Act, 2025 (as passed...
    Act Rules Income Tax
    Comparison of Section 19 "Deductions from salaries" between the Income-Tax Act, 2025 (as passed) and...
    Act Rules Income Tax
    Comparison of Section 17 "Perquisite" between the Income-Tax Act, 2025 (as passed) and the Income-Ta...
    Act Rules Income Tax
    Comparison of Section 11 "Incomes not included in total income" between the Income-Tax Act, 2025 (as...
    Act Rules Income Tax
    Comparison of Section 9 "Income deemed to accrue or arise in India" between the Income-Tax Act, 2025...
    Act Rules Income Tax
    Comparison of Section 8 "Income on receipt of capital asset or stock-in-trade by specified person" b...
    Act Rules Income Tax
    Comparison of Section 6 "Residence in India" between the Income-Tax Act, 2025 (as passed) and the In...
    Act Rules Income Tax
    Comparison of Section 5 "Scope of total income" between the Income-Tax Act, 2025 (as passed) and the...
    Act Rules Income Tax
    Comparison of Section 4 “BASIS OF CHARGE” between the Income‑Tax Act, 2025 (as passe...
    Act Rules Income Tax
    Comparison of Section 2(105) "Stamp duty value" between the Income‑Tax Act, 2025 (as pas...
    Act Rules Income Tax
    Comparison of Section 2(101) "short-term capital asset" between the Income‑Tax Act, 2025...
    Act Rules Income Tax
    Comparison of Section 2(29) "Company in which the public are substantially interested" between...
    Act Rules Income Tax
    Comparison of Section 2(28) "Company" between the Income-Tax Act, 2025 (as passed) and the Income-Ta...
    Act Rules Income Tax
    Comparison of Section 2(22) "Capital Assets" between the Income-Tax Act, 2025 (as passed) and the In...
    Case Laws Income Tax
    Remuneration and interest received by an individual partner from a partnership firm can be subjected...
    Case Laws Income Tax
    Judicial Recall and Tax Implications in Trust Settlements: Using AI-generated citations without prop...
    Case Laws Income Tax
    Corporate Mergers and Tax Assessment: Navigating Legal Entity Changes and rectification u/s 292B
    Case Laws Income Tax
    Reconciling Procedural Timelines with Limitation Periods in Income Tax Reassessments
    Case Laws Income Tax
    Condoning Delay in Filing Income Tax Return: A Case for Equitable Consideration
    Case Laws Income Tax
    Disallowance u/s 14A: Navigating the Interplay of Exempt Income and Expenditure
❮
❯
❯❯
Maximize Maximize Maximize
0 / 200
Expand Note
Add to Folder

No Folders have been created

+

Are you sure you want to delete "My most important" ?

NOTE:

Notes
Showing Results for :
Reset Filters
Results Found:
Show All Summaries Hide All Summaries
Act Rules Income Tax
Show AI Summary
Determination of annual value: higher of expected or actual rent, with narrowed vacancy test and specific exemptions.
Annual value is the higher of expected rent or actual rent received/receivable where let; the enacted text narrows vacancy relief by requiring that vacancy-related reduction make actual rent lower than the notional expected rent before annual value is fixed at actual receipts. Local taxes actually paid reduce annual value, unrealised rent is excluded subject to rules, stock-in-trade newly completed and not let enjoys two years nil annual value upon completion certificate, and owner-occupation yields nil annual value for up to two specified houses unless let or other benefits are derived.
Act Rules Income Tax
Show AI Summary
Deductions from salaries: defined categories, formulaic computation and aggregation limits govern tax relief eligibility.
Section 19 itemises fourteen categories of salary related receipts that are deductible or exempt and prescribes formulas, ceilings and conditions for each. Relief for gratuity, leave encashment, pension commutation, retrenchment and voluntary retirement is computed by statutory formulas or by reference to notified limits and other enactments; an aggregation rule limits cumulative exemption where multiple receipts occur. The provision depends on cross references to other statutes and notifications, requiring classification, documentary evidence and tracing of prior exemptions to determine allowable deductions.
Act Rules Income Tax
Show AI Summary
Perquisite taxation: employer-provided benefits and securities treated as taxable salary components, with limited exclusions and prescribed valuation.
Section 17 defines perquisite for salary taxation by listing employer-provided benefits treated as perquisites-including accommodation, employer-paid obligations, securities and sweat equity allotted or transferred at concessional rates, employer-paid insurance premiums and excess retirement contributions-while excluding certain employer-funded medical treatment, approved insurance arrangements, commuting vehicle expenditure and conditional foreign medical/travel payments; valuation methods and thresholds are delegated to subordinate rules and cross-references link perquisite treatment to existing constructs for gross total income and approved fund schemes.
Act Rules Income Tax
Show AI Summary
Conditional exclusion from total income: schedule-based incomes and persons excluded if conditions met; otherwise included in tax base.
A conditional exclusion regime provides that incomes in Schedules II-VI and persons in Schedule VII are excluded from total income only if schedule conditions are satisfied; failure to satisfy conditions results in inclusion of such income in total income and taxation for the relevant tax year, and the Central Government is empowered to make rules or notifications to operationalise those schedules.
Act Rules Income Tax
Show AI Summary
Significant economic presence expands source taxation, bringing digital interactions and remote services within the domestic tax net.
Section 9 sets an expansive source taxation rule deeming income to accrue or arise domestically where linked to domestic assets, a business connection (including agents), transfers of capital assets situated domestically, salary earned or payable for services linked to domestic performance, dividends of domestic companies, interest subject to exceptions (including separate taxation of interest of an Indian permanent establishment of a foreign bank), and royalty and technical fees; it introduces significant economic presence tests for digital/user-based connections and leaves key thresholds and valuation mechanics to subordinate rules.
Act Rules Income Tax
Show AI Summary
Deemed transfer of distributed assets treated as taxable at entity level; fair market value sets consideration and guidelines now open-ended.
Section 8 treats receipt by a partner or member of capital assets or stock-in-trade from a non-company specified entity on dissolution or reconstitution as a deemed transfer by the entity, with profits or gains taxed at the entity level and the full value of consideration deemed to be the fair market value on the date of receipt; the Board may issue guidelines with prior Central Government approval and parliamentary laying, and the enacted text removes the Bill's two-year sunset on that guideline-making power.
Act Rules Income Tax
Show AI Summary
Residence in India: income-linked deeming now captures high-income returning citizens visiting short-term, and POEM defines company residence.
Section 6 prescribes residence tests combining day-count rules (182-day and 60/365 tests), categorical exceptions for ship crew and visiting citizens/PIOs, an income-linked modification that extends the shorter day-count threshold for higher-income returning citizens, a deeming rule capturing citizens not taxable elsewhere, company residence via Indian status or Place of Effective Management, and a deeming provision that applies residence across all income sources; As Passed drafting clarifies interplay between the visiting exception and income-based modification and contains minor typographical refinements.
Act Rules Income Tax
Show AI Summary
Scope of total income: residents taxed broadly with limited foreign income inclusion for not ordinarily resident persons.
Section 5 sets the scope of total income by applying receipt and accrual tests: residents are taxed on income received or deemed received in India, income accruing or arising or deemed to accrue or arise in India, and foreign income only in limited cases for a person who is not ordinarily resident (foreign income included when derived from a business controlled in India or a profession set up in India). Non residents are taxed on income received or deemed received in India and income accruing or arising or deemed to accrue or arise in India. The section also prevents balance sheet inclusion from constituting receipt and bars double inclusion on accrual and receipt bases.
Act Rules Income Tax
Show AI Summary
Charge of income-tax: linkage to central rates and application to total income, with withholding and advance payment obligations.
Section 4 links the charge of income-tax to rates enacted by a Central Act, charges income-tax on the total income of the tax year of every person (while allowing charging for other specified periods), includes any additional income-tax by whatever name, and requires deduction/collection at source and advance payment for income chargeable under the section.
Act Rules Income Tax
Show AI Summary
Stamp duty value treated as a notional benchmark for tax valuations, overriding conflicting valuation laws for tax purposes.
Section 2(105) defines stamp duty value as the value adopted, assessed or assessable by a Central or State authority for stamp duty on immovable property, where "assessable" is expressly a notional value the authority would have adopted if referred the matter, and that definition applies irrespective of anything to the contrary in any other law in force.
Act Rules Income Tax
Show AI Summary
Holding-period tiers determine capital gain classification with a shorter threshold for listed securities and specific fund units.
Definition of short-term capital asset establishes a two-tier holding-period regime for capital gains classification, retaining a general holding-period test and a shorter test for listed securities, units of the Unit Trust of India, units of equity-oriented funds and zero-coupon bonds; detailed rules determine inclusion, exclusion and commencement of holding periods on liquidation, corporate reorganisations, conversions, allotments, renunciations, free allotments and GDR redemptions, with certain technical matters deferred to prescribed rules.
Act Rules Income Tax
Show AI Summary
Definition of company in which the public are substantially interested: drafting variance may create conjunctive interpretation risk affecting tax classification.
Clause 2 supplies a comprehensive glossary for the Income-tax Act, 2025, defining terms such as company, capital asset, income and virtual digital asset, often with cross-references, provisos and delegated prescriptions; clause 2(29)'s categories for a company in which the public are substantially interested are materially consistent between Bill and Act, but the Bill's connector wording risked a conjunctive reading of alternative tests that the Act's later disjunctive phrasing rectifies, creating interpretive consequences for tax classification and related compliance.
Act Rules Income Tax
Show AI Summary
Definition of company clarified; temporal qualification in transitional limb may narrow which historic entities remain within tax scope.
Section 2 supplies statutory definitions that determine tax coverage. The definition of company comprises Indian companies, foreign bodies corporate, entities assessable as companies under the repealed Act, and Board declared entities. The Bill adds a temporal qualification limiting entities assessed under the prior Act to particular assessment years; the Act text omits this qualification. Scattered drafting and cross reference differences exist. Operational consequences hinge on threshold facts (shareholding, listing, assessment history, population/distance tests) and on unstated transitional provisions.
Act Rules Income Tax
Show AI Summary
Capital asset definition updated to include IFSC-regulated funds and broaden unit-linked policies, affecting capital gains treatment.
The Act retains an inclusive definition of capital asset with exceptions for stock-in-trade, specified personal effects and certain agricultural land, while refining the securities limb to expressly include securities held by FIIs and investment funds regulated under SEBI or IFSC regimes and removing a temporal issuance-date qualifier for unit-linked insurance policies, thereby broadening the category of policies treated as capital assets; numerous drafting and cross-reference clarifications aim to reduce interpretive uncertainty.
Case Laws Income Tax
Show AI Summary
Presumptive taxation: partner remuneration and interest cannot be treated as individual business turnover for presumptive tax purposes.
Section 44AD applies only where the assessee carries on an eligible business and has actual turnover or gross receipts attributable to that assessee. Remuneration and interest paid by a partnership firm to a partner arise from the firm's accounts and partnership agreement; although Section 28(v) taxes such receipts in the hands of the partner, that deeming does not convert them into the partner's turnover or gross receipts for Section 44AD. Section 40(b) governs firm deductibility but does not create an independent business activity in the partner; hence such receipts cannot be subjected to Section 44AD presumptive taxation.
Case Laws Income Tax
Show AI Summary
Trust settlement taxation: broadened construction of shares and securities may capture partnership interests, prompting citation verification.
The tribunal examined whether a trust permitting benefits beyond relatives falls within Section 56(2)(x), construed "shares and securities" to broaden taxable scope, and treated partnership interests as property under the provision. The earlier order was recalled after reliance on non-existent citations, highlighting the need for rigorous verification of precedents and research safeguards in trust taxation matters.
Case Laws Income Tax
Show AI Summary
Rectification of assessment orders cannot cure jurisdictional errors where orders name non-existent entities after mergers.
An assessment order issued in the name of a non-existent entity after a disclosed corporate amalgamation was held to be a fundamental, jurisdictional error not correctable under Section 154 or Section 292B; prior disclosure of the merger and absence of misleading conduct distinguished the case from precedents permitting clerical correction.
Case Laws Income Tax
Show AI Summary
Limitation periods: reassessment procedures must be completed within the overarching statutory period, else notices are time-barred.
The decision construes the interaction between procedural timelines for reassessment and the overarching limitation period, treating the mandatory pre-notice procedure requiring provision of material and an opportunity to respond as part of the reassessment process that must be completed within the ultimate limitation period; if the authority does not complete both the procedural order and issue the reassessment notice within the residual time remaining after statutory exclusions and extensions, the notice is time-barred.
Case Laws Income Tax
Show AI Summary
Condonation of delay: equitable consideration where bona fide technical failures and professional disruptions impede tax filing.
Condonation of short delays in filing income tax returns must be governed by principles of equity and fairness, with bona fide explanations such as portal technical failures and unforeseeable disruptions at a chartered accountant's premises meriting empathetic, case sensitive assessment rather than mechanical rejection. Where assessees rely on professional intermediaries, corroborative evidence of genuine operational impediments is a relevant consideration in exercising discretionary condonation to facilitate compliance objectives.
Case Laws Income Tax
Show AI Summary
Disallowance of expenditure related to exempt income: apportionment required and actual exempt income is a prerequisite.
Disallowance of expenditure relating to exempt income requires identification and apportionment of expenses attributable to non taxable receipts; only expenditure expended to earn taxable income may be claimed. Courts interpret "in relation to" expansively and reject reliance on the spender's dominant purpose. The existence of actual exempt income is necessary to invoke the disallowance rule, and post enactment explanatory amendments that alter prior law are not retrospective.

TMI Notes

Back

All TMI Notes

Showing Results for :
Reset Filters
No Records Found

TMI Notes

Back

All TMI Notes

Comparison of Section 48 "Tea development account, coffee development account and rubber development account" between the Income-Tax Act, 2025 (as passed) and the Income-Tax Bill, 2025 (as originally introduced)

26 August, 2025

Contents
Acts
Rules & Regulations
Summary
Note

Note

-

Bookmark

Print

Print

Section 48 Tea development account, coffee development account and rubber development account.

Income-tax Act, 2025

At a Glance

Clause 48 of the Income Tax Bill, 2025 (Old Version) provides for tax treatment of deposits into designated development accounts for tea, coffee and rubber and for recapture rules on withdrawal or disposal of assets acquired under the relevant schemes. It matters to taxpayers engaged in growing and manufacturing tea, coffee or rubber in India, and to the tax department administering deductions and recapture. Effective dates or enactment timing are Not stated in the document.

Background & Scope

Statutory hook: Clause 48 sits within the chapter on "Profits and gains of business or profession" in the Income Tax Bill, 2025 - that is, it addresses deductible deposits and subsequent chargeability to tax for certain primary-sector activities. The clause ties deductibility and recapture to "the provisions of the Schedule IX" (repeatedly).

The text provides limited definitional content: it identifies the relevant taxpayers as "an assessee ... carrying on business of growing and manufacturing tea or coffee or rubber in India" and references deposit accounts denominated as "tea development account, coffee development account or rubber development account or any other designated account." No statutory definitions for "designated account", "scheme", "deposit scheme", or "Schedule IX" are reproduced in the document; therefore, the precise mechanics and definitions are dependent on Schedule IX and other parts of the Bill/Act.

Statutory Provision Mode

Text & Scope

The clause has three sub-sections. Sub-section (1) states that an assessee engaged in growing and manufacturing tea, coffee or rubber in India "shall be allowed a deduction on the basis of deposits into the tea development account, coffee development account or rubber development account or any other designated account and computed as per the provisions of the Schedule IX." Sub-section (2) provides that any amount withdrawn, utilised or released "shall be charged to tax in the year in which the amount is transferred or withdrawn as per the provisions of the Schedule IX." Sub-section (3) imposes a recapture rule when an asset acquired under the scheme is sold or otherwise transferred by the assessee before the expiry of eight years from the end of the tax year in which it was acquired: "such part of the cost of such asset as is relatable to the deduction allowed under sub-section (1) shall be deemed to be the profits and gains of business or profession of the tax year in which the asset is sold or otherwise transferred and shall accordingly be chargeable to income-tax as the income of that tax year."

Interpretation

The clause establishes a regime of initial tax relief (deduction for qualifying deposits) followed by a recapture mechanism to neutralise tax benefit where withdrawals occur or assets are disposed of within a specified protective period. Legislative intent, as inferable from the text, is to incentivise deposits into sector-specific development accounts while preventing permanent tax avoidance by recapturing benefit on early withdrawal or premature disposal of assets acquired using those amounts. The explicit eight-year recapture period in sub-section (3) signals a policy choice to protect the revenue over a medium-term horizon; the deeming formula targets that portion of asset cost that corresponds to prior deductions, thereby effectuating partial reversal of tax benefit rather than full clawback of proceeds.

Exceptions/Provisos

Not stated in the document: any provisos, exceptions, exemptions, thresholds, or carve-outs beyond the three sub-sections reproduced. The clause itself contains no explicit provisos limiting application (for example, no treatment for transfers between related parties, no inflation adjustments, no apportionment rules beyond "such part of the cost ... as is relatable to the deduction"). Any further exceptions would need to be located in Schedule IX or elsewhere in the Bill.

Illustrations

  • Example 1: An assessee deposits funds into a "tea development account" and claims deduction computed under Schedule IX. If the assessee later withdraws those funds in a subsequent tax year, under Clause 48(2) the withdrawn amount is chargeable to tax in the tax year when the transfer/withdrawal occurs as per Schedule IX.

  • Example 2: An assessee uses deposited funds to acquire machinery under the scheme; if the machine is sold by the assessee within eight years from the end of the tax year of acquisition, the portion of the asset's cost that is attributable to the earlier deduction is "deemed to be the profits and gains" of the year of sale and taxed accordingly (i.e., recapture of benefit).

  • Example 3: Not stated in the document: how apportionment is to be calculated for part disposals, or treatment on sale to related parties; therefore specifics on such illustrations are Not stated in the document.

Interplay

The clause repeatedly instructs that computation and chargeability are "as per the provisions of the Schedule IX." Therefore, detailed operational rules, calculation formulae, timings, compliance processes and potentially definitions are deferred to Schedule IX. No other Rules/Notifications/Circulars are mentioned in the reproduced text. Interaction with general anti-avoidance provisions, transfer pricing provisions, or other parts of the tax code is Not stated in the document.

Differences between Section 48 of the Income-tax Act, 2025 and Clause 48 of the Income Tax Bill, 2025 (Old Version)

  • Specified account nomenclature and breadth: The Bill (Clause 48) expressly names "tea development account, coffee development account or rubber development account or any other designated account" as the basis for deduction; the enacted Section 48 refers more generically to "the special account or deposit account".
    • Practical impact: The Bill's language is more explicit about permitted account types and expressly contemplates additional "designated account(s)"; the Act's broader, less prescriptive phrasing may permit administrative flexibility but less clarity for taxpayers.
  • Timing of tax charge on withdrawals: Clause 48(2) (Bill) specifies that amounts "shall be charged to tax in the year in which the amount is transferred or withdrawn as per the provisions of the Schedule IX." Section 48(2) (Act) states that amounts "withdrawn or utilised or released from the aforesaid accounts at the time of closure or otherwise shall be charged to tax as per the provisions of the Schedule IX" (no explicit year-of-withdrawal phrasing).
    • Practical impact: The Bill provides clearer timing (tax year of transfer/withdrawal); the Act's formulation defers to Schedule IX but is potentially less precise about timing, which could create interpretive uncertainty about whether charge arises at closure, at withdrawal, or u/rs in Schedule IX.
  • Recapture on disposal of assets: Clause 48(3) (Bill) contains a specific deeming provision: where an asset acquired under the scheme is sold/transferred within eight years from the end of the tax year in which it was acquired, "such part of the cost of such asset as is relatable to the deduction allowed under sub-section (1) shall be deemed to be the profits and gains of business or profession" of the year of sale and charged accordingly. Section 48(3) (Act) is shorter and states that where any asset acquired as per the special scheme or deposit scheme is sold or otherwise transferred in any tax year, it "shall be charged to tax in accordance with the provisions of the said Schedule" (no eight-year period; no deeming of a relatable part of cost).
    • Practical impact: The Bill imposes a specific recapture window (8 years) and a deemed income mechanism that clearly recovers deductions previously claimed; the Act removes the explicit 8-year trigger and the specific deeming formula, deferring recapture mechanics to Schedule IX - potentially narrowing or broadening recapture depending on what Schedule IX specifies. Taxpayers face greater certainty under the Bill about recapture scope and timing, while the Act shifts the substantive rule into Schedule IX and may change the practical incidence of recapture.
  • Reference to "site restoration fund" and cross-purpose text: The Bill's explanatory note (as reproduced) mentions that Clauses 48 and 49 "provide for tea development account, coffee development account and rubber development account and Site Restoration Fund..." The clause text itself is focused on tea/coffee/rubber accounts. The Act version omits any accompanying note.
  • Practical impact: The Bill situates Clause 48 in a broader legislative design that includes site restoration for extractive activities; the Act, as excerpted, is self-contained and lacks that contextual pointer.
  • Terminology differences ("special scheme"/"deposit scheme" vs "scheme"/"deposit scheme"): The Act uses "special scheme or the deposit scheme"; the Bill uses "scheme or the deposit scheme."
    • Practical impact: Minor drafting variance; potential interpretive effect depends on definitions in the Bill/Act (not provided here).

Practical Implications

  • Compliance and risk areas: Taxpayers engaged in tea, coffee or rubber cultivation/manufacture who claim deductions under Clause 48 need to monitor withdrawals and the holding period of assets acquired under the scheme closely to determine recapture liabilities. The eight-year window imposes a medium-term compliance risk-early disposals create immediate tax charges under the deeming rule. The specific calculation of the "part of the cost ... relatable to the deduction" will be determinative; practitioners must consult Schedule IX for the precise methodology. Failure to follow the Schedule IX computation or to account for transfers/withdrawals in the year of event would expose taxpayers to assessments and interest/penalties (penalties/interest provisions Not stated in the document).
  • Record-keeping/evidence points: The clause implies the need for contemporaneous and durable records of deposits into the designated accounts, documentary evidence of use of deposited funds to acquire particular assets, acquisition dates, asset cost breakdowns, and records of any transfer/withdrawal or sale including dates and consideration. Records should support apportionment between deductible-funded cost and other funding. Schedule IX likely prescribes precise evidentiary requirements; absent that text, taxpayers should maintain detailed books documenting the flow of funds between bank accounts, account ledgers for the designated accounts, asset registers linking assets to sources of finance, and sale/transfer documentation.

Key Takeaways

  • Clause 48 establishes a conditional deduction for deposits into sector-specific development accounts for tea, coffee and rubber, with computation and operational detail delegated to Schedule IX.
  • Withdrawals or utilisations are taxable in the tax year of transfer/withdrawal in accordance with Schedule IX, creating timing certainty in the clause text (subject to Schedule IX specifics).
  • The clause contains an express eight-year recapture period for assets sold/transferred before expiry of that period, with a deeming rule targeting the portion of asset cost attributable to earlier deduction.
  • The clause does not provide detailed calculation, procedural, or exceptions language within the text; those details are left to Schedule IX and other parts of the Bill/Act.
  • Taxpayers must maintain records linking deposits to account entries and to assets acquired, and should anticipate recapture on early dispositions; specific compliance steps and penalties are Not stated in the document.

Full Text:

Section 48 Tea development account, coffee development account and rubber development account.

Topics

Acts Income Tax