Comparison of Section 113 'Set off and carry forward of losses computed in respect of speculation' between the Income-Tax Act, 2025 (as passed) and the Income-Tax Bill, 2025 (as originally introduced)

Speculation loss ring fencing: losses only offset against speculation profits with limited carry forward and priority in set off.

Losses from speculation business may be set off only against speculation business profits; any unabsorbed speculation business loss is carried forward and set off only against future speculation business profits, subject to a statutory temporal limitation and applied before certain other carried forward allowances. A deeming rule treats companies buying and selling shares of other companies as carrying on speculation business to that extent, subject to carve outs where specified income heads or principal business activities prevail.