Just a moment...

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 characters0/2000
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 ✕
🔎 TMI Notes - Adv. Search
TEXT SEARCH:

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.
RelevanceDefaultDate
    NewsBill
    Amendment in the definition of the specified fund
    NewsBill
    Amendment in the provision relating to merger of non-profit organisations (NPOs)
    NewsBill
    Amendment in the provisions relating to the violations by a registered NPO
    NewsBill
    Amendment of section 332(1)(f) of the Income-tax Act, 2025 to remove certain funds from the requirem...
    NewsBill
    Amendment in section 349 of the Income-tax Act, 2025 to provide for filing of belated return by NPO
    NewsBill
    Non-allowability of Interest as a deduction against Dividend Income
    NewsBill
    Rationalisation of Schedule XI relating to Provident Funds
    NewsBill
    Exemption for Sovereign Gold Bond
    NewsBill
    Increase in tax rates of Securities Transaction Tax
    NewsBill
    Taxation of buyback of shares
    NewsBill
    No tax to de deducted at source in respect of interest income credited or paid to any co-operative s...
    NewsBill
    AMENDMENT TO THE CUSTOMS ACT, 1962
    NewsBill
    AMENDMENTS TO THE CUSTOMS TARIFF ACT, 1975
    NewsBill
    AMENDMENT TO RULES UNDER CUSTOMS ACT, 1962
    NewsBill
    OTHER PROPOSALS INVOLVING CHANGES IN BASIC CUSTOMS DUTY RATES IN NOTIFICATIONS
    NewsBill
    OTHER CHANGES PROPOSED IN THE CUSTOM NOTIFICATIONS
    NewsBill
    REVIEW OF CUSTOMS DUTY EXEMPTIONS
    NewsBill
    Review of exemptions prescribed by other notifications.
    NewsBill
    SOCIAL WELFARE SURCHARGE (SWS)
    NewsBill
    AGRICULTURE INFRASTRUCTURE AND DEVELOPMENT CESS (AIDC)
❯❯
MaximizeMaximizeMaximize
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 SummariesHide All Summaries
    NewsBill
    Show AI Summary
    Specified fund definition aligned with income tax provision, effective April 1, 2026 for tax year 2026 27 onward.
    Amendment aligns the definition of specified fund in Note 1(g) to Schedule VI with the income tax provision definition, so that existing Sl. Nos. 1-4 of Schedule VI apply to any entity that meets the aligned specified fund definition; the amendment takes effect from 1 April 2026 and applies to the tax year 2026-27 and thereafter.
    NewsBill
    Show AI Summary
    Merger of non-profit organisations exempt from accreted-income tax if same or similar objects and prescribed conditions are met.
    A new provision exempts registered non-profit organisations from accreted-income tax on merger when the transferee and transferor are registered non-profit organisations with the same or similar objects and the merger meets prescribed conditions; the merger-liability rule is amended to make tax payable where the merging entity is non-registered, where a registered non-profit's merger fails to satisfy prescribed conditions despite similar objects, or where objects are not the same or similar.
    NewsBill
    Show AI Summary
    Registered non-profit organisations: commercial activity for public utility no longer treated as a specified violation risking registration cancellation.
    The amendment removes commercial activities by registered non-profit organisations carried out for advancement of General Public Utility from the category of specified violation in section 351, preventing such activity from triggering registration cancellation, and aligns the treatment with other violation provisions; effective 1 April 2026 for tax year 2026-27 and thereafter.
    NewsBill
    Show AI Summary
    Registration requirement removed for certain Schedule VII funds to align exemption rules under the Income-tax regime.
    Amendment excludes persons listed in Schedule VII (Table Sl. No. 10-16) from section 332(1)(f) of the Income-tax Act, 2025, removing their obligation to register under section 332 to claim income-tax exemption and aligning registration requirements with the Income-tax Act, 1961; effective 1 April 2026 for tax year 2026-27 onwards.
    NewsBill
    Show AI Summary
    Belated filing by registered non-profit organisations is permitted under amended section 349 referencing belated-filing provision.
    The amendment enables registered non-profit organisations to file belated income-tax returns by adding a cross-reference to the belated-filing provision within the statutory rule governing return filing by such organisations, restoring the belated-filing ability previously available and applying from 1 April 2026 to the 2026-27 tax year and thereafter.
    NewsBill
    Show AI Summary
    Dividend income: interest deductions disallowed for earning dividend or mutual fund unit income from April 1, 2026.
    The Finance Bill amends the law to disallow any deduction for interest expenditure incurred in earning dividend income or income from units of mutual funds, removing the earlier deduction that had been permitted up to a twenty per cent ceiling of gross dividend or mutual fund income; the change applies prospectively from the Bill's implementation date and affects income taxed under Income from other sources.
    NewsBill
    Show AI Summary
    Provident fund tax rules are realigned to the EPF framework, removing legacy contribution limits and investment cap.
    Align recognised provident fund tax provisions with the EPF framework by omitting parity and percentage-based restrictions that duplicate the Rs.7.5 lakh unified employer contribution cap, restrict recognition to funds exempt under section 17 of the EPF Act, remove the fifty per cent statutory limit on Government securities investment, and retain regulatory oversight via subordinate EPF instruments; effective 1 April 2026 for tax year 2026-27 onward.
    NewsBill
    Show AI Summary
    Sovereign Gold Bond exemption limited to original subscribers who hold until maturity, effective for tax year 2026-27 onward.
    The capital gains exemption for Sovereign Gold Bonds is confined to bonds subscribed at original issue and held continuously until redemption on maturity, to ensure uniform application across all Reserve Bank of India issuances.
    NewsBill
    Show AI Summary
    Securities Transaction Tax rates for options and futures increased; revised rates apply to transactions on or after April 1, 2026.
    A calibrated revision raises STT on derivatives: sale of an option in securities from 0.1% to 0.15% of the premium; sale of an exercised option from 0.125% to 0.15% of the intrinsic price; and sale of a future in securities from 0.02% to 0.05% of the traded price. The changes aim to curb disproportionate speculation in futures and options trading, take effect from 1 April 2026, and apply to transactions in options and futures entered into on or after that date.
    NewsBill
    Show AI Summary
    Taxation of share buybacks reclassified as capital gains; higher tax rates apply to promoters and promoter companies.
    Consideration received on buy-back of shares is recharacterised from dividend income to taxable capital gains, with cost of acquisition of extinguished shares remaining separately recognised. Promoters will face an effective tax liability of thirty per cent on buy-back gains (tax at applicable rates plus an additional tax) and promoter companies will face an effective tax liability of twenty-two per cent. These amendments apply from the first day of the relevant financial year and to the tax year 2026-27 and subsequent years.
    NewsBill
    Show AI Summary
    Interest paid to co operative societies carrying on banking exempt from TDS under Finance Bill amendment effective April 1, 2026.
    The Act is amended to align with the Income tax Act, 1961 by providing that deduction of tax at source shall not be made on interest income (other than interest on securities) credited or paid to any co operative society engaged in carrying on the business of banking, including a co operative land mortgage bank; the amendment takes effect from 1 April 2026.
    NewsBill
    Show AI Summary
    Indian-flagged fishing vessels beyond territorial waters get specific customs rules, including duty-free landing and entry procedures.
    Amendments extend Customs Act jurisdiction for fishing activities beyond territorial waters, define Indian-flagged fishing vessel, and insert section 56A to permit duty free importation of fish harvested beyond territorial waters and to treat fish landed at foreign ports as exports while authorising rules on entry, declaration, custody, examination, assessment, clearance, transit and transhipment. Other amendments deem certain penalties a charge for non payment of duty, fix advance rulings' validity at five years with transitional extensions, allow removal of warehoused goods between warehouses without prior officer permission, and enable regulations for custody of imported or export bound goods.
    NewsBill
    Show AI Summary
    Customs tariff amendments adjust basic customs duty rates, create new tariff lines, and reclassify import items effective Feb-May 2026.
    The First Schedule to the Customs Tariff Act, 1975 is amended to change Basic Customs Duty rates and to create new tariff items: immediate BCD increases effective 02.02.2026 (via provisional declaration), targeted BCD decreases effective 01.04.2026, and a comprehensive reclassification and rate migration from exemption notifications into the Tariff Act effective 01.05.2026, preserving applied duty levels while enabling better product identification and monitoring.
    NewsBill
    Show AI Summary
    Baggage rules updated; deferred import duty payments shifted to monthly for eligible importers, creating a new eligibility class.
    The baggage regime is replaced by Baggage Rules, 2026 to clarify temporary carriage of goods, avoid unnecessary detention, and restructure Transfer of Residence benefits by duration of stay, effective 02.02.2026; deferred import duty payment frequency is changed from 15 days to monthly and a new class of eligible importers is created by amending the Deferred Payment of Import Duty Rules, 2016.
    NewsBill
    Show AI Summary
    Basic Customs Duty changes: several commodities moved to nil duty while potassium hydroxide sees a 7.5% levy increase.
    Amendments to Basic Customs Duty effective 2 February 2026 alter duty incidence for specified imports: monazite, sodium antimonate for solar glass, nuclear power generation goods and control/burnable absorber rods, and specified microwave-oven manufacture components are moved to nil duty, while potassium hydroxide is newly subject to a 7.5% basic customs duty; consult the notification for full descriptions.
    NewsBill
    Show AI Summary
    Customs BCD exemptions extended to BESS, aircraft parts, nuclear projects, specified drugs and select critical minerals.
    BCD exemptions are expanded to cover capital goods for Battery Energy Storage Systems and to extend relief for aircraft raw materials and components (including engines) for manufacture or maintenance when imported by defence Public Sector Units, subject to the IGCRS Rules, 2022 and an end use certificate from a Joint Secretary level officer. Exemptions for goods for specified Nuclear Power Projects are broadened irrespective of capacity and extended through 30.09.2035. Lists in the customs notification are updated to add medicines and rare diseases for personal import exemptions, and select critical mineral entries are being consolidated into the tariff with the prior notification to be rescinded.
    NewsBill
    Show AI Summary
    Customs duty exemptions: 102 conditional entries extended, 22 allowed to lapse, and select unconditional exemptions omitted.
    A review of notification No. 45/2025 Customs extends validity of 102 conditional exemption/concessional BCD entries to 31.03.2028, allows 22 conditional entries to lapse on 31.03.2026, and omits specified unconditional exemptions effective 02.02.2026 so applicable BCD rates will apply from the First Schedule. The review also removes or prescribes sunset clauses, modifies certain entries (including mergers, description changes, and extended time limits), and incorporates some rates into the Tariff.
    NewsBill
    Show AI Summary
    Budget changes extend BCD exemptions for listed goods to March 31, 2028 and omit redundant notification entries.
    Extension of certain BCD exemptions to 31.03.2028 is prescribed for specified notifications covering precious stones on approval/return basis, goods imported for execution of export orders for jobbing, copper products from reverts, and gold/silver from copper anode slime exported for toll smelting. One standalone exemption for castor oil cake manufactured in SEZs and brought to DTA lapses on 31.03.2026, and a notification exempting works of art and antiques for public exhibition is given a sunset date of 31.03.2028. Selected exemption entries in notification No. 36/2024-Customs are omitted effective 02.02.2026 as redundant, with BCD rates to operate via the First Schedule of the Customs Tariff Act, 1975.
    NewsBill
    Show AI Summary
    Social Welfare Surcharge changes extend specific customs exemptions, add SWS on personal-use imports, and exempt electronic toys.
    Amendments to notification No. 11/2018-Customs consolidate and preserve SWS exemptions for specified graphite, quartz, silicon dioxide and related items; reassign concessional BCD for sub heading 2106 90 to the First Schedule while retaining SWS incidence; modify the spent catalyst/ash exemption description to remove a lapsed cross reference without altering exemption; impose SWS on all dutiable personal use imports under heading 9804; and exempt parts and goods under heading 9503 (electronic toys) from SWS.
    NewsBill
    Show AI Summary
    New aircraft rubber pneumatic tyres continue to attract 0.5% agriculture infrastructure and development cess from 02.02.2026.
    New pneumatic tyres of rubber used on aircraft under tariff item 4011 30 00 will continue to attract a 0.5% Agriculture Infrastructure and Development Cess. The notification entry is amended to omit reference to a removed exemption entry with effect from 02.02.2026, without changing the 0.5% AIDC rate for these goods (other than those with nil basic customs duty).

    TMI Notes

    Back

    All TMI Notes

    Showing Results for :
    Reset Filters
      No Records Found

      TMI Notes

      Back

      All TMI Notes

      whatsappJoin Channel
      Showing Results for : Reset Filters

      Comparison of Section 199 "Tax on income of certain manufacturing domestic companies." between the Income-Tax Act, 2025 (as passed) and the Income-Tax Bill, 2025 (as originally introduced)

      4 September, 2025

      Contents
      Acts
      Rules & Regulations
      Summary
      Note

      Note

      -

      Bookmark

      Print

      Print

      Section 199 Tax on income of certain manufacturing domestic companies.

      Income-tax Act, 2025

      At a Glance

      This document is Clause 199 of the Income Tax Bill, 2025 - (Old Version), which proposes a concessional 25% tax rate for certain domestic manufacturing companies subject to specified conditions. It matters to domestic companies engaged in manufacture or production (and related research/distribution) that were set up on or after 1 March 2016, and to the tax administration in determining eligibility and compliance. The document does not state an explicit effective date beyond the reference to "tax year" or enactment; no decision date is provided in the text.

      Background & Scope

      Statutory hooks: Clause 199 is placed within the "New tax regime" part of the Income Tax Bill, 2025. It operates "Irrespective of anything contained in this Act, but subject to the provisions of Parts A, B and this Part other than sections 200 and 201," thereby creating a standalone concessional regime subject to limited interplay with other Parts and sections. The provision applies to "a person, being a domestic company," and allows computation of income-tax at a flat rate of 25% at the option of the company, subject to enumerated conditions. Definitions or further explanations (such as definition of "manufacture" or "domestic company") are not stated in the document.

      Statutory Provision Mode

      Text & Scope

      Clause 199(1) authorises, by company option, computation of income-tax at 25% for a domestic company for any tax year, subject to three key conditions:

      • Condition (a): The company must have been set up and registered on or after 1st March, 2016.
      • Condition (b): The company must be engaged solely in the business of manufacture or production of any article or thing, and research in relation to, or distribution of, such article or thing manufactured or produced by it. In other words, the business must be limited to manufacturing/production and related research/distribution activities.
      • Condition (c): The company's total income must be computed without certain deductions listed in sub-clause (i) and without set-off of any loss carried forward attributable to those deductions per sub-clause (ii).

      Clause 199(1)(c)(i) specifies that the computation must be without deduction under (A) sections 45(2)(c) and 47(1)(b); (B) Chapter VIII-C, other than the provisions of section 146; or (C) sections specified in section 205(1)(a) to (g). Clause 199(1)(c)(ii) bars set-off of earlier year losses that are attributable to such disallowed deductions.

      Interpretation

      The clause expresses a legislative intent to create a preferable, simplified tax rate for qualifying manufacturing companies, while preventing duplication or continuance of other specified tax benefits. The language "Irrespective of anything contained in this Act" indicates a non-obstante clause intended to give the concessional rate primacy over other general provisions, but the carve-out "subject to the provisions of Parts A, B and this Part other than sections 200 and 201" indicates preserved interaction with certain Parts and specified sections. The option-based framework (see sub-sections (3) and (4)) suggests a taxpayer election that, once made, binds the company to the regime unless a separate option u/s 200 is exercised.

      Exceptions/Provisos

      Not stated in the document: any express exemptions other than the listed exclusions from deduction. The clause contains implicit carve-outs:

      • Chapter VIII-C benefits are excluded except for section 146 (i.e., section 146 remains available, while other provisions in Chapter VIII-C are not). The document does not elaborate on the content of Chapter VIII-C or on the policy reasons for preserving section 146 only.
      • Sections specified in section 205(1)(a) to (g) are also excluded; the content of those sections is not reproduced in the clause.
      • Losses attributable to the disallowed deductions are barred from set-off; subsection (2) deems such losses to have been given full effect to, preventing future deduction-this is an absolute prohibition with no stated time limitation.

      Illustrations

      • Example 1: A domestic manufacturing company incorporated on 1 April 2017, carrying on only manufacture and distribution of its products, opts into Clause 199. It cannot claim tax deductions under Chapter VIII-C (except section 146), nor can it claim deductions u/ss 45(2)(c) or 47(1)(b). If it has earlier year losses attributable to those disallowed deductions, such losses cannot be set off in the option regime. (All specifics about amounts, calculation mechanics, and interplay with other sections are Not stated in the document.)
      • Example 2: A domestic company set up on 1 February 2016 would be ineligible because incorporation predates 1 March 2016. (The document does not state any transitional provisions.)

      Interplay

      The clause expressly limits interaction with Parts A and B and "this Part" (i.e., the Part containing the clause), excluding sections 200 and 201. It excludes Chapter VIII-C benefits (except section 146) and the listed sections in section 205(1)(a)-(g). The clause calls for an option exercised "in the manner as prescribed" with a reference point to the due date specified u/s 263(1) for filing the first return; thus, it anticipates additional procedural rules to be prescribed. Specific interaction with other Rules, Notifications, or Circulars is Not stated in the document.

      Practical Implications

      • Compliance and risk areas grounded in the document: Companies seeking the 25% rate must ensure eligibility-date of registration (on/after 1 March 2016), exclusive engagement in manufacture/production with related research/distribution, and careful computation of total income excluding specified deductions. Non-compliance with these conditions would jeopardise entitlement to the concessional rate. The clause's election mechanism, including timing linked to section 263(1), creates a procedural compliance risk if the option is not validly exercised.
      • Record-keeping/evidence points suggested by the text: Companies should maintain incorporation/registration records to evidence the registration date; detailed books and documents to demonstrate the nature of activities (manufacture/production, research, distribution) and to segregate income/expenses attributable to other businesses, if any; and documentation linking prior-year losses to specific deductions listed in Clause 199(1)(c)(i) to determine whether losses are barred from set-off.

      Key Takeaways

      • Clause 199 offers an elective flat 25% tax rate for qualifying domestic manufacturing companies incorporated on or after 1 March 2016.
      • Eligibility requires exclusive engagement in manufacture/production and related research/distribution; other business activities disqualify a company under the clause.
      • Certain deductions are expressly disallowed for companies opting into the regime-specifically sections 45(2)(c) and 47(1)(b), most of Chapter VIII-C (except section 146), and sections referred to in section 205(1)(a)-(g).
      • Losses carried forward attributable to those disallowed deductions cannot be set off; subsection (2) deems such losses to have been given full effect to.
      • The concessional rate is elective, requires prescribed procedural exercise by the due date u/s 263(1) for furnishing the first return, and once made, is binding unless section 200 is invoked; the document contains no detail on the prescribed manner.
      • The clause contains a non-obstante opening but preserves certain Parts/sections, indicating limited interplay rather than complete override of the Act.
      • Operational details (definitions, examples, prescribed forms/procedures, transitional rules, or effective date specifics) are Not stated in the document.

      Differences Between Documents and Practical Impact

      TopicEarlier Position (Clause 199 - Bill Old Version)Later Position (Section 199 - Act)
      Parts referenced as subject to"subject to the provisions of Parts A, B and this Part other than sections 200 and 201""subject to the provisions of Parts A, B, E and this Part (other than sections 200 and 201) of this Chapter"
      Reference to section 45(2)Disallowance references "sections 45(2)(c) and 47(1)(b)"Disallowance references "section 45(2) or 47(1)(b)"
      Prescription wording for exercise of option"in the manner as prescribed""in the manner as may be prescribed"
      Typographical/clerical varianceSub-section (4) references "section section 200" (duplication)Sub-section (4) references "section 200" (single)

      Practical impact of each change:

      • Inclusion of Part E in the Act's version (Section 199) expands the set of statutory provisions that the new regime is "subject to." This broadens potential interactions and conditions that survive the non-obstante clause; companies and practitioners would need to consider Part E compliance where relevant. The Bill version omitting Part E would have left such interactions narrower. (Specific contents of Part E and practical consequences are Not stated in the document.)
      • The Bill's specific reference to section 45(2)(c) narrows the disallowance to a particular sub-paragraph of section 45(2), whereas the enacted Section 199's reference to section 45(2) more broadly excludes deductions under the whole of section 45(2). The broader reference in the Act can widen the range of deductions that are incompatible with the concessional regime, increasing the number of prior benefits/losses that may be denied. This is a substantive change affecting eligibility and post-election tax position.
      • The change from "in the manner as prescribed" to "in the manner as may be prescribed" is modest; the latter is a more conventional legislative drafting phrase indicating prescription power. It likely has no material effect beyond standardising drafting.
      • Correction of a typographical duplication ("section section 200") clarifies the cross-reference; it has no substantive legal effect beyond removing ambiguity.

      Full Text:

      Section 199 Tax on income of certain manufacturing domestic companies.

      Topics

      ActsIncome Tax