Comparison of Section 210 'Tax on income of Foreign Institutional Investors from securities or capital gains arising from their transfer.' between the Income-Tax Act, 2025 (as passed) and the Income-Tax Bill, 2025 (as originally introduced)

Taxation of foreign institutional investors' securities income: fixed-category rates apply and residual income taxed under general rates.

The provision creates a category-based tax regime for Foreign Institutional Investors and specified funds, requiring segregation of securities income and capital gains into prescribed heads and applying fixed tax rates to each head, with residual income taxed at general rates. Specified funds are taxed only on amounts attributable to units held by non-residents (attribution to be prescribed). Where gross total income is solely securities income, routine deductions are disallowed; where mixed, specified incomes are excluded for deduction computations. A specified loss-set-off mechanism is excluded for the listed capital gains.