Comparison of section 223 'Tax on income of unit holder and business trust.' between the Income-Tax Act, 2025 (as passed) and the Income-Tax Bill, 2025 (as originally introduced)

Deeming rule: distributions retain trust character, requiring payer reporting and trust taxation at maximum marginal rate.

Clause 223 deems distributions by a business trust to retain the same character and proportion in the hands of unit holders, charges the trust's total income at the maximum marginal rate subject to qualifying statutory mechanisms, treats specified scheduled items as unit holder income in the year of receipt, excludes certain sums from the deeming rule, and requires payers to furnish prescribed statements detailing the nature of distributed amounts.