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
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 ✕
🔎 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
    competitive taxation structure for shipping companies : Clause 228(14) and (15) of the Income Tax Bi...
    Simplified and concessionary method of taxation based on the net tonnage of qualifying ships, rather...
    computation of tonnage income where ships are jointly operated or where multiple companies are invol...
    Computation of Taxable income of the shipping companies based on Tonnage: Clause 227(1)-(6) of the I...
    Comprehensive Review of the Tonnage Tax Scheme : Clause 226(7) of the Income Tax Bill, 2025 Vs. Sect...
    Presumptive Taxation for Shipping Companies : Clause 226(2)-(6) of the Income Tax Bill, 2025 and Sec...
    Examination of "Qualifying Ship" : Clause 235(i) of the Income Tax Bill, 2025 Vs. Section 115VD of t...
    Defining the Qualifying Company under India's Tonnage Tax Regime : Clause 235(h) of the Income Tax B...
    Continuity and Change in India's Tonnage Tax Regime : Clause 226(1) of the Income Tax Bill, 2025 Vs....
    Navigating Special Tax Regimes for Shipping : Clause 225 of the Income Tax Bill, 2025 Vs. Section 11...
    Interpreting Special Provisions for Shipping Companies : Clause 235 of the Income Tax Bill, 2025 Vs....
    Special Tax Regimes for Investment Funds : Clause 224 of Income Tax Bill, 2025 Vs. Section 115UB of ...
    special taxation regime for business trusts such as (REITs)/(InvITs) Clause 223 of the Income Tax Bi...
    Special Provisions Relating to Pass-Through Entities in Venture Capital Structures : Clause 222 of I...
    Enforcement and Recovery of Tax on Accreted Income : Clause 352(8) & (9) of the Income Tax Bill, 202...
    Changing Landscape of Interest on Delayed Payment of Tax on Accreted Income : Clause 352(7) of Incom...
    Reforming the Exit Tax Regime for non-profit organizations (NPOs) or charitable institutions : Claus...
    Comprehensive Review of Taxation, Reporting, and Compliance for Securitisation Trusts : Clause 221 o...
    Definitions, Scope, and Impact on the MAT/AMT Regime : Clause 206(19) of the Income Tax Bill, 2025 V...
    Reducing tax avoidance by curbing the excessive use of deductions and exemptions by corporate and se...
❯❯
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
    Act RulesBills
    Show AI Summary
    Allocation of shared costs and depreciation: apportionment on reasonable basis and fair proportion affects tonnage tax computations.
    Clause 228(14) requires common costs attributable to the tonnage tax business to be allocated on a reasonable basis, with taxpayers maintaining records to support apportionment. Clause 228(15) requires depreciation for assets other than qualifying ships to be apportioned on a fair proportion determined by the Assessing Officer with reference to actual use. Both provisions mirror Section 115VJ, vesting discretion in the AO and preserving the objective of preventing tax arbitrage while increasing documentation and compliance burdens.
    Act RulesBills
    Show AI Summary
    Tonnage tax regime: clarifies qualifying shipping income, market value inter company valuation, and related party anti avoidance adjustments.
    Tonnage tax applies to qualifying shipping income measured by net tonnage, defined as profits from specified core shipping activities and prescribed incidental activities; incidental income above a prescribed threshold is excluded. Inter business transfers must be computed at market value, with assessing officer power to use reasonable bases in exceptional cases. Related party arrangements producing more than ordinary profits may be adjusted to reasonable levels. The Central Government may exclude activities or set limits by notification subject to parliamentary laying. Losses in tonnage computation are ignored.
    Act RulesBills
    Show AI Summary
    Allocation of tonnage income: proportional or independent computation affects tax treatment of jointly operated qualifying ships.
    Computation of tonnage income for jointly operated qualifying ships follows a two-step approach: where participating companies' shares are definite and ascertainable, income is allocated proportionately to each company; where shares are not definite and ascertainable, tonnage income for each operator is computed as if it were the sole operator. The rule aligns taxation with economic interest, creates documentary and compliance incentives, functions as an anti-avoidance measure, and may interact with cross-border tax rules, requiring clearer guidance on "definite and ascertainable" shares and documentation standards.
    Act RulesBills
    Show AI Summary
    Tonnage tax regime: ships' taxable income computed by daily tonnage rates and aggregation, excluding deductions.
    Clause 227(1)-(6) prescribes a ship wise tonnage tax: each qualifying ship's tonnage income equals its daily tonnage income multiplied by qualifying days, with daily rates set by a four tier slab linked to certified net tonnage. Tonnage includes certified physical tonnage and prescribed deemed tonnage for slot and sharing arrangements, rounded to the nearest hundred tons. A non obstante clause bars any deductions or set offs, making the computed tonnage income the exclusive tax base under the Part.
    Act RulesBills
    Show AI Summary
    Tonnage tax scheme: deemed tonnage income treated as business profits, excluding actual shipping income under eligibility conditions.
    Clause 226(7) mandates that tonnage income be computed under a separate formulaic provision and be deemed to be the profits chargeable under business income, while expressly excluding the actual "relevant shipping income" from tax once the tonnage computation applies; these effects are conditional on compliance with the Part's eligibility, option, separation, and record keeping requirements.
    Act RulesBills
    Show AI Summary
    Tonnage tax scheme: elective presumptive taxation for shipping income, requiring separate accounting and exclusive computation under qualifying criteria.
    The tonnage tax scheme is an elective presumptive regime requiring eligible companies operating qualifying ships to compute profits from that business exclusively under the tonnage basis; the tonnage tax business is treated as a separate business with independent computation and accounting, and companies not opting or ineligible must compute shipping profits under the normal provisions of the Act.
    Act RulesBills
    Show AI Summary
    Qualifying ship definition governs tonnage tax eligibility by tying registration, certification, and operational use to tax benefit access.
    The definition of qualifying ship in Clause 235(i) requires three operative conditions for tonnage tax eligibility: a minimum net tonnage, registration under the relevant shipping statute or an authorised foreign licence, and a valid certificate evidencing net tonnage. It lists explicit exclusions-vessels providing services normally provided on land, fishing vessels, factory ships, pleasure crafts, harbour and river ferries, offshore installations-and disqualifies vessels used for fishing beyond a specified threshold in a tax year, anchoring eligibility in maritime regulatory certification and operational use.
    Act RulesBills
    Show AI Summary
    Place of effective management central to qualifying company status, restricting tonnage tax benefits to genuinely India-managed shipping firms.
    The qualifying company for the tonnage tax regime must satisfy four cumulative conditions: be an Indian company; have its place of effective management in India-defined to include decisions made by executives as well as the board; own at least one qualifying ship; and have its main object as operating ships. Clause 235(h) consolidates these criteria within a broader definitional framework and references updated maritime legislation to clarify eligibility and reduce interpretive disputes.
    Act RulesBills
    Show AI Summary
    Tonnage tax eligibility defined by operation status: owners and charterers qualify, long term bareboat lessors excluded.
    Clause 226(1) treats a company as operating a ship or inland vessel if it owns or charters a vessel, including partial charters such as slot, space, or joint charters, and excludes companies that have chartered out vessels on bareboat charter or bareboat charter cum demise terms for periods exceeding three years, thereby distinguishing operational risk bearing operators from passive, long term financiers for purposes of the tonnage tax scheme.
    Act RulesBills
    Show AI Summary
    Tonnage tax regime: option to compute shipping income on a tonnage basis with deeming treatment as business profits.
    Clause 225 creates a self-contained tonnage tax regime for companies operating qualifying ships, allowing an option to compute income under its Part with a deeming provision treating that income as profits and gains of business; key operational questions concern the definition of qualifying ships, the option's exercise and lock-in mechanics, and interaction with loss set-off, allowances, and other tax measures.
    Act RulesBills
    Show AI Summary
    Tonnage tax definitions: expanded, self-contained eligibility rules broaden coverage and tighten residency and exclusion tests.
    Clause 235 consolidates and expands tonnage tax definitions by explicitly including inland vessels, embedding a detailed qualifying company test requiring Indian residency, ownership of qualifying ships, principal shipping business, and a specified place of effective management; it also defines qualifying ship with tonnage, registration/licensing and certification requirements and enumerated exclusions to prevent abuse.
    Act RulesBills
    Show AI Summary
    Pass-through taxation preserves investor-level tax treatment of investment fund income while ring-fencing fund-level losses.
    Clause 224 restates a pass-through regime: income from investments in a regulated fund is taxed in the hands of unit holders as if held directly, while business income remains taxable at the fund level. Business losses are ring fenced at the fund; other losses pass through subject to holding period conditions and transitional attribution of legacy losses to unit holders. Income retained by the fund is deemed credited to unit holders at year end and prescribed statements must be furnished to unit holders and tax authorities to secure transparency and enforcement.
    Act RulesBills
    Show AI Summary
    Pass-through taxation for business trusts preserves income character and shifts tax consequences to unit holders with reporting duties.
    The clause establishes a statutory pass-through mechanism under which income distributed by business trusts is deemed to retain its original character and proportion in the hands of unit holders, while subjecting the trust's total income to tax at the maximum marginal rate subject to specified withholding provisions; it also deems certain scheduled categories of distributed income taxable on distribution, carves out specified statutory exceptions, and imposes prescribed reporting obligations on payers to unit holders and tax authorities.
    Act RulesBills
    Show AI Summary
    Pass-through taxation of venture capital income taxes investors as if invested directly, with reporting and deemed-credit safeguards.
    Pass-through taxation requires that income arising to investors from venture capital companies or funds be taxed in the investor's hands as if invested directly, with the fund and payer furnishing prescribed statements to investors and tax authorities; undistributed income is deemed credited to investors at year-end in proportion to entitlement, while income already included on an accrual basis is not taxed again on actual payment; specified investment funds are excluded and key terms are defined in the schedule.
    Act RulesBills
    Show AI Summary
    Tax on accreted income: transferees and officers may be deemed assessees in default, with liability limited to asset value.
    Clause 352(8) deems the specified person (NPO) and its principal officer or trustee to be assessee in default for unpaid tax on accreted income and applies all recovery provisions of the Act; it also deems a transferee of assets in specified dissolution cases to be an assessee in default in respect of such tax. Clause 352(9) limits the transferee's liability to the extent the asset received is capable of meeting the liability, ensuring proportionality in recovery.
    Act RulesBills
    Show AI Summary
    Accreted income interest compels prompt tax payment and creates joint personal liability for trustees and principal officers.
    Clause 352(7) imposes simple interest for delayed payment of tax on accreted income, with joint and several liability on the specified person and the principal officer or trustee; interest is computed monthly (any part-month treated as a full month) using an explicit formula, and liable persons are deemed assessee in default to enable statutory recovery mechanisms.
    Act RulesBills
    Show AI Summary
    Exit tax on accreted income expands triggers and fixes final levy after prescribed valuation and procedural safeguards.
    A tax on accreted income charges NPOs additional income tax at the maximum marginal rate when specified events occur; accreted income equals aggregate fair market value of assets less total liabilities on a specified date, computed under prescribed valuation methods, with exclusions as prescribed. The Assessing Officer must afford a hearing before ordering tax, the bill sets a detailed table of triggering events and payment timelines, and the tax payment is final with no further credit or deduction allowed.
    Act RulesBills
    Show AI Summary
    Pass-through taxation for securitisation trust income preserves investor-level taxation while mandating reporting and deemed-accrual rules.
    Clause 221 establishes a pass-through taxation regime for income from securitisation trusts, preserving the character and proportion of underlying income in the hands of investors, deeming unpaid accruals as credited on the last day of the tax year to prevent deferral, requiring prescribed statements to investors and tax authorities, and preventing double taxation by excluding income already taxed on accrual from subsequent inclusion on actual payment.
    Act RulesBills
    Show AI Summary
    Minimum alternate tax definitions shape MAT/AMT computation and Ind AS transition treatment, narrowing tax arbitrage opportunities.
    Clause 206(19) supplies granular definitions aligning MAT/AMT computation with Ind AS convergence, insolvency law and cross statutory terms. Key terms include adjudicating authority (IBC), convergence date, transition amount with specified exclusions, net worth, company classifications, securities, tribunal, unit (IFSC) and year of convergence. These definitions phase in Ind AS transition impacts, harmonize tax and insolvency treatment, clarify eligibility for concessional AMT rates, and reduce tax arbitrage and interpretive disputes compared with the narrower definitions in Section 115JF.
    Act RulesBills
    Show AI Summary
    Minimum alternate tax exclusions: narrow MAT/AMT to specified taxpayers including life insurers, alternative regime opters, presumptive and small taxpayers.
    Clause 206(18) narrows MAT/AMT applicability by exempting companies with life insurance income, taxpayers who opt for specified alternative tax regimes, persons taxed under special or presumptive computation sections, specified funds identified in the Schedule, and non corporate persons whose adjusted total income falls below the statutory threshold; the exclusions reflect sectoral accounting differences, aim to promote concessional regimes and financial competitiveness, and reduce compliance burdens while requiring clear definitions and anti abuse safeguards.

    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 261 "Interpretation." between the Income-Tax Act, 2025 (as passed) and the Income-Tax Bill, 2025 (as originally introduced)

      9 September, 2025

      Contents
      Acts
      Rules & Regulations
      Summary
      Note

      Note

      -

      Bookmark

      Print

      Print

      Section 261 Interpretation.

      Income-tax Act, 2025

      At a Glance

      Clause 261 of the Income Tax Bill, 2025 (Old Version) sets out definitions used in the Chapter dealing with powers relating to search, seizure and requisition. It matters because definitional scaffolding determines the scope of search-and-seizure powers and the evidentiary status of electronic material; affected parties include taxpayers, authorised officers, and the Department. Effective date or decision date: Not stated in the document.

      Background & Scope

      Statutory hooks: Clause 261 sits in Chapter XIV (as the note indicates) of the Income Tax Bill, 2025. It supplies definitions of expressions used for the purposes of the Chapter that regulates powers (search, requisition and related procedural mechanisms). The clause lists definitional meanings for "approving authority," "asset," "authorised officer," "competent authority," "computer system," "date on which the last of the authorisations for search was executed," "material seized," "proceeding" and "virtual digital space." The text provides definitions but no express legislative history or policy rationale. Any statutory cross-references explicitly stated are to section 247 and section 248 (for search and requisition), and to the Income-tax Act, 1961 in the "proceeding" definition.

      Statutory Provision Mode

      Text & Scope

      The clause defines the following core terms:

      • Approving authority: enumerates senior posts (Principal Director General/Director General; Principal Chief Commissioner/Chief Commissioner; Principal Director/Director; Principal Commissioner/Commissioner).
      • Asset: defined as "any money, bullion, jewellery or other valuable article or thing, held in physical or virtual form." This is a broad property-oriented definition, purposely not limiting to corporeal assets.
      • Authorised officer: ranges from Joint Director/Additional Director through to Income-tax Officer/Tax Recovery Officer; this specifies the class of officers empowered under the Chapter.
      • Competent authority: similar enumeration to approving authority but broader, including Joint Director/Additional Director and Joint Commissioner/Additional Commissioner.
      • Computer system: broad language: "computers, computer systems, computer networks, computer resources, communication devices, digital or electronic data storage devices" whether stand-alone or networked, including remote server, cloud server or virtual digital space; describes both modes of use and examples of included infrastructure.
      • Date on which the last of the authorisations for search was executed: two alternatives:
        • (i) in the case of search, the date of conclusion as recorded in the last panchnama drawn for persons covered by a warrant;
        • (ii) in case of requisition u/s 248, the date of actual receipt of books, documents or assets by the requisitioning officer.
      • Material seized: defined expansively to include books of account, other documents, digital data storage devices, computer systems and extracts seized during searches u/s 247 or requisition u/s 248; explicitly mentions backups from specialised programmes and electronic records (tally, excel, word files) and says such material "shall be construed to mean as book of accounts maintained by the said person."
      • Proceeding: covers any proceeding in respect of any year whether under the Income-tax Act, 1961 or under this Act that may be pending on the date of authorisation of a search/requisition or completed on or before such date, and includes proceedings which may be commenced after such date.
      • Virtual digital space: defined as an environment created via computer technology, including email servers, social media accounts, online investment/trading/banking accounts, websites storing ownership details, remote/cloud servers, application platforms and similar spaces.

      Interpretation

      The clause evinces an interpretive approach that is expansive and technology-aware. "Asset" as "physical or virtual" and the separate definition of "virtual digital space" show intent to capture non-physical forms of value. The "computer system" definition emphasises functional coverage - whether standalone or networked - and expressly includes cloud and remote servers. The "material seized" provision equates seized electronic records/backups with books of account, indicating legislative intent to treat digital evidence on parity with traditional account books for purposes of assessment and proceedings. The "proceeding" definition adopts a temporal sweep, covering past, pending and future proceedings tied to the date of search/requisition.

      Exceptions/Provisos

      Not stated in the document.

      Illustrations

      • If during a search (authorised u/s 247), an authorised officer seizes a company's cloud-hosted accounting backup, that backup would fall within "material seized" and be treated as books of account maintained by the company (consistent with the definition).
      • If a requisitioning officer u/s 248 takes physical custody of a server containing transaction logs on a stated date, the "date on which the last of the authorisations for search was executed" (for purposes of related provisions) would be the date of actual receipt of that server (as "assets").
      • An online trading account held on a digital application platform falls within "virtual digital space" and accordingly may be captured by definitions of assets or material when relevant to a search/requisition.

      Interplay

      The clause expressly references sections 247 and 248 as the operative powers under which material may be seized or requisitioned. It cross-links to the Income-tax Act, 1961 in defining "proceeding." The provision states that electronic backups and specialised programme data are to be treated as books of account for purposes of the Chapter; this creates an internal evidentiary linkage between digital material and statutory accounting records. No explicit references to rules, notifications or circulars are contained in the text.

      Differences between the two provisions and practical impact

      • Terminology - "asset" includes "virtual digital asset": The Act (Document 1) expressly expands the definition of "asset" to include "virtual digital asset"; the Bill (Document 2) refers to "asset" as "any money, bullion, jewellery or other valuable article or thing, held in physical or virtual form" and does not explicitly use the phrase "virtual digital asset."
        • Practical impact: the Act's explicit inclusion of "virtual digital asset" clarifies legislative intent to capture cryptocurrencies and similar instruments; the Bill's broader but less explicit phrasing may leave room for interpretive disputes about whether specific crypto instruments fall within "virtual digital asset" or merely "virtual form" of an asset.
      • Scope of "material seized" vs "material seized or requisitioned": The Bill (Document 2) uses the heading "material seized" and describes items seized during search or requisition; the Act (Document 1) uses "material seized or requisitioned" as the term and expressly includes "computer systems" in the list and states that such material "shall be construed to mean as books of accounts maintained by the said person."
        • Practical impact: the Act clarifies that requisitioned material is explicitly included and equates seized electronic material to books of accounts, potentially broadening evidentiary reach and supporting treatment of electronic extracts as formal books; the Bill's framing is marginally narrower or less explicit on that declaratory equivalence.
      • Inclusion of "electronic form" and "electronic record" cross-references: The Act (Document 1) contains specific sub-clauses (g) and (h) that adopt terms from the Information Technology Act, 2000; the Bill (Document 2) does not include corresponding sub-clauses labelled (g) and (h) for those exact cross-references (in the Bill numbering, (g) is used for "material seized" and (h) for "proceeding").
        • Practical impact: the Act's explicit cross-references to the IT Act clarify that statutory notions of electronic documents and records are to be read consistently with established definitions; the Bill is less explicit about adopting those statutory definitions, possibly creating interpretive friction as to whether IT Act definitions are imported.
      • "Proceeding" definition present in the Bill but absent in the Act text provided: The Bill includes a definition of "proceeding" (Document 2, clause (h)) describing what proceedings are covered (including references to the Income-tax Act, 1961 and proceedings pending or completed on the date of search/requisition). The Act excerpt (Document 1) as provided does not contain that "proceeding" definition.
        • Practical impact: retention of an express "proceeding" definition in the Bill would have clarified temporal and substantive reach of actions triggered by searches/requisitions; its absence from the Act extract may mean either omission in the Act or that it is located elsewhere-if absent, scope of covered proceedings may be less explicitly delimited, creating uncertainty over retrospective or prospective application to earlier or later proceedings.
      • Computer system / computer resources phrasing: Both texts define "computer system" broadly, but the Bill starts with "computers, computer systems" and the Act begins with "computers, computer networks," etc. The Act explicitly repeats "computer resources, communication devices, digital or electronic data storage devices" and again includes "virtual digital space."
        • Practical impact: differences are largely stylistic; both convey a broad technological reach. The Act's inclusion of "virtual digital space" in the computer system clause and as a separate defined term strengthens the capture of cloud and online environments.
      • Requisition wording in definition of the date on which last authorisation was executed: The Bill's clause (f)(ii) refers to "actual receipt of the books of account or other documents or assets by the requisitioning officer"; the Act's clause (f)(ii) expands that to "books of account or other documents or computer system or assets."
        • Practical impact: the Act's explicit inclusion of "computer system" in what may be requisitioned tightens the statutory basis for claiming a requisitioned server or digital environment was effectively taken on a given date; the Bill might have been read to focus more on physical assets or documents.

      Practical Implications

      • Compliance and risk areas: Taxpayers with digital records or holdings in virtual spaces should expect those records to be treated as books of account when seized or requisitioned. The broad definition of "computer system" and "virtual digital space" increases the Department's practical reach into cloud servers, social media accounts and online financial platforms during investigations.
      • Record-keeping/evidence points: Entities should maintain clear, verifiable backups and audit trails for accounting software, spreadsheets and electronic records since the statute singles out backups from specialised programmes. Documentation that demonstrates provenance and linkage between digital files and formal accounts will be relevant where seized material is used as books of account.

      Key Takeaways

      • Clause 261 supplies a broad, technology-inclusive set of definitions to govern search, seizure and requisition powers in the Chapter.
      • "Material seized" explicitly includes digital backups and computer systems and is to be construed as books of account, elevating electronic records to evidentiary parity with traditional accounting records.
      • "Virtual digital space" is comprehensively defined to include email servers, social media, online investment/trading/banking accounts, websites holding ownership details, remote/cloud servers and application platforms.
      • "Proceeding" is defined to cover proceedings under the Income-tax Act, 1961 and the new Act, including pending, completed or subsequent proceedings linked to the date of search/requisition.
      • The clause casts a wide net over digital environments and assets, signalling administrative emphasis on accessing electronic data during tax investigations.

      Full Text:

      Section 261 Interpretation.

      Topics

      ActsIncome Tax