Reference to Transfer Pricing Officer centralises arm's length price determination, binding assessments and enabling validated multi year application.
An Assessing Officer, with prior supervisory approval, may refer determination of the arm's length price for international or specified domestic transactions to a designated Transfer Pricing Officer who issues a written order after notice and hearing; that TPO order is binding on the Assessing Officer for computing total income, and an opt in permits validated application of the TPO's determination to the two immediately following tax years subject to prescribed conditions and recomputation procedures.

Arm's length price determination allows limited acceptance of actual transaction price; AO may redetermine ALP after show-cause.
Arm's length price must be determined using specified transfer pricing methods or other Board prescribed methods, selecting the most appropriate method based on transaction nature, functions and prescribed factors. If a single method yields one price that price governs; a notified tolerance permits acceptance of the actual transaction price in specified cases. The Assessing Officer may determine the arm's length price during assessment where documentation, reliability, or compliance with notice requirements is deficient, but must first give the taxpayer a show cause notice before recomputing total income on that basis.

Specified domestic transaction definition narrows domestic related party scope and imposes an aggregate threshold triggering special anti avoidance rules.
Section 164 defines specified domestic transaction for the Chapter on avoidance of tax by enumerating categories of domestic dealings (cross referencing sections 122, 140(9), 140(13), Chapter VIII, section 144 and section 205(4)) and by permitting additional prescribed transactions; each item is subject to exclusion of international transactions and to an annual aggregate materiality threshold that determines applicability.

Associated enterprise definition expands to objective participation and dependence tests, broadening related party compliance risks.
Clause 162 defines associated enterprise by a general participation test (direct, indirect or through intermediaries in management, control or capital, or common persons participating therein) and a non exhaustive deeming list operative at any time during the tax year that includes objective thresholds and indicia such as minimum shareholding, reciprocal holdings, loan exposure relative to book assets, guarantee exposure, appointment control, IP dependence, supply/purchase dependence, family/common control and a residual mutual interest relationship subject to prescription; for specified domestic transactions the definition is expanded to include other units of the assessee and cross referenced persons or enterprises.

Tax rebate for resident individuals: post calculation reduction of tax up to capped amounts with special formula for higher incomes.
A deduction from income tax payable is available to resident individual assessees in specified income bands: tax is computed first and then reduced by a rebate subject to fixed monetary caps; for incomes above the higher threshold a formulaic reduction by the excess income is prescribed, and any deduction is capped so it does not exceed tax payable under the referenced computation provision.

Deduction for interest on deposits: account-type ceilings differ by seniority, with senior citizens' scope including time deposits.
Deduction for interest on deposits permits individuals (distinctly identifying senior citizens) and HUFs to claim limited deductions on interest from deposits with regulated banks, cooperative societies and Post Offices, subject to monetary ceilings and account-type limits: non-senior individuals and HUFs are restricted to interest from savings accounts excluding time deposits, senior citizens are allowed a broader deduction described as applying to savings accounts and expressly including time deposits, and no deduction is permitted where the deposit is held by or on behalf of a firm, association of persons or body of individuals; "time deposits" are defined as deposits repayable on expiry of fixed periods.

Time bound deduction for Producer Companies allows full tax relief for profits from defined member related agricultural activities, subject to sequencing.
A time bound tax incentive allows Producer Companies, as defined in the Companies Act, to claim a full deduction for profits attributable to an eligible business (marketing members' agricultural produce; supplying members with agricultural inputs; processing members' agricultural produce), subject to a turnover ceiling and a sequencing rule that permits the deduction only after other Chapter deductions; the clause omits attribution, anti abuse and procedural rules, creating compliance uncertainty.

Deduction for co-operative societies: specified cooperative income receives preferential tax deductions, subject to governance and computation rules.
Clause 149 permits targeted tax deductions for co operative societies by fully or partially deducting income attributable to enumerated cooperative activities (banking/credit to members, cottage industries, marketing of members' agricultural produce, supply of agricultural inputs, processing without power, collective disposal of members' labour, and fishing/allied activities), supplies by primary societies to federal cooperatives or government entities, inter cooperative investment income, and income from letting godowns; certain non specified activities qualify only up to capped amounts, governance restrictions on voting rights condition some deductions, and cooperative deductions are computed after reducing specified pre existing deductions.

Special tax deduction for North-Eastern undertakings grants full profit exemption for a fixed consecutive period.
A 100% deduction of profits and gains is available to undertakings in specified North-Eastern States for ten consecutive tax years starting from an "initial tax year", contingent on commencement or substantial expansion within a discrete qualifying window, formation and newness-of-plant conditions, exclusions for specified goods and activities, a defined test for "substantial expansion", and exclusivity preventing concurrent Chapter deductions; cross-referenced provisions determine treatment of re-established entities and aggregate duration limits.

Deduction for research donations: tax relief for approved gifts subject to verification and specified exclusions.
Deduction is allowed for donations to approved research associations or educational institutions for scientific or social science/statistical research, contingent on recipient approval and information furnished by the payee to the prescribed income tax authority and subject to the Board's risk based verification; deductions are excluded where the donor has business/profession income or where contributions in cash exceed the prescribed threshold, and deduction is not to be denied solely because recipient approval is later withdrawn.

Pension contribution deduction: employer and individual pension contributions receive tax relief, with caps and deeming rules affecting receipt.
Section 124 allows deductions for employer contributions to Central Government notified pension schemes subject to employer type percentage ceilings and for individual deposits into such schemes subject to an overall statutory cap; parent or guardian deposits for minors are aggregated with the individual cap. The provision defines salary for this purpose to include dearness allowance where employment terms so provide, disallows duplicate deduction where relief was claimed under the related provision, and deems amounts received on closure, opt out, or as annuity taxable in the year of receipt, with limited exceptions for nominee/parent/guardian receipts on death.

Loss carry-forward restrictions: beneficial ownership and voting-power continuity determine entitlement to set off historic losses.
The section restricts carry forward and set off of losses on change in firm constitution, succession other than by inheritance, and change in shareholding of non-public companies unless continuity of beneficial ownership of shares carrying not less than fifty-one percent of voting power is maintained or specified exceptions (death, gift to relative, certain amalgamations/demergers, insolvency resolution plans with opportunity to be heard, tribunal-approved restructuring, relocation, and a start-up carve-out) apply.

Carry-forward of predecessor losses: successor bank may set off losses as if reorganisation had not occurred, subject to continuity conditions.
Section 118 permits successor or resulting co operative banks to carry forward and set off predecessor accumulated losses and unabsorbed depreciation on amalgamation or demerger "as if the business reorganisation had not taken place," subject to the Act's set-off and depreciation rules. Demergers transfer directly attributable losses to the resulting undertaking and require pro rata apportionment of non direct losses by asset distribution. Qualification depends on continuity of banking activity and specified fixed asset holding thresholds, deemed tax year splitting, prescribed/notified conditions, and denial of set offs as taxable income upon non compliance.

Ring-fencing of race-horse losses restricts set-off to stake-money income and allows limited carry forward period.
Losses from owning and maintaining race horses are ring-fenced and may be set off only against income from the same specified activity (stake money). Unabsorbed losses may be carried forward for set-off solely against future stake-money income in years when the assessee carries on the specified activity, subject to a limited carry-forward period after which unabsorbed amounts expire. Definitions narrow the scope of eligible income and losses.

Set-off restriction for specified business losses limits use to profits of other specified business activities only.
Losses computed in respect of a specified business carried on by the assessee in a tax year may be set off only against profits and gains of other specified business activities for that year; any portion not so set off is an unabsorbed loss that may be carried forward and set off only against profits and gains of specified businesses in subsequent years.

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.

Carry forward of unabsorbed business loss limited to set off only against business profits, with a temporal carry forward limit.
Unabsorbed business loss (loss under Profits and gains of business or profession excluding speculation loss not absorbed under inter head set off) shall be carried forward and may be set off only against business or profession profits in subsequent years; any amount not so set off is carried forward iteratively, subject to a limit of not more than eight succeeding tax years, and such unabsorbed loss is to be given effect before allowing set off of specified carried forward allowances.

Carry forward of capital losses: limited temporal carry forward with distinct set off rules for long term and short term losses.
A statutory regime prescribes distinct set off rules for losses under the head Capital gains: short term capital losses may be set off against gains from any other capital asset, long term capital losses only against gains from other long term assets, and any residual loss after intra year set off qualifies for carry forward but only for a limited number of succeeding tax years; the Bill defined this residual as an unabsorbed capital loss, whereas the enacted provision omits that label but retains equivalent practical effect.

Carry-forward restriction of house property losses confines set-off to future house property income with a time-limited ceiling.
Residual losses computed under Income from house property that are not wholly absorbed by intra-year set-off qualify as unabsorbed loss from house property and may be carried forward, to be set off only against future house property income in subsequent years until the loss is absorbed or the statutory temporal limit expires; the clause defines the qualifying unabsorbed loss by reference to prior application of intra-year set-off rules.

Capital gains set-off rules restrict long-term losses to long-term gains while short-term losses offset any capital gains.
Section 108 separates general intra-head set-off (excluding capital gains) from specific capital gains rules: long-term capital losses are only set off against other long-term capital gains in the same year, while short-term capital losses may be set off against gains from any capital asset, with classification and computation governed by the capital gains framework.