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    Source-based taxation requires payers to withhold tax on non-resident sports and entertainment fees, ensuring collection at source.
    Clause 393(2)[Table: S.No.1] mandates a tax deduction at source on payments to non-resident sportsmen, entertainers, and non-resident sports associations or institutions for income referred to in section 211, imposing the obligation on any person making the payment to deduct tax at the earlier of credit or payment. The provision specifies a flat withholding rate, explicitly addresses grossing up for net-of-tax contracts, and is integrated within wider TDS subsections providing exceptions and administrative rules.
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    TDS on insurance commission: mandatory deduction at earlier of credit or payment, with threshold and declaratory relief.
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    Clause 393(1)[Table: S.No. 6(i)] applies TDS to sums for carrying out work, including supply of labour, payable by a designated person, preserving differential rates for individuals/HUFs and others, applying deduction at credit or payment, allowing exclusion of material where separately invoiced, and aggregating payments for threshold purposes, subject to specified exceptions and procedural requirements.
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    Clause 393(3)[Table: S.No. 3] mandates TDS on horse-race winnings by bookmakers or licensed operators at prevailing rates where winnings in a single transaction exceed the threshold, requires deduction at payment irrespective of mode, and integrates these obligations into Clause 393's unified procedural framework while leaving open interpretive issues such as the definition of "single transaction," aggregation risk, and valuation of non-cash payouts.
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    TDS on online gaming winnings: mandatory source deduction on net winnings, requiring payer compliance, reporting, and collection for noncash prizes.
    Clause 393(3)[Table: S.No. 2] mandates TDS on "any income by way of winnings from online game" payable or credited by "any person," requiring deduction at "rates in force" on net winnings (as per Note 1) at the time of payment or credit, irrespective of mode of payment including cash, kind, credits or digital assets; payer obligations include computation, deduction, remittance, certification and reporting, with standard consequences for non-compliance.
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    Clause 393(3)[Table: S.No.1] requires payers to deduct tax at source at rates in force on winnings from lotteries, puzzles, card games, other games, gambling and betting at the time of payment. The provision applies to cash and in-kind prizes and uses a single-transaction threshold to trigger TDS; payers must ensure tax is paid before releasing non-cash prizes. Online gaming winnings are excluded from this sub-clause and treated separately. General TDS reporting and deposit obligations apply.
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    TDS on interest: Bill raises senior citizen threshold and consolidates exemptions, altering deductor obligations and clarifying procedures.
    Clause 393(1)[Table: S.No. 5(ii) & 5(iii)] prescribes TDS on interest other than on securities by distinguishing banking companies, co operative banks and post offices (subject to higher thresholds) from other specified payers (subject to a lower threshold), fixing time of deduction as credit or payment whichever is earlier, retaining branch wise aggregation where core banking is absent, and allowing intra year adjustment; Clause 393(4)[Table: S.No. 7] lists exemptions mirroring institutional and co operative carve outs with turnover conditions and freezes new ad hoc notifications after the stipulated cutoff.
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    TDS on dividends: new Bill mandates deduction before distribution, retaining specified institutional and small-holder exemptions.
    Clause 393(1) requires TDS on all dividends (including preference shares) paid by domestic companies to resident shareholders at a flat rate, deducted before any distribution; Clause 393(4) lists conditional exemptions for specified institutional investors, notified persons, and small individual shareholders receiving dividends by non-cash modes, with exemptions contingent on payee type, payment mode, and aggregate amounts during the tax year.
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    The Bill reaffirms TDS on interest on securities payable to residents, requiring deduction at the earlier of credit or payment at prevailing rates, subject to an aggregate annual threshold. It consolidates instrument based and entity based exemptions in a notified table, preserves the government's notification power to add exemptions, and modernizes language to reflect current financial instruments. Procedural rules permit declarations for non deduction with clearer delivery and reporting timelines for payers, require documentation to justify non deduction, and emphasize tracking aggregate payments and timely reporting and deposit to improve compliance and reduce disputes.
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    Clause 390 mandates three modes of tax payment-deduction or collection at source, advance payment, and payment under section 392(2)(a)-to be effected "as per this Chapter," establishes that these obligations arise irrespective of later assessment proceedings, and includes a savings provision preserving the substantive charge to tax under section 4(1), thereby ensuring collection mechanisms do not affect the underlying tax liability.
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    Continuity of tax liability: dissolved firms treated as continuing for assessment, penalties, and recovery under new clause.
    Clause 330 treats a dissolved or discontinued firm as continuing for assessment and recovery, empowering tax authorities to assess total income, impose penalties, and apply all Act provisions; it imposes joint and several liability on partners and legal representatives and permits continuation of proceedings at the stage they stood at dissolution, while preserving other relevant statutory provisions through a saving clause.
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      Comparison of section 296 "Time-limit for completion of block assessment." between the Income-Tax Act, 2025 (as passed) and the Income-Tax Bill, 2025 (as originally introduced)

      10 September, 2025

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      Section 296 Time-limit for completion of block assessment

      Income-tax Act, 2025

      At a Glance

      The document under detailed consideration is Clause 296 of the Income Tax Bill, 2025 - (Old Version) which prescribes the time-limits and exclusion rules for completion of block assessments under the special procedure for search cases (section 294). It matters to taxpayers subjected to search and seizure proceedings, their representatives, and the Income-tax Department. The Bill text sets out computation rules, specified exclusions, and minimum remaining-period safeguards. Effective date or enactment status: Not stated in the document.

      Background & Scope

      Statutory hooks: Clause 296 (Bill) interacts primarily with section 294 (orders following search), section 295 (other persons), section 166(1) (references), section 159 (agreements for exchange of information), sections 244(2), 268(5), 269(1), 270(11)(i), 270(13), 274(1), and chapters dealing with Advance Rulings (sections 381 and 384 cited in the Bill). The Clause sets time-limits for passing assessment orders under the special search/block-assessment procedure and prescribes periods that are to be excluded in computing limitation. Definitions or explanatory notes: Not stated in the document beyond cross-references to the cited sections.

      Statutory Provision Mode

      Text & Scope

      Clause 296 prescribes that an order u/s 294 must be passed within twelve months from the end of the month in which the last of the authorisations for search was executed or requisition was made (sub-s. (1)). It applies "irrespective of the provisions of section 296" (likely an editorial inconsistency in the Bill text: see Interplay). The clause covers both the primary assessee and "other persons" (section 295) with separate computation for the latter (sub-s. (5)). It also provides for a 12-month extension where a reference u/s 166(1) is made during the course of proceedings (sub-ss. (2) and (6)).

      Interpretation

      The Bill text indicates an intent to fix a relatively short, definite time-frame (12 months) from a clear calendar point (end of the month in which the last search authorisation was executed or requisition made), subject to specified exclusions and extensions. The inclusion of enumerated excluded periods suggests the legislative principle that certain delays (court stays, information exchange, valuation/audit directions, references to authorities) should not count against the statutory limit. The use of calendar-month endpoints and an explicit minimum remaining period mechanism (sub-s. (8)) reflects an aim to provide practical breathing space for completion after exclusion periods. Legislative intent beyond these textual signals: Not stated in the document.

      Exceptions/Provisos

      Key carve-outs and conditions in the Clause:

      • Exclusion of a period (not exceeding 180 days) from date of search/requisition to date on which seized/requisitioned items are handed over to the Assessing Officer having jurisdiction (sub-s. (3)).
      • Enumerated exclusions in sub-s. (7): court stay periods (until certified copy of vacating order received), exchange-of-information reference periods (up to last receipt or one year, whichever less), time for reopening or re-hearing u/s 244(2), time taken where assessee is directed to get accounts audited/inventory valued u/s 268(5), period for reference to Valuation Officer u/s 269(1), periods linked to contraventions under Schedule III as per section 270(11)(i), references to Principal Commissioner/Commissioner u/s 270(13), periods relating to impermissible avoidance arrangement references u/s 274(1), and periods for Board for Advance Rulings applications and pronouncements u/ss 381/384 (sub-ss. (7)(a) to (j)).
      • Minimum remaining-period protection: where, after exclusion under (3) or (7), the remaining period is less than sixty days, it is extended to sixty days (sub-s. (8)).
      • Month-end extension: if after exclusions or extensions the period would expire before month end, it is extended to end of that month (sub-s. (4) and (9)).

      Illustrations

      • Example 1: Search executed on 10 January. Last authorisation executed that month. The normal limitation runs to 31 January of the next year (twelve months from end of the month of execution). If 120 days elapse between search and physical handover and are excluded under sub-s. (3), the remaining period is computed after excluding that 120-day span and then adjusted under sub-s. (4) or (8) as applicable.
      • Example 2: During assessment a reference u/s 166(1) is made. The time available for completion is extended by twelve months under sub-s. (2).
      • Example 3: A court grants a stay on assessment for 90 days; the stay is vacated and the jurisdictional Principal Commissioner receives certified copy 100 days later. The stay period (start to certified copy receipt) is excluded under sub-s. (7)(a) from computation.

      Interplay

      The Clause expressly interacts with multiple provisions: section 294 (orders after search), section 295 (other persons), section 166 (references), section 159 (exchange of information), section 244(2) (re-hearing/reopening), sections 268-269 (audit/valuation), section 270 (penalty/procedure references), section 274 (avoidance arrangements), and the Advance Rulings provisions (sections 381/384). The Bill text does not refer to any subordinate Rules, notifications or circulars. Potential textual inconsistency: sub-s. (1) refers to "Irrespective of the provisions of section 296", which appears circular or mis-referenced (likely intended to refer to another section-Not stated in the document).

      Practical Implications

      • Compliance and risk areas: Tax officers must track multiple exclusion events and maintain documentary proof (dates of handover of seized items, certified copies of court orders, dates of receipt of exchanged information, audit/valuation reports, Valuation Officer reports, advance ruling communications). Failure to accurately compute exclusions could result in time-bar disputes. The Bill requires attention to the precise calendar endpoint ("end of the month") for initial limitation calculation.
      • Record-keeping/evidence points: The text implicitly requires records showing the date of search/requisition, date of handover of seized/requisitioned items, dates of service/receipt of certified copies of court orders and authority communications, dates of references and replies under information-exchange, dates of audit/inventory valuation directions and reports, reports from Valuation Officer, and communications from the Board for Advance Rulings. Specific required forms or formats: Not stated in the document.

      Key Takeaways

      • Clause 296 fixes a twelve-month period (from end of the month of last search authorisation/requisition) for completion of block assessment orders u/s 294.
      • Specified exclusions (including up to 180 days for seizure custody and a series of procedural delays) are carved out from limitation computation.
      • A 12-month extension applies where a reference u/s 166(1) is made during proceedings (for primary assessee and separately for "other persons").
      • Where exclusions leave less than sixty days to proceed, the remaining period is extended to sixty days, creating a minimum workable timeframe post-exclusions.
      • Month-end rounding rules extend expiry to the end of the month if the period would otherwise expire mid-month.
      • The Clause requires careful tracking of multiple external events and receipt dates; however, procedural forms, judicial or administrative guidance on computation: Not stated in the document.
      • Textual inconsistency in sub-section (1) referring to "provisions of section 296": Not explained in the document.

      Differences Between (Document 2) Clause 296 of the Income Tax Bill, 2025 - Old Version and (Document 1) Section 296 of the Income-tax Act, 2025

      • Trigger point for the twelve-month period: Bill uses "twelve months from the end of the month in which the last of the authorisations for search was executed, or requisition was made" (Bill sub-s. (1)). The Act uses "twelve months from the end of the quarter in which the last of the authorisations for search was executed, or requisition was made" (Act sub-s. (1)(a)).
        • Practical impact: The Act lengthens the period by aligning to quarter ends rather than month ends, effectively giving up to approximately three additional months in some cases for completion, reducing pressure on the department (more time) and increasing uncertainty for taxpayers about the precise deadline (wider window).
      • Provision for extension where return-filing time is extended: The Act contains sub-s. (1)(b) stating that if the time for furnishing return u/s 294(1)(a)(v) is extended by 30 days, "twelve months" is to be read as "thirteen months". This is absent in the Bill.
        • Practical impact: Act expressly accommodates administrative extensions for return filing; the Bill silent on that contingency.
      • Seizure/exclusion wording: Bill excludes "the period (not exceeding one hundred eighty days) commencing from the date on which a search is initiated or a requisition is made and ending on the date on which seized or requisitioned items are handed over to the Assessing Officer having jurisdiction over the assessee" (Bill sub-s. (3)). The Act is more specific in sub-s. (3): it refers to assets [as provided in section 261(b)] and material seized or requisitioned [as provided in section 261(i)] are handed over to the Assessing Officer having jurisdiction.
        • Practical impact: Act clarifies the nature of items (cross-referring to section 261 definitions) which may reduce disputes about what constitutes seized items; Bill is more general.
      • Detailed sub-sectioning and drafting refinements: The Act expands certain sub-section numbering and presents the "quarter" rule, an additional clause for extension linked to return-filing, and adds or rearranges textual clarifications for persons u/s 295 (Act sub-s. (5) refers to "twelve months from the end of the quarter in which the notice u/s 294 in pursuance of section 295, was issued ..."). The Bill refers to "end of the month".
        • Practical impact: For "other persons" (section 295), the Act again gives a quarter-end anchor, providing more time compared to the Bill's month-end anchor.
      • Order of exclusions and minor drafting differences: The Act reorders or clarifies some exclusion clauses, and in some instances expands wording to refer to delivery/receipt to Principal Commissioner/Commissioner or Assessing Officer.
      • Practical impact: The Act's drafting appears designed to reduce ambiguity on receipt events and which authority's receipt triggers cessation of exclusion; the Bill is less explicit in certain respects.
      • Other differences: The Act includes an explicit sub-s. (8) and (9) analogous to the Bill but keyed to quarter-end based primary limitations.
        • Practical impact: Overall the Act tends to provide marginally more time and greater specificity on what is excluded and how computation is to be anchored.

      Action Points

      • Parties should maintain contemporaneous records establishing dates of search/requisition, dates of handover of seized items, certified copies of court orders, communications for exchange of information, references and reports from Valuation Officer, audit/inventory valuation reports, and Board for Advance Rulings communications.
      • Practitioners should note whether the operative limitation is computed from month-end (Bill) or quarter-end (Act) when advising clients and tracking deadlines; post-enactment, use the Act wording (quarter-end) where applicable.
      • In disputes, ensure pleadings and computation tables explicitly apply the correct anchor (month vs quarter) and list excluded periods with documentary proof of receipt dates.

      Full Text:

      Section 296 Time-limit for completion of block assessment

      Topics

      ActsIncome Tax