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
    NewsBills
    AMENDMENTS IN THE CGST ACT, 2017
    NewsBills
    AMENDMENTS IN THE IGST ACT, 2017
    Refund of unutilised ITC - inverted duty structure - Denial on Input services - Contradictory Judgem...
    Case LawsIncome Tax
    Introduction of concept of mediation and Advance Ruling System for Residents to reduce tax litigatio...
    Supersession of regulation - Transportation of Goods (Through Foreign Territory), Regulations 1965
    NewsBills
    Retrospective Amendments of GST rate notifications
    NewsBills
    AMENDMENTS IN THE Goods and Services Tax (Compensation to States) ACT, 2017:
    NewsBills
    AMENDMENTS IN THE UTGST ACT 2017:
    NewsBills
    AMENDMENTS IN THE IGST ACT 2017:
    NewsBills
    AMENDMENTS IN THE CGST ACT 2017:
    NewsBills
    EXCISE AMENDMENT IN THE SEVENTH SCHEDULE TO THE FINANCE ACT, 2001* [Clause [145] of the Finance Bill...
    NewsBills
    Other Miscellaneous changes pertaining to Anti-Dumping Duty/Countervailing Duty
    NewsBills
    Exemption from Social Welfare Surcharge hitherto available on certain items falling chapter 84, 85 a...
    NewsBills
    Social Welfare Surcharge is being exempted on following items.
    NewsBills
    OTHER CHANGES (INCLUDING CERTAIN CLARIFICATIONS' TECHNICAL CHANGES)
    NewsBills
    IMPOSITION OF HEALTH CESS ON IMPORT OF CERTAIN ITEMS
    NewsBills
    Customs duty exemptions which have been granted through certain other stand-alone notifications have...
    NewsBills
    Review of concessional rates of BCD prescribed in notification no. 50/2017 - Customs dated 30.62017:...
    NewsBills
    OTHER PROPOSALS INVOLVING CHANGES IN BASIC CUSTOMS DUTY RATES IN NOTIFICATIONS
    NewsBills
    AMENDMENTS IN THE FIRST SCHEDULE TO THE CUSTOMS TARIFF ACT, 1975
❯❯
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
    NewsBills
    Show AI Summary
    CGST amendments tighten taxation of related party supplies and revise returns, credit, interest, enforcement and appeal rules.
    Finance Bill, 2021 amends the CGST Act to: tax supplies between non individuals and members retrospectively; limit input tax credit to supplier reported outward supplies; replace mandatory audited reconciliation and account audits with self certified annual returns; charge interest on net cash liability retrospectively; separate seizure/confiscation from tax recovery; make provisional attachment valid through proceedings and one year after order; condition certain appeals on payment of part of penalty; clarify self assessed tax includes outward supplies omitted from returns; expand information calling powers while preserving a hearing requirement.
    NewsBills
    Show AI Summary
    Zero-rating of supplies to SEZs limited to authorised operations; zero-rating on payment restricted to notified taxpayers, refund linked to forex.
    Amendments narrow zero-rated supplies to Special Economic Zone developers or units to transactions for authorised operations; restrict zero-rating on payment of integrated tax to notified classes of taxpayers or notified supplies; and connect export refund entitlement to actual foreign exchange remittance, thereby conditioning refunds on realization documentation.
    Case LawsGST
    Show AI Summary
    Refund entitlement for unutilised input tax credit limited to credits from input goods under inverted duty structure.
    The document contrasts two high court approaches to refund of unutilised input tax credit under an inverted duty structure: one holding that Net ITC for refund must include credits on inputs and input services and striking down a rule excluding input services as ultra vires; the other upholding the proviso that limits refund to credit accumulated because tax on input goods exceeds tax on output supplies, finding an amended rule that excludes input services to be intra vires and a valid legislative classification.
    Case LawsIncome Tax
    Show AI Summary
    Advance Ruling System can reduce tax litigation and provide binding certainty for taxpayers, urging reform and institutional strengthening.
    Recommend comprehensive reform of the Advance Ruling regime to reduce tax litigation by improving AAR capacity and timeliness, lowering the high resident eligibility threshold, and creating an institutional council modeled on Swedish and New Zealand systems so advance rulings become a practicable, binding, and transparent mechanism to provide tax certainty and narrow further challenges.
    NotificationsCustoms
    Show AI Summary
    Supersession of regulations: new Transportation of Goods rules clarify governing instrument and resolve prior regulatory confusion.
    CBIC issued the Transportation of Goods (Through Foreign Territory), Regulations, 2020, expressly superseding the 1965 Regulations; prior notifications had temporarily purported to supersede and then restore the 1965 Regulations, creating stakeholder confusion about governing instruments until the 2020 regulations clarified the supersession.
    NewsBills
    Show AI Summary
    Retrospective GST amendments change exemption and levy rules and bar refunds on paid GST in specified goods.
    Amendments give retrospective effect to changes in GST treatment for specified goods: fishmeal exemption is limited with no refunds for paid GST; reduced levy treatment for certain pulley and wheel parts used in agricultural machinery is applied retrospectively, also without refunds; and refunds of accumulated compensation cess credit on tobacco products arising from an inverted duty structure are disallowed retrospectively.
    NewsBills
    Show AI Summary
    Removal of difficulties orders extended under GST compensation law to allow continued issuance for an additional statutory period.
    Amendment to Section 14 of the Goods and Services Tax (Compensation to States) Act, 2017 expands the temporal scope for issuing removal of difficulties orders, enabling the grant of such orders for an additional two-year period and thereby extending authority to issue orders until five years from the Act's commencement.
    NewsBills
    Show AI Summary
    Removal of difficulties orders extended to permit issuance beyond the original timeframe, enabling continued administrative corrections.
    The UTGST Act is amended by modifying Section 26 to extend the statutory authority to issue removal of difficulties orders, permitting continuation of those orders beyond the Act's initial transitional window and thereby lengthening the period during which administrative corrections and clarifications may be made under the Act.
    NewsBills
    Show AI Summary
    Extension of removal of difficulties orders: continuation permitted for two years under amended IGST Act provision.
    The amendment to Section 25 extends the authority to issue removal of difficulties orders for an additional two years, allowing such orders to be made up to five years from the date of commencement of the IGST Act, thereby prolonging the administrative mechanism to address implementation issues.
    NewsBills
    Show AI Summary
    Composition scheme exclusions expanded, affecting service suppliers and inter state service supplies and tightening input tax credit rules.
    Amendments revise the definition of Union territory, narrow the composition scheme to exclude specified categories of service supplies, delink debit note date from invoice date for input tax credit, prescribe manner and time limits for transitional credit, and strengthen registration, procedural and enforcement provisions including cancellation and revocation rules, invoice issuance for services, removal of TDS certificate obligations, and enhanced penalties and cognizable treatment for fraudulent availment of input tax credit.
    NewsBills
    Show AI Summary
    Excise duty increase and higher NCCD rates on tobacco products raise tax incidence and apply immediately.
    Amendment increases excise and NCCD rates for specified tobacco and tobacco substitute tariff items in the Seventh Schedule to the Finance Act, 2001, listing revised unit and ad valorem rates by tariff heading and measurement unit. The changes take effect on enactment and are applied immediately under the Provisional Collection of Taxes Act, 1931.
    NewsBills
    Show AI Summary
    Anti-circumvention measures expanded to enable investigations into circumvention of anti-dumping and countervailing duties.
    Amendments broaden Anti-Dumping Rules to strengthen anti-circumvention measures and clarify investigation scope for dumping that injures domestic industry; corresponding changes add an explicit investigatory mechanism in Countervailing Duty Rules to address circumvention of countervailing duties and clarify procedural scope. The instrument also revokes specified anti-dumping duties on purified terephthalic acid originating from certain trading partners.
    NewsBills
    Show AI Summary
    Social Welfare Surcharge exemption withdrawn; notification amended to remove specified tariff entries in certain chapters.
    Exemption from the Social Welfare Surcharge previously applicable to specified imported goods is being withdrawn by amendment to the governing customs notification, which omits certain table entries so those goods no longer attract the earlier surcharge exemption.
    NewsBills
    Show AI Summary
    Social Welfare Surcharge exemption on specified imported goods announced, covering foodstuffs, stone products and complete commercial vehicles.
    Social Welfare Surcharge is exempted on a specified list of imported goods identified by HS codes and descriptions, including dairy products (whey, cheese), live plants, nuts (almonds, walnuts), cereals (wheat, maize), chewing gum, infant food preparations, various forms of orange juice, selected marble and calcareous stone products (tiles, blocks, monumental stone), and all commercial vehicles (including electric vehicles) imported as completely built units.
    NewsBills
    Show AI Summary
    Customs tariff amendments tighten concession eligibility and harmonise BCD entries while removing redundant provisions.
    Amendments to customs tariff notifications revise BCD entries by omitting redundant listings, consolidating inconsistent tariff provisions, and narrowing ambiguous item scope so concessions apply only to intended end uses. Procedural and eligibility changes include imposing an actual user condition on a bamboo import concession, aligning technical conditions for satellite testing equipment and scientific instruments, clarifying assistive device coverage for disabled users, and removing the techno economic clearance requirement for a fertilizer renovation concessional BCD.
    NewsBills
    Show AI Summary
    Health cess on imported medical devices imposes an additional customs duty, excluding BCD exempt items and manufacturing inputs.
    A Health Cess is proposed as an ad valorem customs duty on imported medical devices (HS headings 9018-9022) measured by import value under the Customs Act; export promotion scrips cannot be used for payment. Devices exempt from basic customs duty and inputs/parts used in manufacture are exempt from the Cess, and proceeds are to fund health infrastructure.
    NewsBills
    Show AI Summary
    Customs duty exemptions withdrawn as obsolete; several notifications rescinded or consolidated into updated customs notifications.
    Several earlier customs duty exemption notifications are being withdrawn as no longer relevant, including exemptions for Commonwealth Games imports, power-project imports, Advance Customs Clearance Permit imports, SAARC preferential trade, goods produced in Nepal, wool/woollen fabrics and paper money by humanitarian entities, preferential tariff items, and water-supply projects under Project Imports; certain entries have been merged or superseded and some exemptions are now available through notification No. 50/2017-Customs.
    NewsBills
    Show AI Summary
    BCD exemption withdrawal removes concessional customs treatment for numerous listed import goods, restoring standard basic customs duty.
    Review under the Finance Bill 2020 withdraws concessional basic customs duty exemptions by omitting specified entries from Notification No. 50/2017-Customs, thereby removing concessional BCD treatment for a broad list of listed imports - including agricultural and food products, oils, sugars, raw materials, polymers, films, chemicals, specified machinery and project-tied imports - with several entries subject to quantitative caps or conditional provisos.
    NewsBills
    Show AI Summary
    Customs duty revisions reshape tariffs to protect domestic manufacturing while exempting inputs and conditioning concessional rates.
    Proposed revision of basic customs duty rates reallocates protection by increasing duties on finished consumer and automotive imports while reducing or exempting inputs and designated end-use materials to promote domestic manufacturing. Concessional rates and exemptions are conditional on specified end-uses and registrations, such as RNI registration for newsprint; electronic and mobile-phone components face staged duty increases with effective dates; defense-related imports by specified public sector undertakings are exempted subject to listed items.
    NewsBills
    Show AI Summary
    Basic Customs Duty increases apply to numerous tariff headings, altering import duty obligations from the effective date.
    Amendments increase the Basic Customs Duty in the First Schedule to the Customs Tariff Act, 1975 for numerous tariff headings, specifying revised duty percentages for defined commodities and adding new tariff entries; certain new entries show an operative zero effective rate. The changes are effective 02.02.2020 and declared immediately collectible under the Provisional Collection of Taxes Act, 1931.

    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 524 "Presumption as to assets, books of account, etc." between the Income-Tax Act, 2025 (as passed) and the Income-Tax Bill, 2025 (as originally introduced)

      17 September, 2025

      Contents
      Acts
      Rules & Regulations
      Summary
      Note

      Note

      -

      Bookmark

      Print

      Print

      Section 524 Presumption as to assets, books of account, etc

      Income-tax Act, 2025

      At a Glance

      The documents are two textual versions of Clause/Section 524 dealing with presumptions as to assets, books of account and related items encountered during searches (s.247) or surveys (s.253) under the Income-tax enactment. One is the enacted Section 524 of the Income-tax Act, 2025 (Document 1) and the other is the older Bill version of Clause 524 (Document 2). The provisions affect taxpayers, investigating officers and the Department; effective/decision date is Not stated in the document.

      Background & Scope

      Statutory hooks: references in the texts to searches u/s 247, surveys u/s 253 and requisitioning officer u/s 248. Both texts set out presumptions that may be drawn "in any proceeding under this Act" where specified items are found in the possession or control of a person during search or survey. Definitions or extended explanations are Not stated in the document beyond the explicit list of items and the cross-references to sections 247, 248 and 253.

      Statutory Provision Mode

      Text & Scope

      Coverage and elements (as stated in the Bill version, Document 2): Clause 524 provides that where any books of account, other documents, money, bullion, jewellery, virtual digital asset or other valuable article or thing is found in the possession or control of any person in the course of a search u/s 247 or survey u/s 253, it may, in any proceeding under this Act, be presumed-

      • (a) that such items belong to such person;
      • (b) that the contents of such books of account and other document are true;
      • (c) that signatures and parts purported to be in handwriting of a person are in that person's handwriting;
      • (d) in the case of a document stamped, executed or attested, that it was duly stamped and executed or attested by the person by whom it purports to have been so executed or attested (text includes a trailing phrase that is unclear: "article or thing belong or belongs to such person").

      Sub-section (2) in both texts provides that if books/documents/assets have been delivered to the requisitioning officer u/s 248, the presumptions apply as if those items had been found in the possession/control of the person in the course of a search u/s 247.

      Interpretation

      The Bill text creates evidentiary presumptions in proceedings under the Income-tax enactment where enumerated items are found during statutory search/survey processes. The phrase "it may ... be presumed" indicates a statutory permissive presumption (a rebuttable presumption) rather than an absolute rule; the Bill's accompanying explanatory note (in the summary line) expressly describes the provision as providing "a rebuttable presumption." The operative context for the presumptions is "in the course of a search u/s 247 or survey u/s 253" and in "any proceeding under this Act."

      Exceptions/Provisos

      No exceptions, provisos, thresholds, or conditions beyond the cross-references to sections 247, 248 and 253 are specified in the Bill text. Any carve-outs or procedural safeguards are Not stated in the document.

      Illustrations

      • Example 1: If during a search u/s 247, an assessor finds physical ledgers and jewellery in X's premises, Clause 524 permits a presumption that the ledgers and jewellery belong to X and that the ledger contents are true. (This follows from sub-clauses (a) and (b) of the Bill text.)
      • Example 2: If a stamped contract purportedly signed by Y is recovered in Y's control during a survey u/s 253, the contract may be presumed to be duly stamped and executed by Y per sub-clause (d). (Derived directly from the Bill text.)
      • Example 3: Not stated in the document. (No example involving electronic records is in the Bill text; the enacted Section 524, Document 1, includes such examples by reference to electronic information.)

      Interplay

      The clause expressly interfaces with: section 247 (search), section 253 (survey), and section 248 (requisitioning officer). There is an explicit mechanism in sub-section (2) treating items delivered to a requisitioning officer as if found during a search u/s 247. Interaction with rules, notifications or other circulars is Not stated in the document.

      Differences Between the Two Provisions and Practical Impact

      Key textual differences observed between the enacted Section 524 (Document 1) and the Bill/old Clause 524 (Document 2) are:

      • Inclusion of electronic information and computer systems: Document 1 expressly includes "any information in electronic form as defined in section 261(g) or on a computer system as defined in section 261(e) or any computer system containing the said information" among the items found and subject to presumptions. Document 2 omits any such express reference to information in electronic form or computer systems.
      • Additional presumption regarding electronic exchange: Document 1 contains a distinct clause (e) providing that "exchange of such information in electronic form, or on such computer system purported to be exchanged between any parties, is exchanged between the parties thereto." Document 2 lacks an equivalent clause.
      • Expanded specification of covered items: Document 1 repeats the list and explicitly connects "such information or computer system" to the presumptions in sub-clauses; Document 2 lists tangible/digital assets but does not incorporate electronic information/computer systems in the text of presumptions.
      • Stylistic/typographical differences: Document 2's clause (d) contains a textual anomaly-an apparent duplication or misplacement at the end ("...attested article or thing belong or belongs to such person"); Document 1's clause (d) is cleaner and constrained to the stamped/executed/attested document presumption.

      Practical impact of those changes (as directly deduced from the texts):

      • Broader evidentiary reach: The enacted text (Document 1) extends statutory presumptions to information in electronic form and to computer systems containing that information. This broadens the class of items which, when found in the course of a search/survey, may be treated as belonging to the person and whose contents may be presumed true.
      • Specific presumption for electronic exchanges: The addition of clause (e) in Document 1 creates a statutory presumption that an electronic exchange recorded on a system was exchanged between the purported parties. This directly addresses evidentiary weight for electronic communications.
      • Increased evidentiary burden on the possessor: By expanding presumptions to electronic records and exchanges, the enacted provision, on its face, shifts the initial evidentiary position in proceedings-raising the threshold for a person in whose possession such records are found to rebut the presumptions. The Bill version provided a narrower scope.
      • Operational/forensic consequences for investigations: The statutory inclusion of computer systems and electronic information signals that material seized in digital form will attract the same presumptive weight as physical books/documents found; this has implications for digital forensics, custody, and chain-of-evidence practices (the text does not prescribe procedures; those are Not stated in the document).

      Practical Implications

      • Compliance and risk areas: Under the Bill text, material found during searches/surveys attracts statutory presumptive weight for ownership, truth of ledger contents and authenticity of signatures. Taxpayers and their advisors should be aware that discovery of books/documents/assets during official actions can trigger presumptions in subsequent proceedings. The Bill version does not address electronic information specifically; the enacted text does-see the Differences section above.
      • Record-keeping/evidence points: The Bill text does not prescribe custody, notice, or forensic procedures; therefore, documentation of chain of custody, independent corroborating records and means to rebut presumptions will be relevant in practice. Specific requirements for handling or challenging electronic material are Not stated in the document.

      Key Takeaways

      • Clause 524 creates rebuttable presumptions in proceedings under the Act where enumerated items are found during searches (s.247) or surveys (s.253).
      • Presumptions cover ownership, truth of book/document contents, handwriting/signature authenticity and proper stamping/execution/attestation of documents.
      • Sub-section (2) treats items delivered to the requisitioning officer under s.248 as if found in a search under s.247.
      • The Bill version (Document 2) does not expressly mention information in electronic form or computer systems; the enacted Section (Document 1) expands the scope to include electronic information and a presumption as to electronic exchange.
      • No procedural safeguards, timelines, or mechanisms for rebuttal are specified in the Bill text; such matters are Not stated in the document.

      Full Text:

      Section 524 Presumption as to assets, books of account, etc

      Topics

      ActsIncome Tax