Accelerated assessment on business discontinuance enables taxation up to cessation with mandatory notice and taxation of post-cessation receipts.
Clause 320 permits discretionary accelerated assessment of income up to the date of business discontinuance, mandates separate assessments for each completed tax year or part thereof, requires mandatory notification of discontinuance within fifteen days, empowers notice and information-gathering powers on persons, partners or officers, and deems post-discontinuance receipts to be taxable as income of the recipient while clarifying that tax charged under the clause is additional to any other tax liability.

Preventive assessment of likely asset transfers: current year taxation triggered by AO belief of tax avoidance intent.
Clause 319 empowers the Assessing Officer to tax the total income of persons believed likely to dispose of assets to avoid tax, charging income in the current tax year from its first day until proceedings commence; it requires formation of an AO opinion based on credible material, applies procedural provisions analogous to those for persons leaving the jurisdiction, and raises interpretive issues including the undefined scope of "assets", the standard for AO satisfaction, the truncated assessment period, and overlap with other anti avoidance rules.

Taxation of short lived entities: income of event specific AOPs/BOIs/AJPs charged in the tax year up to dissolution.
Clause 318 empowers the Assessing Officer to treat the total income of an AOP, BOI or AJP formed for a particular event or purpose as chargeable to tax for the tax year from its first day up to the date of dissolution where the AO is satisfied the entity is likely to dissolve, and applies the Bill's expedited procedural machinery for assessment, provisional determination and recovery.

Assessment of persons leaving India: expedited tax assessment from the tax year start to departure with short notice requirements.
Clause 317 permits the Assessing Officer to assess an individual's total income from the first day of the current tax year up to the probable date of departure where the AO reasonably believes the individual intends not to return; income is assessed by completed tax years or part-years at rates in force, may be estimated if not readily determinable, and the AO may require an expedited return within a minimum seven-day period, with taxes charged under this provision being additional to other tax liabilities.

Recovery of tax from non residents: source withholding and attachment of any assets within India enable enforcement.
Clause 422 and Section 173 authorise two primary enforcement mechanisms against non residents: recovery by deduction at source imposed on payers, agents or representative assessees, and recovery by attachment of any assets of the non resident that are, or may at any time come, within India. These powers apply whether tax is assessed in the non resident's name or in the name of a representative assessee and operate without prejudice to other assessment and recovery provisions, creating a continuing domestic enforcement right subject to definitional, procedural and treaty interaction issues.

Presumptive taxation of foreign shipping secures Indian tax on carriage income via deemed income and port clearance linkage.
Clause 316 introduces a presumptive regime deeming a fixed proportion of amounts paid or payable for carriage from Indian ports as income of non resident ship owners or charterers, includes demurrage and similar charges, requires the ship's master to file a pre departure return with the Assessing Officer (with limited deferred filing), empowers assessment within nine months, ties tax payment or satisfactory arrangements to port clearance, and preserves an option for regular assessment with payments treated as advance tax.

HUF partition rules preserve deemed continuity and joint liability, limiting recognition of partial partitions and strengthening tax recovery.
Clause 315 deems an assessed HUF to remain undivided for tax purposes until a formal finding of partition is recorded; mandates AO inquiry with notice to all members when a partition is claimed; assesses HUF income up to the partition date as if no partition occurred; imposes joint and several liability on former members for tax, penalties, interest and other sums; allows recovery from pre-partition members; computes several liability in proportion to property allotted; and disallows recognition of partial partitions for tax purposes within the specified post-cut-off period.

Modified return requirement ensures tax assessments follow business reorganisation orders and must be adjusted accordingly.
Clause 314 mandates that a successor entity furnish a modified return within the prescribed period after a business reorganisation order, limited to changes necessitated by that order, and requires the Assessing Officer to modify completed assessments or complete pending assessments in accordance with the order and the modified return; ordinary Act provisions apply unless expressly overridden, and key terms including business reorganisation and successor are defined with coverage of insolvency-sanctioned reorganisations.

Continuity of tax liability on business succession: successor taxed post succession and may bear predecessor's unrecoverable dues.
Clause 313 mandates that the predecessor is assessed for income up to the succession date and the successor for income thereafter in the same tax year; pending proceedings against the predecessor are deemed on the successor; if the predecessor cannot be found or dues are irrecoverable, assessment and recovery may be effected on the successor, who may then recover amounts from the predecessor. The clause explicitly includes gains from transfer in "income" and defines "pendency" for insolvency and tribunal contexts, aligning tax continuity with insolvency processes.

Executor's right of recovery: statutory mechanism to reclaim taxes paid from the estate, subject to procedural adaptations.
Clause 312(7) makes Section 305 applicable to executors "so far as may be" in respect of tax paid or payable by them, treating executors as representative assessees and thereby enabling statutory recovery of taxes from the estate or beneficiaries while permitting necessary adaptations of procedures and raising questions on priority and apportionment in insolvent or contested estates.

Taxation of deceased estates: executor liable for estate income until complete distribution, with legatee inclusion on distributed income.
Clause 312 taxes income of a deceased person's estate in the hands of the executor or administrator, with a single executor assessed as an individual and multiple executors as an association of persons; the executor is deemed to have the deceased's residential status for the tax year of death, assessments of estate income are separate from the executor's personal returns, separate assessments apply for each tax year or part thereof until complete distribution, and income distributed to specific legatees is excluded from the estate's income and included in the legatees' income.

Joint and several liability of LLP partners applies where tax dues cannot be recovered from the LLP, subject to exculpation.
Clause 331 makes every person who was a partner of an LLP during the relevant tax year jointly and severally liable for any tax, penalty, interest, fees or other sums payable under the Income tax law that cannot be recovered from the LLP or relevant persons, expressly overriding LLP Act protections. Liability is triggered only after non recovery from the LLP and is rebuttable: a partner can escape liability by proving that the non recovery was not due to his gross neglect, misfeasance, or breach of duty.

Taxation of AOPs/BOIs with unknown member shares: maximum marginal rate applied to deter tax avoidance.
Clause 311 mandates taxation of an AOP/BOI's total income at the maximum marginal rate where members' shares are indeterminate or unknown, and requires taxation at any higher rate applicable to any member; when shares are determinate, it taxes the whole income at the maximum marginal rate if a member's other income exceeds the exemption threshold, while portions attributable to members chargeable at higher rates are taxed at those higher rates, with a deeming provision treating shares as indeterminate if so at formation or thereafter.

Firm taxation: firms taxed on total income at rates set annually in the Finance Act.
Clause 324 charges a firm which is assessable as a firm with tax on its total income at the rate specified in the Finance Act for the relevant year, applying only to entities that qualify as firms and requiring alignment with definitional, computation and allocation provisions elsewhere in the Act.

Representative assessee liability: authorities may use the same remedies against property under a representative's control to recover tax dues.
Clause 304(5) of the Income Tax Bill, 2025, mirrors Section 167 by empowering the Assessing Officer to exercise the same remedies in the same manner against all property vested in, or under the control or management of, a representative assessee as would be available against a person directly liable for tax, covering all kinds of property and applying regardless of whether the tax demand is raised against the representative or the beneficiary.

Direct assessment empowers tax authorities to bypass representative assessees and pursue beneficiaries directly, preserving recovery powers.
Clause 304(3) (Income Tax Bill, 2025) and Section 166 (Income tax Act, 1961) are non obstante provisions empowering the AO to directly assess and recover tax from the person entitled to income, irrespective of the existence of a representative assessee; these powers are discretionary, cover both assessment and recovery, preserve procedural safeguards for the beneficiary, and operate as alternative (not cumulative) mechanisms to prevent revenue loss due to procedural technicalities or representative non cooperation.

Proportional apportionment clarifies how beneficiaries' trust distributions are computed for tax using a statutory formula.
Clause 304(4) prescribes that where only part of a trust's income is chargeable, the taxable portion of a beneficiary's receipts is determined by multiplying the beneficiary's receipt by the ratio of the trust's chargeable part to its whole income (A x C / B), thereby codifying proportional apportionment and imposing related recordkeeping and reporting obligations on trustees and representative assessees.

Taxation of oral trusts: income charged at the maximum marginal rate regardless of other provisions, deterring informal trusts.
Income from oral trusts is taxed at the maximum marginal rate under both Section 164A and Clause 308, with a non-obstante clause to override other provisions; Clause 308 modernises the framework by referring to the person appointed under an oral trust and centralising the definition, thereby broadening potential liability and simplifying enforcement while raising disclosure and evidentiary burdens on assessees.

Taxation of indeterminate-beneficiary trusts: highest marginal rate applies unless narrow bona fide exceptions permit AOP rate.
Clause 307 taxes income of representative assessees at the maximum marginal rate where beneficiaries or their shares are not expressly identifiable in the trust instrument or court order, with deeming provisions treating ambiguity as indeterminacy. Exceptions permit taxation at the AOP rate for beneficiaries below exemption limits and not under other trusts, sole will-declared trusts, bona fide pre-1970 family trusts for dependents, and bona fide employee benefit funds. Business profits are generally taxed at the maximum rate, except for sole testamentary trusts for dependent relatives which may get AOP treatment.

Agent of non resident: expanded definition enables tax assessment and recovery from connected persons and intermediaries.
The clause defines who may be regarded as an agent of a non resident for tax purposes, listing persons employed by or acting for the non resident, those having any business connection with the non resident, persons from or through whom the non resident receives income, trustees, and any person acquiring a capital asset in India by transfer; it excludes certain brokers and requires an opportunity of being heard before treating any person as an agent.