Concessional TDS rates on specified foreign borrowings extended and a lower rate introduced for IFSC listed bonds.
Amendment of section 194LC extends concessional withholding for interest paid to non residents on eligible foreign currency borrowings by a specified company or business trust, maintaining the concessional rate for approved loans, long term bonds and rupee denominated bonds within prescribed limits. It also establishes a lower withholding rate for interest on long term bonds and rupee denominated bonds issued from abroad that are listed solely on a recognised IFSC stock exchange, with the amendment operating from the commencement date specified in the Finance Bill.

Concessional tax for new manufacturers: generation of electricity treated as manufacturing allowing concessional rate subject to eligibility conditions.
The amendment clarifies that manufacturing or production for the concessional tax regime includes generation of electricity. Eligible new domestic manufacturing companies-set up on or after 1 October 2019 and commencing by 31 March 2023-that do not avail specified incentives or deductions may opt for the concessional tax provision. The change takes effect from 1 April 2020 and applies from the assessment year 2020-21 onward.

Offshore fund exemption relaxed: manager contributions initially excluded and corpus timing harmonised to reduce discrimination.
Amendments to section 9A relax two eligibility conditions for offshore funds' exemption from creating a business connection: contributions by the eligible fund manager during the first three years up to a capped amount will be excluded when calculating the aggregate participation of Indian residents, and funds established in the previous year must meet the monthly average corpus requirement within twelve months from the last day of the month of establishment or incorporation. The amendments take effect from 1 April 2020.

Deduction under section 80EEA extended to include additional loans, broadening affordable housing tax relief eligibility.
The proposal extends the sanctioning period for loans eligible for the interest deduction under section 80EEA for acquisition of affordable residential property, allowing additional loans to qualify subject to existing conditions, including the stamp duty threshold and cap on interest relief. The amendment takes effect from 1st April, 2021 and applies to the assessment year 2021 22 and thereafter.

Extension of approval period for affordable housing projects expands eligibility for full business profit deduction under section 80-IBA.
Extension of the approval deadline under section 80-IBA permits additional affordable housing projects to meet the statutory approval-timing condition for claiming a deduction equal to one hundred per cent of profits and gains from the business of developing and building such projects; the approval deadline is extended to 31st March, 2021 and the amendment takes effect from 1st April, 2021, applying to the assessment year 2021-22 and thereafter.

Startup deduction expanded: three-year relief selectable within first ten years and turnover eligibility substantially increased.
Amendment revises the start-up deduction so an eligible start-up may claim a three-consecutive-assessment-year deduction selectable within ten years from incorporation, and raises the turnover eligibility ceiling so the deduction applies where total business turnover does not exceed a substantially higher threshold in any previous year counted from incorporation; the change takes effect from the start of the next fiscal cycle and applies to subsequent assessment years.

Exemption for strategic petroleum reserve income: income exempt if replenishment occurs within three-year period under government directions.
Exemption is provided to ISPRL for income arising from arrangements for replenishment of crude oil stored in its Indian storage facilities when replenishment is carried out pursuant to directions of the Central Government, subject to the condition that the crude oil is replenished within three years from the end of the financial year in which it was first removed from storage; effective from 1 April 2020 for assessment year 2020-21 onward.

Exemption for sovereign wealth fund investments: dividends, interest and long-term capital gains eligible if conditions satisfied.
A new exemption applies to income in the nature of dividend, interest and long-term capital gains of a specified person arising from investments, debt or equity, in Indian companies or enterprises engaged in developing, operating or maintaining infrastructure facilities or other notified businesses, provided the investment is made on or before the prescribed cut-off and held for the minimum required period. "Specified person" includes a wholly owned ADIA subsidiary resident in the UAE and sovereign wealth funds satisfying defined ownership, regulatory, benefit, vesting, commercial activity and notification conditions.

Withdrawal of income-tax exemption for specified perquisites to UPSC and Election Commissioners, bringing those benefits into taxable income.
The Finance Bill removes income-tax exemption for specified allowances and perquisites previously granted to serving and retired UPSC Chairmen and members and to the Chief Election Commissioner and Election Commissioners. Exemptions being withdrawn include rent-free residence, conveyance and transport allowances, sumptuary allowance, leave travel concession, post-retirement secretarial and telephone allowances, medical facilities and related service condition benefits, with the change to apply prospectively from the stated fiscal implementation point and to the subsequent assessment year.

Concessional tax option: domestic companies barred from Chapter VI-A deductions except limited exceptions, narrowing eligible incentives.
Domestic companies electing the concessional tax regime are barred from claiming any Chapter VI-A deductions except two specified exceptions: the employee-related wage deduction and the intercorporate dividend relief provision. This amendment takes effect from 1 April 2020 and applies to the assessment year beginning thereafter and subsequent assessment years, narrowing the deductions and incentives available to companies that opt for the special tax rate.

New concessional tax regime for individuals and HUFs allows optional slab taxation with strict deduction and withdrawal conditions.
Insertion of section 115BAC allows individuals and HUFs to opt into a concessional tax regime from assessment year 2021-22 under specified slab rates, subject to conditions: limited permitted allowances, broad disallowance of exemptions and deductions (including many section 10 exemptions, chapter VI-A deductions, and certain depreciation and loss set-offs), prescribed treatment of depreciation and transitional written-down value adjustment, prescribed exercise and withdrawal mechanics, and consequential exclusion from AMT and AMT credit carry-forward provisions.

Concessional tax option for resident co-operative societies permits a reduced corporate rate subject to strict disallowances.
A new provision allows resident co-operative societies to opt for a concessional tax regime from the assessment year beginning 1 April 2021 where the society elects the option by the prescribed due date; the option is irrevocable and applies to subsequent years. Eligibility requires computing total income without specified deductions or incentives and without set-off of earlier losses or depreciation attributable to those disallowed items; such losses and depreciation are deemed given full effect and barred from future deduction, with prescribed written down value adjustments for unabsorbed depreciation. The regime attracts a 10 per cent surcharge and excludes applicability of Alternate Minimum Tax and related credit carryforward.

Tax rate structure and withholding: optional new regimes affect salary TDS, advance tax and surcharge treatment.
Part III of the First Schedule prescribes slab-based TDS rates on salaries, advance tax computation rules and surcharge bands with marginal relief for individuals, HUFs, co-operative societies, firms, local authorities and companies; it retains distinct corporate rates tied to turnover, applies a health and education cess, and creates elective alternate tax regimes including optional taxation under section 115BAC for individuals/HUFs and section 115BAD for resident co-operative societies, which affect rate computation and surcharge treatment.

Tax Deduction at Source: rates remain as prior year; new sections added and section 194 rate amended.
Tax deduction at source rates for non-salary incomes in FY 2020-21 remain as specified in the prior year schedule; section-specific deduction provisions persist. New sections 194K and 194O specify rates within those sections, and the rate under section 194 is revised to a rate stated in the Bill. Surcharge provisions apply to non-resident recipients by category and income bands, and Health and Education Cess continues to apply on income tax including surcharge.

Surcharge tiers on income-tax established by taxpayer class and income bands; marginal relief and health and education cess apply.
The Bill prescribes tax rates for assessment year 2020-21 and establishes a multi-tier surcharge regime differentiated by taxpayer class and income bands, with specific caps on surcharge for income taxed under certain provisions. Marginal relief is provided to temper surcharge effects at thresholds. A Health and Education Cess is levied at a fixed rate on income tax inclusive of surcharge, with no marginal relief available for the cess.

Judicial custody applied where investigative agency failed to demonstrate necessity for police or CBI custodial interrogation.
The magistrate refused the investigating agency's request for custodial interrogation, finding insufficient grounds for police/CBI custody and remanding the accused to judicial custody pending further production. The accused and co accused presented conflicting accounts-one alleging he had been investigating a larger fraud and that superiors failed to act-while defence counsel warned of administrative consequences arising from custody. The magistrate applied the requirement that custodial remand be justified by demonstrable investigative necessity rather than allegation alone.

Reopening of assessment: Section 148 notices held in abeyance pending Supreme Court decision on Section 80P deduction entitlement.
Reopening of assessment under Section 147 and notices under Section 148 to cooperative societies were stayed and kept in abeyance pending disposal of Special Leave Petitions concerning entitlement to deduction under Section 80P(2)(a)(i) read with Section 80P(4). The High Court ordered that if the Supreme Court allows the SLPs the notices will revive and reassessment may proceed, and if the Supreme Court rules for the assessees the impugned notices will be set aside.

Pre-deposit requirement can be satisfied before the appeal is first taken up for consideration, permitting admission if paid.
The pre-deposit obligation is an independent mandatory condition distinct from the limitation period for filing or condoning delay; it need not be discharged at filing but can be satisfied up to the moment the appellate authority first takes the appeal up for consideration for condonation or admission. If proof of payment of the specified tax dues is not produced by that first consideration, the appellate authority must reject the appeal as institutionally defective and has no power to extend time to deposit.

Substance over form requires assessing officers to inquire beyond certified statutory forms before reopening assessments.
Non-disclosure must be sufficiently material to show that, but for it, income would have escaped assessment; Assessing Officers must not rely mechanically on CA-certified statutory forms and must make independent enquiries, applying the substance over form principle when determining commencement of commercial production or eligibility for tax concessions.

Search and seizure authorization: proper officer's reason to believe permits prohibition orders and provisional release via clause six.
Section 67 empowers an authorised proper officer, not below Joint Commissioner, to search and seize goods or documents when he has reason to believe they are secreted; if seizure is impracticable, a prohibition on dealing with goods may be issued under Rule 139(4). "Secreted" includes items not kept in their normal place or likely to be kept out of the way, and the officer must have a reasoned belief before exercising search powers. Procedural accuracy in authorisation and forms is required, and clause (6) permits provisional release on bond, security or payment.