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Act Rules Bills
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Concessional taxation for nonresident investment income and capital gains restructured, standardizing rates and raising scope and transitional questions.
Clause 214 restructures tax treatment for non-resident investment income and long-term capital gains by prescribing concessional flat rates for gains on specified assets and other investment income, retaining an aggregation mechanism that segregates concessional categories from remaining total income taxed at normal rates, while leaving key terms such as specified asset, investment income, and long-term capital gain to be defined by cross-reference, which creates potential scope and transitional ambiguities.
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Investment income taxation: new rule bars deductions and segregates capital gains, altering deduction eligibility for non-residents.
Clause 213 bars any deduction or allowance in computing the investment income of a non-resident Indian and provides that where gross total income consists only of investment income and/or long-term capital gains no deductions under Chapter VIII are permitted; where such income coexists with other income, the investment/long-term capital gains component must be excluded from gross total income before computing allowable deductions under Chapter VIII.
Act Rules Bills
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Foreign exchange asset definition narrows concessional tax eligibility for non-residents, affecting documentation and asset scope.
Clause 212 defines key terms for the concessional tax regime applicable to non-residents and foreign companies: foreign exchange asset (assets acquired with convertible foreign exchange), investment income (income from such assets), long-term capital gains (capital gains on foreign exchange assets not short-term), non-resident Indian (citizen or person of Indian origin who is not resident) and specified asset (shares, certain debentures and deposits, government securities, and notified assets). The clause updates cross-references to current company law and retains notification powers, while omitting an explicit explanation of person of Indian origin and an in-text definition of convertible foreign exchange, creating potential interpretive need for rules or guidance.
Act Rules Bills
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Taxation of specified income tightened for non-profit organisations, expanding taxable triggers and clarifying timing of taxability.
Clause 337 creates an event based tax regime for specified income of registered non profit organisations by enumerating eleven triggers (including anonymous donations above a threshold, related party benefits, prohibited overseas application, investment contraventions, corpus condition breaches, misapplication or non utilisation of accumulated income, transfers to other NPOs, application to non charitable purposes, and assessing officer determined business income) and linking each trigger to the tax year in which the taxable event occurs, thereby prioritising disclosure, accountability, and timing clarity while leaving rate and deduction rules to other provisions.
Act Rules Bills
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Taxation of online gaming winnings: a ring fenced flat rate regime with prescribed computation and enhanced reporting obligations.
Clause 194 creates a distinct tax regime for net winnings from any online game, applying to any person and defining online games broadly. Net winnings must be computed as prescribed, with gaming receipts ring fenced and taxed at a specified flat rate while remaining income is taxed ordinarily. The provision emphasizes definitions aligned with technology statutes and anticipates detailed subordinate rules for aggregation, timing, promotional credits, and interaction with TDS, with limited scope for deductions unless the computation rules provide otherwise.
Act Rules Bills
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Taxation of virtual digital assets: flat rate plus denial of loss relief reshapes compliance and reporting obligations.
Clause 194 (Table: S. No. 4) creates a dedicated tax regime for income from transfer of virtual digital assets, applying to any person and taxing such income at a flat rate while allowing only the cost of acquisition as a deduction. All other expenses, allowances, set offs and carry forwards of losses from VDA transfers are disallowed. The statutory definition of "transfer" applies to VDAs irrespective of capital asset status, requiring segregation of VDA income in tax computation and imposing enhanced record keeping and compliance obligations.
Act Rules Bills
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Taxation of carbon credit transfers: concessional flat tax with prohibition on deductions simplifies compliance and defines eligible credits.
Clause 194 of the Income Tax Bill, 2025 subjects income from transfer of carbon credits to a self contained regime: any person is taxable on such income at a flat 10% rate, computed by taxing the carbon credit income at 10% and taxing remaining income under normal provisions. The provision defines carbon credit as a UNFCCC validated reduction of one tonne of CO2 or equivalent gases tradable at market price, contains an overriding clause over other Act provisions, and expressly disallows any deduction or allowance in computing such income, resulting in taxation of gross consideration.
Act Rules Bills
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Concessional patent royalty regime offers lower tax for resident patentees subject to option, no deductions, and lockout on noncompliance.
A concessional regime taxes royalty from patents developed and registered in India for resident patentees as gross income at a concessional rate, disallowing any deduction; assessees must exercise a prescribed option within the prescribed time, and non compliance for any of five succeeding years triggers a five year ineligibility. Definitions require substantial in country development expenditure and exclude sale proceeds and capital gains from royalty.
Act Rules Bills
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Tax on unexplained income: punitive flat rate and denial of deductions for incomes classified under specified provisions.
Clause 195 targets income referred to in sections 102-106, applying whether self declared or determined by the Assessing Officer, and mandates taxation of those amounts at a punitive flat rate while the balance income is taxed normally. It further provides an overriding rule that no deduction, allowance, or set off of losses is permitted against the income so classified, thereby preventing taxpayers from reducing liability on such unexplained or unaccounted sums.
Act Rules Bills
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Anonymous donations taxation: broader scope and threshold rule increase compliance and record-keeping obligations for non-profits.
Clause 337 targets anonymous donations to registered non-profit organisations (excluding entities wholly for religious purposes) by taxing the amount of anonymous donations exceeding the higher of a specified absolute sum or a percentage of such donations in the tax year, with contemporaneous recognition of receipts. The clause broadens applicability beyond the prior enumerated institutions, omits a specified tax rate, and lacks detailed definitions and compliance mechanics, creating interpretive and administrative uncertainties for mixed purpose organisations and cross border receipts.
Act Rules Bills
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Special taxation of non-resident sports and entertainment income: flat-rate treatment with no deductions and TDS-driven compliance.
A flat-rate regime taxes specified India-sourced receipts of non-resident sportsmen, sports associations, and entertainers-covering participation, performances, advertisements and article contributions-with such receipts treated as ring-fenced special income taxed separately from other income; deductions are expressly disallowed for computing that special income, and proper withholding at source can exempt a taxpayer from domestic return-filing when that is the taxpayer's sole Indian income.
Act Rules Bills
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Tax on gambling winnings: flat gross tax with no deductions, and online gaming treated separately.
Clause 194 (Table S. No. 1) taxes winnings from lotteries, crossword puzzles, races (excluding income from owning or maintaining race horses), card games and other gambling at a flat rate on gross receipts with no deductions or set-off; tax is computed in two steps-tax on such winnings and tax on the balance of income as if winnings were excluded-and winnings from online games are expressly excluded and dealt with separately.
Act Rules Bills
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Concessional tax regime for new manufacturing co-operative societies offers reduced tax for qualifying manufacturing income.
A concessional tax regime grants newly formed manufacturing co-operative societies an optional, irrevocable reduced tax treatment for qualifying manufacturing income, contingent on formation and commencement within prescribed windows, exercise of the option in the prescribed manner, and compliance with anti abuse conditions. Qualifying income is computed without specified deductions or set offs, certain non manufacturing income and specified gains are taxed at higher rates, and failure to satisfy conditions withdraws the regime for the relevant and subsequent years.
Act Rules Bills
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Concessional tax regime for resident cooperative societies: elective simplified computation in exchange for forgoing specified deductions.
Clause 203 establishes an elective concessional tax regime for resident cooperative societies permitting computation of total income without specified deductions and without set-off of losses or depreciation attributable to those disallowed deductions; the option is exercised in the prescribed manner within the return-filing timeframe, is irrevocable, and failure to meet conditions renders the option invalid for that and subsequent years, while losses and depreciation not allowed are deemed finally given effect. An IFSC carve-out permits designated deductions for IFSC units subject to conditions.
Act Rules Bills
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New tax regime narrows exemptions and denies related loss carry-forwards, requiring strict opt-in procedures and electronic compliance.
Clause 202 creates a consolidated new tax regime for individuals, HUFs, AOPs, BOIs and certain artificial juridical persons pairing a graded slab structure with the denial of most specified exemptions, deductions and loss set-offs. Total income is computed without the benefit of listed deductions and without carry-forward or set-off of losses and depreciation attributable to those disallowed items. The clause prescribes an option procedure with strict withdrawal and re-entry limits for business/professional assessees and contemplates procedural electronic filing requirements and an IFSC carve-out.
Act Rules Bills
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Concessional tax regime for new manufacturing companies limits exemptions and binds firms to an irrevocable option for preferential taxation.
Concessional tax regime for new manufacturing domestic companies grants a lower corporate rate to qualifying manufacturers while disallowing most exemptions and deductions. The regime requires an irrevocable option, exercised in the prescribed manner by the due date for the first return; failure to meet conditions causes permanent loss of eligibility. Income computation is exemption free, with no carry forward for losses or depreciation attributable to disallowed deductions. Benefits can continue on amalgamation if conditions are met. Procedural and definitional details are expected to be specified in subordinate rules.
Act Rules Bills
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Optional concessional corporate tax regime requires companies to forgo specified deductions and accept irrevocable tax treatment.
Optional concessional corporate tax regime requires domestic companies to compute taxable income without specified deductions and to forgo set-off or carry forward of losses or depreciation attributable to those disallowed items, treating such losses and depreciation as having been given full effect; the option must be exercised in the prescribed manner by the filing due date, is irrevocable and applies to subsequent tax years, with modified treatment for IFSC units and procedural details to be provided by subordinate rules.
Act Rules Bills
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Concessional tax regime for manufacturing companies requires irrevocable option and prohibits set off of attributable losses.
Clause 199 creates a concessional tax regime for qualifying domestic manufacturing companies, available at the taxpayer's option, conditioned on exclusive engagement in manufacturing related activities and computed without specified deductions. It precludes set off of losses attributable to those disallowed deductions by deeming such losses to have been fully given effect to. The option must be exercised in the prescribed manner by the due date for the first return and, once exercised, is irrevocable for subsequent years except where a statutory switch is permitted, thereby trading lower tax rates for forfeiture of targeted incentives and necessitating clear procedural compliance.
Act Rules Bills
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Taxation of special incomes: consolidated flat-rate regime covering life insurance profits and emerging digital income streams.
Clause 194 creates a consolidated flat-tax framework for specified special incomes-winnings, patent royalties, carbon credits, VDAs, online game winnings, and life insurance profits-providing category-specific rates, comprehensive definitions, and an overriding application. For life insurance business it preserves a concessional 12.5% flat tax and the aggregate computation method but omits the prior temporary deposit requirement and lacks detailed computation rules, potentially causing interpretive issues on measuring ''profits and gains.'' Clause 194 modernises taxation of emerging income streams while centralising special-income treatment under one provision.
Act Rules Bills
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Taxation of foreign portfolio investment: concessional rates tied to strict attribution and compliance requirements.
Clause 210 creates a consolidated tax framework for FIIs and specified funds on securities income and capital gains, setting concessional rates by income category and conditioning those rates on prescribed attribution to non resident unit holders (excluding permanent establishments). It restricts specified deductions where income consists solely of securities receipts, disapplies certain loss set off provisions for securities gains, and anticipates rule based mechanisms for daily AUM attribution and digital filing requirements, aligning and refining the policy and operational features previously governed by Section 115AD and Rules 21AJ/21AJAA.

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PROPOSALS INVOLVING CHANGES IN BASIC CUSTOMS DUTY RATES AND CLARIFICATORY AMENDMENTS IN RESPECTIVE NOTIFICATIONS - FINANCE (No.2) BILL, 2019

5 July, 2019

Contents
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PROPOSALS INVOLVING CHANGES IN BASIC CUSTOMS DUTY RATES AND CLARIFICATORY AMENDMENTS IN RESPECTIVE NOTIFICATIONS

S. No

Heading, sub-heading tariff item

Commodity

From

To

 

 

Defence 

 

 

1

Any Chapter 

Specified Defence equipment and their parts imported by the Ministry of Defence or the Armed Forces

Applicable rate

Nil

 

 

Medical Devices

 

 

2

Any Chapter

Raw material, parts or accessories  for use manufacture of artificial kidneys, disposable sterilized dialyzer and micro-barrier of artificial kidney

Applicable rate

Nil

 

 

Food processing

 

 

3

0801 32 10

Cashew kernel broken 

₹ 60/ Kg or45%, whichever is higher

70%

4

0801 32 20,

0801 32 90

Cashew kernel whole, Cashew nuts shelled, others 

₹ 75/ Kg or 45%, whichever is higher

70%

 

 

Nuclear Fuels and Nuclear Energy projects

 

 

5

2612 10 00

All forms of Uranium ores and Concentrates for generation of nuclear power (Uranium concentrate U3O8 already exempt)

2.5%

Nil

6

2844 20 00

All goods for use in generation of Nuclear power (Certain goods such as sintered natural uranium dioxide already exempt)

7.5%

Nil

7

9801

All goods required for setting up of the following power projects under project imports: -

a)Mahi Banswara Atomic Power project- 1 to 4, Mahi Banswara site Rajasthan

b)Kaiga Atomic Power project – 5 & 6, Kaiga site, Karnataka

c)Gorakhpur Atomic Power project- 3 & 4, GHAVP, Haryana

d)Chutka Atomic Power project- 1 & 2, Chutka site, Madhya Pradesh

Applicable rate

Nil

 

 

Oils and associated chemicals 

 

 

8

Chapter 15, 

2915 70,

3823 11 00,

3823 12 00, 3823 13 00,

3823 19 00

Palm stearin and other oils, having 20% or more free fatty acid, Palm Fatty Acid Distillate and other industrial monocarboxylic fatty acids, acid oils from refining, for use in manufacture of soap and oleochemicals.

Nil

7.5%

 

 

Petroleum and Petrochemicals

 

 

9

2709 00 00

Petroleum Crude

Nil

Re. 1 per tonne

10

2710

Naphtha

5%

4 %

11

2903 15 00

Ethylene dichloride (EDC)

2%

Nil

12

2910 20 00

Methyloxirane (Propylene Oxide)

7.5%

5%

13

 

Plastic and Rubber 

 

 

14

3904

Poly Vinyl Chloride

7.5%

10%

15

3926 90 91,

3926 90 99 

Articles of plastics 

10%

15%

16

4002 31 00

 All goods i.e. Butyl Rubber

5%

10%

17

4002 39 00

 Chlorobutyl rubber or bromobutyl rubber

5%

10%

 

 

Paper and Paper products

 

 

18

 48

a. Newsprint 

Nil

10%

 

 

b.Uncoated paper used for printing of newspapers

 

 

 

 

c.Lightweight coated paper used for printing of magazines

 

 

19

4901 10 10,

4901 91 00,

4901 99 00

Printed books (including covers for printed books) and printed manuals, in bound form or in loose-leaf form with binder, executed on paper or any other material including transparencies.

Nil

5%

 

 

Textiles

 

 

20

5101

Wool Fibre

5%

2.5%

21

5105

Wool Tops

5%

2.5%

 

 

Flooring materials

 

 

22

2515 12 20,

6802 10 00,

6802 21 10,

6802 21 20,

6802 21 90,

6802 91 00,

6802 92 00

Marble Slabs

20%

40%

 

 

Inputs for Optical Fibres

 

 

23

28 or 70

Raw materials used in manufacture of Preform of Silica:-

(i)Refrigerated Helium Liquid (2804 29 10)

(ii)Silicon Tetra Chloride and Germanium Tetra Chloride (2812 19 20, 2812)

(iii)Silica Rods (7002 20 90)

(iv)Silica Tube (7002 31 00)

Applicable Rate

 

Nil  

24

5603 94 00

Water blocking tapes for manufacture of optical fiber cable

Nil

20%

 

 

Precious Metals

 

 

25

7106

Silver dore bar, having silver content not exceeding 95%

8.5%

11%

26

7108

Gold dore bar, having gold content not exceeding 95%

9.35%

11.85%

27

71 or 98

(a) Gold (excluding ornaments studded with stones or pearls) imported by an eligible passenger as baggage

(b)Silver (excluding ornaments studded with stones or pearls)  imported by an eligible passenger as baggage

10%

12.5%

 

 

Iron and Steel, Other base metals

 

 

28

7218

Stainless steel in ingots or other primary forms; semi-finished products of stainless less

5%

7.5%

29

7224

Other alloy steel in ingots or other primary forms; semi-finished products of other alloy steel

5%

7.5%

30

 

7225, 

7225 19 90

Inputs for the  manufacture of CRGO steel:-

a) MgO coated cold rolled steel coils

b)Hot rolled coils

c)Cold-rolled MgO coated and annealed steel

d)Hot rolled annealed and pickled coils

e)Cold rolled full hard

5%

2.5%

31

7226 99 30

Amorphous alloy ribbon

10%

5%

32

7229

Wire of other alloy steel (other than INVAR)

5%

7.5%

33

8105 20 10

Cobalt mattes and other intermediate products of cobalt metallurgy

5%

2.5%

 

 

Capital goods

 

 

34

8474 20 10

Stone crushing (cone type) plants for the construction of roads

Nil

7.5%

35

82, 84, 85 or 90

Capital goods used for manufacturing of following electronic items, namely-

(i)Populated PCBA

(ii)Camera module of cellular mobile phones

(iii)Charger/Adapter of cellular mobile phone

(iv)Lithium Ion Cell

(v)Display Module

(vi)Set Top Box

(vii)Compact Camera Module 

Applicable rate

Nil

36

84, 85 or 90

Capital goods used for manufacturing of specified electronic items, namely-

(i)Cathode Ray tubes;

(ii)CD/CD-R/DVD/DVD-R;

(iii)Deflection components, CRT monitors/CTVs;

(iv)Plasma Display Panel

Nil 

Applicable 

 

 

Electronics

 

 

37

8504 40

Charger/Power adapter for CCTV camera/IP camera/DVR/NVR

Nil

15%

38

85

Specified electronic items like plugs, sockets, switches, connectors,  relays.

Nil

Applicable rate

 

 

Automobile and automobile parts 

 

 

39

8421 39 20,

8421 39 90

Catalytic convertor (All goods under these tariff items other than catalytic converters will continue at 7.5%)

5%

10%

40

8702, 8704

Completely Built Unit (CBU) of vehicles falling under heading 8702, 8704

25%

30%

41

Any Chapter 

(i)E-Drive assembly, 

(ii)On board charger, 

(iii)E-compressor and

(iv)Charging Gun

Following parts of electric vehicles: -

Applicable rate

Nil

42

87

Prescribing actual user condition in respect of existing exemption from BCD to parts of Hybrid vehicles

-

-

 

 

Oil rigs and other goods used for oil exploration

 

 

43

84 or any other chapter 

Providing option to pay BCD at transaction value on the disposal of goods, imported without payment of customs duty for petroleum operations / coal bed Methane operations where such disposal is made in unserviceable and mutilated condition

Applicable rate on depreciated value 

7.5% on transaction value

 

 

Export Promotion for Sports goods

 

 

44

39 , 4407 

Foam/EVA foam (39) and Pine Wood (4407) are being included in the list of items allowed duty free import upto 3% of FOB value of sports goods exported in the preceding financial year subject to specified conditions

Applicable rate

Nil

 

Clarifications and Miscellaneous changes regarding Basic Customs Duty

 

 

Fisheries

 

 

45

2309

Clarification is being issue that prawn feed and shrimp larvae feed, other than in pellet form will also attract 5% customs duty applicable on other fish feed in pellet form.  

 

 

 

 

Topics

Acts Income Tax