Section 350: Exclusive permitted investment and deposit modes for registered non-profit organisations with transitional short-holding grace
The schedule enumerates the exclusive modes in which monies under section 350 may be invested or deposited by registered non-profit organisations, listing government-backed savings, scheduled/cooperative bank deposits, specified public sector and regulated corporate instruments, certain mutual fund units, approved infrastructure and housing bonds, immovable property within limits, specified shares and units (including incubator/incubatee and payment-system related investments), historical corpus exceptions and a one-year short-holding grace for non-specified assets. Differences between the Act and Bill versions are editorial (titles, numbering, minor wording and placement of definitions); substantive permitted modes and transitional carve-outs remain effectively the same.

Schedule XV lists deductible payments under section 123, defining life-insurance, annuities, provident funds, tuition, housing, and capital subscriptions
Schedule XV enumerates payments deductible under section 123, covering life-insurance premia (with percentage caps linked to issue dates and disability), deferred annuities, provident/superannuation contributions, specified deposits, tuition for two children, housing purchase/construction costs (subject to limits), and certain capital-issue subscriptions, with recapture rules on surrender, early withdrawal, or sale. Key differences between the Act and the Bill are cross-references defining "security" and "eligible issue of capital" and minor drafting variants; those cross-reference changes can alter which instruments qualify and create interpretive uncertainty pending implementing notifications and rules.

Schedule XIV defines separate tax bases for life and non-life insurance, with rules for averaging, add-backs, and credits
Schedule XIV prescribes distinct tax bases for life and non-life insurance: life-insurance taxable income is the annual average of actuarial surplus for the last inter-valuation period (with specified adjustments and separate computation), while non-life taxable profit is profit before tax and appropriations per statutory accounts subject to enumerated add-backs and permitted reserve deductions. Special rules govern inter-valuation periods exceeding 12 months for tax credits and TDS averaging. Key drafting differences between the Bill and the Act affect a cross-reference to credit denial, a limiting qualification on add-backs, and the standard for non-resident allocation ("reliable" vs "more reliable"), creating operational uncertainties until clarified.

Schedule XI sets trust, vesting and investment rules for provident, superannuation and gratuity funds; tax on excess contributions above 12%
Schedule XI governs recognised provident, approved superannuation and gratuity funds, conditioning tax-favourable treatment on trust structure, vesting, permitted assets, payment rules and residency/employee thresholds; recognition/approval is discretionary and revocable. The Act and Bill are substantively aligned with drafting refinements, cross-reference edits and minor wording changes; the material divergence concerns which statute defines "government securities," affecting the 50% investment cap and trustees' permitted investments. Employer contributions above prescribed thresholds (e.g., excess over 12% for provident funds) and interest above notified rates are taxable to employees. Trustees/employers must maintain prescribed accounts, comply with reporting, monitor investments and face inspection, TDS and post-cessation liability risks.

Deduction allowed for SBI site-restoration deposits for petroleum and gas businesses, capped at 20% of profits; diversion triggers clawback
A statutory Schedule creates a deduction for deposits into designated site restoration accounts (maintained with the State Bank of India) for businesses engaged in petroleum/natural gas operations, limited to the lesser of actual deposits or 20% of pre-deduction profits, subject to audit, scheme conditions and strict withdrawal/use restrictions; diversion or closure triggers deeming/clawback rules and disallows duplicate deductions. Most edits between the Bill and the enacted Act are drafting or locational, but a material divergence exists: the Bill expressly deems amounts used to buy specified assets as taxable income on utilisation, whereas the Act's parallel provision primarily disallows the deduction (with other paragraphs still enabling deeming in certain cases).

Deduction for tea, coffee and rubber deposits capped at lesser of actual or 40% of profits, audited, timed, eight-year clawback
The Schedule creates a deduction for deposits into tea, coffee and rubber development accounts equal to the lesser of actual deposits or 40% of business profits, subject to audited evidence, deposit-timing, restricted withdrawals, immediate taxation on unauthorized use, and an eight-year claw-back on assets funded by the accounts; claimed amounts cannot be re-claimed. Key differences between the Bill and the enacted Act include a cross-reference change (section 110 vs 112), the Act's explicit six-month/return-due deposit timing, slight variations in audit verification language, a missing "special scheme" definition and a statutory citation inconsistency for the Rubber Act.

Amended Schedule excludes certain income and tightens compliance rules for registered political parties and electoral trusts
The Schedule excludes specified income (house property, other sources, capital gains, and voluntary contributions) from the total income of registered political parties and voluntary contributions for electoral trusts, subject to conditions: registration eligibility, maintenance of books and audited accounts, donor identification for non-electoral-bond contributions over Rs.20,000, prescribed receipt modes for donations over Rs.2,000, timely filing of returns, and electoral-trust distribution of 95% of receipts in the tax year. Amendments clarify cross-references and delegated rule-making language, tightening compliance and reducing drafting ambiguity.

Enacted Schedule VII preserves tax-exempt categories, fixes typos and cross-references, clarifies anonymous donations; Bill had inconsistencies.
The comparison shows that the enacted Schedule VII preserves the Bill's core list of tax-exempt entity categories and conditions but corrects typographical errors, standardises cross-references and clarifies treatment of anonymous donations, while the Bill version contains drafting inconsistencies and a numeric receipts threshold formulation. Key differences affect interpretation and administration: the Act adds a corrigendum and clearer cross-references (reducing ambiguity on anonymous donations), standardises "Nil" conditions, and refines notification/approval language; the Bill's wording and punctuation variations could create interpretive friction. Practically, entities must rely on the final enacted text for eligibility, approvals, notifications and compliance documentation.

Schedule VI narrows IFSC income exclusions, clarifies definitions and delegation, cross-reference to section 147, compliance critical
The comparison shows Schedule VI excludes specified IFSC-related income from total income for eligible non-residents, IFSC units and specified funds, but the enacted Act refines drafting from the Bill: it adds explicit items (e.g., "Nil" for the specified-fund condition), standardises "as may be prescribed" delegation, tightens cross-references (notably to section 147) and clarifies definitions and scope (e.g., inclusion of OTC derivatives). Substantive tax outcomes remain similar, but eligibility is fact-sensitive and conditional (convertible foreign exchange, unit-holding limits, commencement/ten-year windows) and depends on delegated rules, so compliance, documentation and rule notifications are critical.

Schedule V narrows income exclusions for institutional investors, sets timing, holding-period, proportional rules, clawback, and guideline powers
SCHEDULE V excludes specified categories of income from total income for defined institutional investors (investment funds, business trusts including REITs/InvITs, venture capital vehicles and certain foreign public investors), operating as a negative list subject to detailed notes, cross-references to SEBI/RBI/IFSC rules and conditions. Eight table entries set scope (e.g., exclusion of non-business income for investment funds, SPV interest/dividend exemptions for business trusts, unit-holder distribution carve-outs, venture capital and "specified person" exemptions). Sl. No.7 imposes temporal and holding-period limits (investments 1-Apr-2020 to 31-Mar-2030; three-year hold), proportional computation rules, clawback on failure, and an express bar for sovereign/pension funds that use borrowings. The Board may issue binding guidelines with government approval.

Schedule IV exempts specified income for eligible non-residents and foreign companies, subject to residency, stay, permissions, and documentation.
Schedule IV exempts specified categories of income from total income for eligible non-residents, foreign companies and related persons, conditional on residency status, duration of stay, absence of trade or business in the jurisdiction, regulatory permissions and Central Government notifications or agreements. Exemptions cover bank interest on NRE accounts, diplomatic remuneration, short-term non-resident employment income, certain royalties/fees to security agencies, offshore banking deposits, intra-group cruise lease rentals, notified crude-oil arrangements and EEC investments. Differences between the enacted Act and the original Bill are editorial or phrasing variations only; no substantive change in scope is discernible. Compliance documentation and notifications are critical.

Schedule excludes specified incomes from total income but enacted text renumbering, cross-reference errors require careful compliance and monitoring
The Schedule lists incomes excluded from total income for specified eligible persons, preserving targeted tax exemptions (pensions, NPS withdrawals, compensation, sectoral subsidies, funds, local authorities, research/khadi bodies, securitisation and investor-protection structures) subject to conditions, certificates and prescribed rules. Key differences between the enacted Act and the original Bill include renumbered statutory hooks (e.g., NPS section), omission of a company-withholding clarifying clause, inconsistent cross-references and regulatory dates, and wording changes affecting delegation to subordinate rules. Practical effects: taxpayers must verify the authoritative enacted text, comply with documentary conditions, and monitor notifications/corrigenda to avoid denial of exclusions.

Schedule II narrows income exclusions; life insurance, section 127 receipts, provident fund interest and NPS rules changed
SCHEDULE II excludes specified income from "total income" but the enacted Act alters the originally introduced Bill on key points: life-insurance exemptions are conditioned by issue dates, premium-to-sum-assured ratios and aggregate premium ceilings (with a new IFSC carve-out benefiting IFSC-issued policies from 1-Apr-2025); certain section-127 receipts and keyman policies are expressly ineligible; provident fund interest attributable to large contributions on/after 1-Apr-2021 is disqualified above stated thresholds; the Act adds specific NPS/unified pension entries while the Bill's equalisation-levy exclusion is not carried forward consistently. Several exemptions defer computation and procedural detail to rules, creating transitional uncertainty.

Schedule to section 9(12) creates safe harbour for non-resident investment funds and managers meeting thresholds and safeguards
A Schedule to section 9(12) creates a safe harbour excluding certain non-resident investment funds and their managers from constituting a business connection in India if objective thresholds and structural safeguards are met: non-resident status, Indian resident participation limits (5% cap - Act counts direct holdings only, Bill counted direct and indirect), minimum unconnected membership, concentration and single-investor caps, corpus floor (INR 100 crore with start-up/wind-up relief), independent registered fund manager with prescribed remuneration and profit caps, and filing requirements. The Act broadens executive power to relax conditions for IFSC managers and updates cross-references to current SEBI regulations.

Repeal-and-savings clause preserves tax proceedings, elections, refunds, penalties, and carry-forwards for pre-April 1, 2026 tax years
The repeal-and-savings clause preserves continuity when the 1961 Income-tax Act is repealed: pending and future proceedings relating to tax years beginning before 1 April 2026, elections, refunds, recovery, penalties, carry-forwards of losses/credits/depreciation, notified schemes and searches/requisitions remain effective and are to be dealt with under the repealed Act or corresponding provisions of the new Act. Key differences between the introduced and enacted texts: the enacted version more clearly preserves proceedings initiated after commencement but concerning pre-cutoff years, ties search/requisition protection to the Act's commencement (not a fixed date), adds a rule translating references to tax year 2025, and alters the fallback provision for schemes, reducing transitional uncertainty.

Law creates rebuttable presumption that items found under sections 247, 248, 253 belong to possessor and electronic records are authentic
Where enumerated items are found in the course of a search under section 247 or survey under section 253 (or delivered to a requisitioning officer under section 248), the provision creates a rebuttable presumption that the items belong to the possessor, that book/document contents are true, handwriting/signatures are genuine, and stamped documents were duly executed; the enacted text expands the Bill by expressly including electronic information and computer systems and adds a specific presumption that an electronic exchange recorded on such systems occurred between the purported parties, thereby broadening evidentiary reach and increasing the initial burden to rebut.

Legislation tightens authorised representative rules: updates practitioner references, replaces "trust" with "registered non-profit", expands delegated rulemaking
The enacted section narrows and refines the Bill's rules on authorised representatives by adjusting legacy practitioner references (linking to the 1961 Act rather than the 1922 Act), replacing "trust or institution" with "registered non-profit organisation" in an accountant-exception, altering penalty cross-references that affect disqualification, and inserting "may be prescribed"/"prescribed income-tax authority," signaling greater delegated rulemaking and a designated authority for non-professional misconduct disqualifications; these changes chiefly affect which historical practitioners qualify, which non-profits are covered, which prior penalties bar representation, and the role of subordinate rules in defining eligibility and disqualification.

Section 511 requires country-by-country reporting, Indian entities to notify tax authority and file consolidated reports within 12 months
Section 511 imposes country-by-country reporting duties for international groups with constituent entities resident in India: Indian resident constituent entities must notify the tax authority if the group parent is non-resident; Indian parent or alternate reporting entities must file an annual consolidated report within 12 months of the reporting year; fallback filing applies where the parent jurisdiction neither files nor exchanges reports or has a systemic failure. The enacted text and the original Bill differ only in minor drafting and prescription phrasing, not in substance; key operational details (forms, deadlines, revenue threshold) remain delegated to subordinate rules and must be monitored for compliance.

Indian concerns must provide prescribed information when foreign entity shares derive substantial value from assets in India under section 9(10)(a)
An Indian concern must furnish prescribed information or documents to the designated income-tax authority when shares or interests in a foreign entity derive substantial value from assets located in India and are held, directly or indirectly, through that Indian concern; the enactment and bill differ mainly in a cross-reference (section 9(10)(a) versus 9(9)(a)) and minor drafting/ordering changes but both delegate timing, manner and scope to subordinate prescription. The provision is procedural, lacks stated exceptions or penalties in the text provided, and requires affected Indian concerns to retain records pending rulemaking.

Law shifts liaison office annual reporting deadline and details from statute to rules, raising compliance uncertainty and interim risk
A statutory annual reporting obligation requires any non-resident operating an RBI/FEMA-authorised liaison office in India to prepare and deliver to the Assessing Officer a statement of its activities for the tax year; the Bill originally prescribed filing "within sixty days from the end of such tax year," while the enacted Section delegates the filing deadline, form and particulars to subordinate legislation ("within such period as may be prescribed"). The enacted text thus shifts timing and detail to rules, increasing administrative flexibility but reducing statutory certainty and creating interim compliance risk until rules are notified.