Statutory deduction for interest income derived from deposits : Clause 153 of the Income Tax Bill, 2025 Vs. Section 80TTA of the Income-tax Act, 1961

Clause 153 Deduction for interest on deposits.

Income Tax Bill, 2025

1. Introduction

Clause 153 of the Income Tax Bill, 2025, proposes a statutory deduction for interest income derived from deposits, specifically targeting individuals, senior citizens, and Hindu Undivided Families (HUFs). This provision is situated within the broader legislative context of providing relief to small savers and encouraging savings through formal financial channels. The clause is a successor, and in many respects a re-casting, of the existing Section 80TTA of the Income-tax Act, 1961, which currently governs deductions for interest earned on savings account deposits. Section 80TTA, introduced by the Finance Act of 2012 and effective from the assessment year 2013-14, was a significant measure to provide relief to individual and HUF taxpayers in respect of interest income from savings accounts, thereby fostering a culture of savings and financial inclusion. The subsequent introduction of Section 80TTB in 2018 created a higher threshold for senior citizens, reflecting evolving policy priorities. Clause 153, as proposed in the Income Tax Bill, 2025, seeks to consolidate, expand, and clarify the scope of such deductions, introducing notable changes in eligibility, quantum, and coverage. The comparative analysis of Clause 153 and Section 80TTA is essential for understanding the trajectory of legislative intent, the practical implications for taxpayers, and the potential areas of ambiguity or reform.

2. Objective and Purpose

Legislative Intent and Policy Considerations The primary objective behind Section 80TTA and its successor, Clause 153, is to incentivize small savings by providing a deduction for interest income earned by individuals and HUFs from savings accounts. The legislative history indicates a clear policy focus on:

• Encouraging the use of formal banking channels for savings.
• Providing tax relief to small depositors, particularly those with modest interest income.
• Ensuring that the deduction is not exploited by non-individual entities or through indirect means.
• Recognizing the unique requirements of senior citizens, as reflected in the higher deduction threshold.

Clause 153 further refines the legislative intent by explicitly incorporating senior citizens and extending the deduction to a higher amount for them, while also clarifying the treatment of time deposits and the eligibility of HUFs.

3. Detailed Analysis of Clause 153

3.1. Structure and Scope Clause 153 is structured as follows:

• Sub-section (1): Specifies eligible assessees (individuals, senior citizens, and HUFs) and the types of deposits/institutions eligible for the deduction.
• Sub-section (2): Prescribes the quantum of deduction based on the class of assessee and type of deposit.
• Sub-section (3): Excludes certain entities (firms, AOPs, BOIs) from availing the deduction indirectly.
• Sub-section (4): Defines "time deposits."

3.2. Eligible Assessees Clause 153(1) expands the scope of eligible assessees by explicitly mentioning:

• (a) Individuals, not being senior citizens;
• (b) Individuals, being senior citizens;
• (c) Hindu Undivided Families (HUFs).

This is a departure from Section 80TTA, which covers only individuals and HUFs, with senior citizens excluded by virtue of Section 80TTB. Clause 153 amalgamates the treatment of all individuals, including senior citizens, within a single provision, but with differential deduction limits.

3.3. Eligible Institutions and Deposits Clause 153(1) allows deductions for interest on deposits with:

• Banking companies governed by the Banking Regulation Act, 1949;
• Co-operative societies engaged in banking, including co-operative land mortgage/development banks;
• Post Offices as defined under the Post Office Act, 2023.

This is substantially similar to Section 80TTA, except for the update in the Post Office Act reference (from the 1898 Act to the 2023 Act), reflecting statutory modernization.

3.4. Quantum of Deduction Clause 153(2) prescribes the quantum as follows:

• (a) For non-senior individuals and HUFs: Deduction up to Rs. 10,000 on interest from savings account deposits, excluding time deposits.
• (b) For senior citizens: Deduction up to Rs. 50,000 on interest from savings account deposits, including time deposits.

This is a significant shift from Section 80TTA, which allows only up to Rs. 10,000 for all eligible individuals and HUFs (excluding senior citizens, who are covered u/s 80TTB with a Rs. 50,000 limit including time deposits). Clause 153 therefore consolidates and aligns the treatment of senior citizens within the same provision, while expanding the scope for them to include time deposits.

3.5. Exclusion of Indirect Deduction Clause 153(3) mirrors Section 80TTA(2) by denying the deduction in cases where the interest income is derived from a savings account held by or on behalf of a firm, association of persons (AOP), or body of individuals (BOI), preventing partners or members from claiming the deduction indirectly.

3.6. Definition of Time Deposits Clause 153(4) defines "time deposits" as deposits repayable on expiry of fixed periods, identical to the explanation in Section 80TTA.

4. Practical Implications

4.1. Impact on Taxpayers

• Non-Senior Individuals and HUFs: The deduction quantum and conditions remain largely unchanged from Section 80TTA. Interest up to Rs. 10,000 from savings accounts (excluding time deposits) is deductible, thus maintaining status quo for this class.
• Senior Citizens: The most significant impact is on senior citizens, who are now included within the same provision, with a higher deduction limit of Rs. 50,000, and crucially, on both savings and time deposits. This aligns with the policy u/s 80TTB but consolidates the law for ease of reference and application.
• HUFs: The position for HUFs remains the same, with eligibility for deduction up to Rs. 10,000 on interest from savings accounts (excluding time deposits).

4.2. Compliance and Procedural Aspects

• Taxpayers must identify the nature of deposit (savings vs. time deposit) and their status (senior citizen or not) to determine the applicable deduction.
• Interest on time deposits is only deductible for senior citizens; others must exclude such interest from the deduction computation.
• Interest income from joint accounts with firms, AOPs, or BOIs is specifically excluded, preventing misuse.
• The revised reference to the Post Office Act, 2023, may require taxpayers and institutions to update references in documentation and compliance systems.

4.3. Administrative and Regulatory Impact

• The consolidation of provisions for all individuals (including senior citizens) may simplify administration and reduce errors in claim processing.
• The explicit inclusion of time deposits for senior citizens may require additional reporting by banks and post offices to facilitate accurate deduction claims.

5. Comparative Analysis: Clause 153 vs. Section 80TTA

5.1. Eligibility

Aspect	Section 80TTA of the Income-tax Act, 1961	Clause 153 of the Income Tax Bill, 2025
Individuals (non-senior)	Eligible	Eligible
Senior Citizens	Not eligible (covered under 80TTB)	Eligible (higher limit)
HUFs	Eligible	Eligible
Firms/AOPs/BOIs	Not eligible, including indirect claims	Not eligible, including indirect claims

5.2. Quantum and Nature of Deduction

Aspect	Section 80TTA	Clause 153
Deduction Limit (non-senior individuals/HUFs)	Rs. 10,000 (savings accounts only, excluding time deposits)	Rs. 10,000 (savings accounts only, excluding time deposits)
Deduction Limit (senior citizens)	Not applicable (see 80TTB: Rs. 50,000, including time deposits)	Rs. 50,000 (savings and time deposits)
Time Deposits	Not eligible (for any assessee under 80TTA)	Eligible for senior citizens only

5.3. Eligible Institutions Both provisions allow interest from:

• Banking companies under the Banking Regulation Act, 1949
• Co-operative societies engaged in banking
• Post Offices (reference updated in Clause 153 to the 2023 Act)

5.4. Anti-Avoidance Provisions Both provisions deny deduction for interest earned by or on behalf of a firm, AOP, or BOI, ensuring that only individual or HUF savings are incentivized and preventing indirect claims through partnership or association structures.

5.5. Definitions The definition of "time deposits" is identical in both provisions, ensuring continuity in interpretation.

5.6. Legislative Consolidation and Clarity Clause 153 consolidates the provisions for all individuals, including senior citizens, within a single clause, whereas under the 1961 Act, senior citizens are covered separately u/s 80TTB. This consolidation may reduce confusion and streamline compliance.

6. Conclusion

Clause 153 of the Income Tax Bill, 2025, represents an evolutionary step in the legislative framework governing deductions for interest income from deposits. By consolidating and clarifying the provisions applicable to individuals, senior citizens, and HUFs, the clause seeks to simplify compliance, provide targeted relief, and prevent abuse through indirect claims. The inclusion of senior citizens within the same provision, with a higher deduction limit and coverage of time deposits, aligns with the broader policy objective of supporting the financial security of the elderly. The practical implications for taxpayers are largely positive, with the main compliance requirement being the accurate aggregation and reporting of eligible interest income. The revised reference to the Post Office Act and the consolidation of provisions may require minor administrative adjustments but are unlikely to pose significant challenges. Potential areas for further clarification include the definition of "senior citizen," the treatment of joint accounts, and the interaction with other deduction provisions. Judicial or administrative guidance may be required to address these nuances and ensure uniform application.

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Full Text:

Clause 153 Deduction for interest on deposits.

 

Dated: 21-4-2025