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TMI BlogAddresses the tax liability of individuals in respect of income that is included in the income of another person in Clause 100 of the Income Tax Bill, 2025 vs. Section 65 of the Income Tax Act, 1961X X X X Extracts X X X X X X X X Extracts X X X X ..... assets or membership in a firm, is attributed to another taxpayer. This clause is situated within a broader legislative framework that seeks to ensure comprehensive taxation of income and prevent tax avoidance through the strategic allocation of assets and incomes. The significance of Clause 100 lies in its potential impact on taxpayers who have financial interests in assets or firms that generate income attributed to others, thus affecting how they manage and report such interests. Objective and Purpose The primary objective of Clause 100 is to establish a clear legal framework for taxing income that, while generated by a person other than the assessee, is included in the assessee's total income. This provision is intended to prevent ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ns of Chapter XIX-D apply accordingly. Chapter XIX-D typically relates to the procedural aspects of tax recovery, suggesting that the mechanisms for enforcing tax liability under Clause 100 are consistent with existing procedures for recovering tax dues. The clause is crafted to override any contrary provisions in other laws, emphasizing its priority in determining tax liabilities related to income attribution. This ensures uniform application and prevents conflicts with other legal provisions that might otherwise exempt certain incomes from taxation. Practical Implications For taxpayers, Clause 100 has significant implications. Individuals with assets or firm memberships that generate income attributed to another must be prepared to meet ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 3. Procedural References:- Clause 100 references Chapter XIX-D for procedural aspects, whereas Section 65 refers to Chapter XVII-D. This difference may reflect updates in procedural frameworks between the two legislative instruments. 4. Override Provisions:- Both provisions override contrary laws, ensuring their primacy in determining tax liabilities related to income attribution. This underscores the importance of these provisions in the broader tax framework. 5. Legislative Evolution:- The transition from Section 65 to Clause 100 may reflect an evolution in legislative thinking, potentially incorporating lessons learned from the application of Section 65 over the years. This evolution could involve clarifications, updates to procedural ..... X X X X Extracts X X X X X X X X Extracts X X X X
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