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This is only a renumbering — Section 115BBE of ITA 1961 is now Section 195 of ITA 2025. The legal position is unchanged. Existing judicial precedents continue to apply. No action required beyond updating section references in filings from AY 2026-27 onwards.
Section 115BBE: Income referred to in Sections 68, 69, 69A, 69B, 69C, 69D taxed at 60% (plus surcharge 25% and cess) — effective rate ~78.2%.
Section 195: Same 60% tax rate on unexplained income.
Renumbered from 115BBE to 195. Harsh rate of 60% unchanged.
Only renumbering; substantive law unchanged. Existing judicial precedents continue to apply.
This is only a renumbering — Section 195 of ITA 1961 is now Section 393(2), Sl. 17 of ITA 2025. The legal position is unchanged. Existing judicial precedents continue to apply. No action required beyond updating section references in filings from AY 2026-27 onwards.
Section 195: TDS on any sum (other than salary) paid to a non-resident — at rates in force. Payer must determine taxability.
Section 393(2), Table Sl. No. 17: TDS on payments to non-residents — catch-all provision within consolidated TDS.
Consolidated into Section 393(2), Table Sl. No. 17. No change in rates or obligation.
Only renumbering; substantive law unchanged. Existing judicial precedents continue to apply.