TMI Short Notes

TMI Short Notes on various issues

1. Examination of provision of Disqualification from Tonnage Tax Scheme : Clause 231(12) of the Income Tax Bill, 2025 and Section 115VS of the Income-tax Act, 1961

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2. Examining Renewal Provisions for Tonnage Tax in Indian Shipping Taxation : Clause 231(10)-(11) of Income Tax Bill, 2025 Vs. Section 115VR of Income-tax Act, 1961

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3. Duration and Cessation of Tonnage Tax Option : Clause 231(8)-(9) of the Income Tax Bill, 2025 Vs. Section 115VQ of the Income-tax Act, 1961

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4. Procedural framework for opting into the tonnage tax scheme : Clause 231(1)-(7) of Income Tax Bill, 2025 Vs. Section 115VP of Income-tax Act, 1961

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5. Legal and Practical Implications of Excluding Tonnage Tax Profits from Book Profits in Indian Shipping Taxation : Clause 228(16) of the Income Tax Bill, 2025 Vs. Section 115VO of the Income-tax Act, 1961

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6. Capital Gains taxation on Qualifying Ships : Clause 229(8) to (10) of the Income Tax Bill, 2025 Vs. Section 115VN of the Income-tax Act, 1961

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7. Loss Set-Off and Apportionment in the Shipping Industry : Clause 230(2)-(4) of the Income Tax Bill, 2025 Vs. Section 115VM of the Income-tax Act, 1961

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8. Exclusion of Deductions and Loss Set-Off under the Tonnage Tax Regime : Clause 230(1) of the Income Tax Bill, 2025 Vs. Section 115VL of the Income-tax Act, 1961

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9. Depreciation and Asset Classification under Tonnage Tax : Clause 229(1)-(7) of the Income Tax Bill, 2025 Vs. Section 115VK of the Income-tax Act, 1961

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10. competitive taxation structure for shipping companies : Clause 228(14) and (15) of the Income Tax Bill, 2025 Vs. Section 115VJ of the Income-tax Act, 1961

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11. Simplified and concessionary method of taxation based on the net tonnage of qualifying ships, rather than on actual profits : Clause 228(1)-(13) of the Income Tax Bill, 2025 Vs. Section 115VI of the Income-tax Act, 1961

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12. computation of tonnage income where ships are jointly operated or where multiple companies are involved in the operation of a qualifying ship : Clause 227(7)-(8) of Income Tax Bill, 2025 Vs. Section 115VH of Income-tax Act, 1961

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13. Computation of Taxable income of the shipping companies based on Tonnage: Clause 227(1)-(6) of the Income Tax Bill, 2025 Vs. Section 115VG of the Income-tax Act, 1961

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14. Comprehensive Review of the Tonnage Tax Scheme : Clause 226(7) of the Income Tax Bill, 2025 Vs. Section 115VF of the Income-tax Act, 1961

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15. Presumptive Taxation for Shipping Companies : Clause 226(2)-(6) of the Income Tax Bill, 2025 and Section 115VE of the Income-tax Act, 1961

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16. Examination of "Qualifying Ship" : Clause 235(i) of the Income Tax Bill, 2025 Vs. Section 115VD of the Income-tax Act, 1961

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17. Defining the Qualifying Company under India's Tonnage Tax Regime : Clause 235(h) of the Income Tax Bill, 2025 Vs. Section 115VC of the Income Tax Act, 1961

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18. Continuity and Change in India's Tonnage Tax Regime : Clause 226(1) of the Income Tax Bill, 2025 Vs. Section 115VB of the Income-tax Act, 1961

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19. Navigating Special Tax Regimes for Shipping : Clause 225 of the Income Tax Bill, 2025 Vs. Section 115VA of the Income-tax Act, 1961

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20. Interpreting Special Provisions for Shipping Companies : Clause 235 of the Income Tax Bill, 2025 Vs. Section 115V of the Income-tax Act, 1961

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21. Special Tax Regimes for Investment Funds : Clause 224 of Income Tax Bill, 2025 Vs. Section 115UB of the Income-tax Act, 1961

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22. special taxation regime for business trusts such as (REITs)/(InvITs) Clause 223 of the Income Tax Bill, 2025 Vs. Section 115UA of the Income-tax Act, 1961

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23. Special Provisions Relating to Pass-Through Entities in Venture Capital Structures : Clause 222 of Income Tax Bill, 2025 Vs. Section 115U of Income Tax Act, 1961

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24. Enforcement and Recovery of Tax on Accreted Income : Clause 352(8) & (9) of the Income Tax Bill, 2025 Vs. Section 115TF of the Income-tax Act, 1961

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25. Changing Landscape of Interest on Delayed Payment of Tax on Accreted Income : Clause 352(7) of Income Tax Bill, 2025 Vs. Section 115TE of Income-tax Act, 1961

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26. Reforming the Exit Tax Regime for non-profit organizations (NPOs) or charitable institutions : Clause 352 of the Income Tax Bill, 2025 Vs. Section 115TD of the Income-tax Act, 1961

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27. Comprehensive Review of Taxation, Reporting, and Compliance for Securitisation Trusts : Clause 221 of the Income Tax Bill, 2025 Vs.Section 115TCA of the Income Tax Act, 1961

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28. Definitions, Scope, and Impact on the MAT/AMT Regime : Clause 206(19) of the Income Tax Bill, 2025 Vs. Section 115JF of the Income Tax Act, 1961

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29. Reducing tax avoidance by curbing the excessive use of deductions and exemptions by corporate and select non-corporate entities : Clause 206(18) of the Income Tax Bill, 2025 Vs. Section 115JEE of the Income-tax Act, 1961

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30. The Interplay of Special and General Provisions : Clause 206(12) of Income Tax Bill, 2025 Vs. Section 115JE of Income Tax Act, 1961

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31. Addresses the mechanism for granting tax credit for MAT/AMT paid in excess of regular tax liability by Other than Corporate : Clause 206(13)-(16) of the Income Tax Bill, 2025 Vs. Section 115JD of the Income-tax

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32. Addresses the mechanism for granting tax credit for MAT/AMT paid in excess of regular tax liability by Companies : Clause 206(13)-(16) of the Income Tax Bill, 2025 Vs. Section 115JAA of the Income-tax Act, 1961

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33. Harmonizing Minimum Tax Computation under India's Income Tax Laws : Clause 206(2)-(5) of the Income-tax Bill, 2025 Vs. Section 115JB and Section 115JC of the Income-tax Act, 1961

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34. imposition of Minimum Alternate Tax (MAT) and Alternate Minimum Tax (AMT) on various classes of taxpayers : Clause 206(1) of the Income Tax Bill, 2025 Vs. Section 115JA of the Income-tax Act, 1961

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35. Residency Reclassification and Tax Implications for Foreign Companies : Clause 220 of the Income Tax Bill, 2025 Vs. Section 115JH of the Income Tax Act, 1961

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36. Special provisions regarding conversion of an Indian branch of a foreign company, into a subsidiary Indian company : Clause 219 of the Income Tax Bill, 2025 Vs. Section 115JG of the Income-tax Act, 1961

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37. Special vs. General Tax Regimes for NRIs : Clause 218 of Income Tax Bill, 2025 Vs. Section 115I of Income-tax Act, 1961

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38. Concessional Tax Regime to non-resident Indians (NRIs) become residents of India : Clause 217 of the Income Tax Bill, 2025, Vs. Section 115H of the Income-tax Act, 1961

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39. Exemption from Income Tax Return Filing for Non-Resident Indians : Clause 216 of Income Tax Bill, 2025 Vs. Section 115G of Income-tax Act, 1961

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40. Taxation of Foreign Exchange Asset Transfers by NRIs : Clause 215 of the Income Tax Bill, 2025 Vs. Section 115F of the Income-tax Act, 1961

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41. Transitioning NRI Taxation : Clause 214 of Income Tax Bill, 2025 Vs. Section 115E of Income Tax Act, 1961

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42. Special provisions that govern the computation of total income for non-resident Indians (NRIs) : Clause 213 of Income Tax Bill, 2025 Vs. Section 115D of Income Tax Act, 1961

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43. Special taxation regime applicable to non-residents and foreign companies : Clause 212 of Income Tax Bill, 2025 Vs. Section 115C of Income-tax Act, 1961

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44. Reforming of Taxation of Specified Income of Non-Profit Organisations (NPOs) : Clause 337 of the Income Tax Bill, 2025 Vs. Section 115BBI of the Income-tax Act, 1961

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45. Evolution of the digital economy "Taxation of winnings from online games" : Clause 194 (S. No. 5) of Income Tax Bill, 2025 Vs. Section 115BBJ of Income-tax Act, 1961

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46. Development in the taxation of income arising from the transfer of virtual digital assets (VDAs) : Clause 194 (Table: S. No. 4) of Income Tax Bill, 2025 Vs. Section 115BBH of Income Tax Act, 1961

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47. Legal and Practical Perspectives on the Taxation of Carbon Credit Transfers : Clause 194 (Table: S. No. 3) of the Income Tax Bill, 2025 Vs. Section 115BBG of the Income-tax Act, 1961

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48. Concessional tax regime for Patent Royalty Income for resident patentees: Clause 194 (Table: S. No. 2) of Income Tax Bill, 2025 Vs. Section 115BBF of the Income-tax Act, 1961

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49. Taxation of Unexplained Incomes : Clause 195 of Income Tax Bill, 2025 Vs. Section 115BBE of Income-tax Act, 1961

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50. Comprehensive regime for the taxation of "specified income" of registered non-profit organisations (NPOs) : Clause 337 (Table: S. No. 1) of the Income Tax Bill, 2025 Vs. Section 115BBC of the Income Tax Act, 1961

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