ClarificationHigh ImpactINCOME_TAX_ACT_1961
Official PDF (p. 4)INCOME_TAX_ACT_1961 · Section 94B / Thin Capitalisation
Section 94B Interest Limitation: Exclusion of Specified Financing Entities and Safe Harbour Norms
Applicable from 2026-06
Attempt Applicability
2026-06:Applies
2026-12:Applies
Statutory Comparison
Prior PositionPre-amendment
Interest deduction disallowance applied strictly to all cross-border associated enterprise loans exceeding ₹1 crore.
New PositionAmended
Clarified safe harbour exclusions for regulated finance and insurance entities operating under IFSC authority guidelines.
Affected Syllabus Chapters
direct-tax-laws-and-international-taxation
assessment-of-income-and-computation-of-tax-liability-of-various-entities
Code: assessment-of-income-and-computation-of-tax-liability-of-various-entities
Authority Document Reference
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