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ITA 1961 → DTC 2025Penal Tax Rates

Section 115BBE Section 120

Tax on income referred to in section 68 or section 69 or section 69A or section 69B or section 69C or section 69D

RetainedCritical - Destroys the economics of tax evasion and black money hoarding.

Quick Answer

Section 115BBE of the Income Tax Act, 1961 (Tax on income referred to in section 68 or section 69 or section 69A or section 69B or section 69C or section 69D) corresponds to Section 120 of the Direct Tax Code 2025 (Income-tax Act, 2025), effective 1st April 2026. Status: Retained.

Old Law (ITA 1961)Ch: XII

Sec 115BBE

Provision Summary

Taxes unexplained cash credits, investments, and expenditures at a punitive flat rate of 60% (effectively 78% with surcharge and cess). No deductions or basic exemption limit allowed.

New Law (DTC 2025)Ch: XI

Sec 120

Provision Summary

Retained verbatim. The ultimate penal tax rate used by the investigation wing.

Key Changes & Highlights

  • Explicitly denies set-off of any loss against such unexplained income.

Related Sections

Frequently Asked Questions

What does Section 115BBE of the Income Tax Act 1961 deal with?

Section 115BBE (Tax on income referred to in section 68 or section 69 or section 69A or section 69B or section 69C or section 69D) Taxes unexplained cash credits, investments, and expenditures at a punitive flat rate of 60% (effectively 78% with surcharge and cess). No deductions or basic exemption limit allowed.

What is the new section number for Section 115BBE under the Direct Tax Code 2025?

Section 115BBE of the ITA 1961 maps to Section 120 of the Direct Tax Code 2025 (Income-tax Act, 2025), effective from 1st April 2026.

What is the status of Section 115BBE under the new tax code?

Section 115BBE is marked as "Retained" with status "Active". Impact: Critical - Destroys the economics of tax evasion and black money hoarding.

What are the key changes to Section 115BBE under DTC 2025?

Explicitly denies set-off of any loss against such unexplained income.

Disclaimer: This page is for educational and reference purposes only. Section mappings are based on publicly available drafts and circulars. Always consult a qualified Chartered Accountant before filing or making compliance decisions under the Direct Tax Code 2025.

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