Section 94B → Section 193
Limitation on interest deduction in certain cases (Thin Capitalisation)
Quick Answer
Section 94B of the Income Tax Act, 1961 (Limitation on interest deduction in certain cases (Thin Capitalisation)) corresponds to Section 193 of the Direct Tax Code 2025 (Income-tax Act, 2025), effective 1st April 2026. Status: Retained.
Sec 94B
Provision Summary
Restricts interest deduction to 30% of EBITDA for interest paid to associated enterprises (to prevent profit shifting via heavy debt).
Sec 193
Provision Summary
Retained. Protects the Indian tax base from highly leveraged foreign MNC subsidiaries.
Key Changes & Highlights
- Carry forward of disallowed interest for 8 years is maintained, but tracked securely via portal.
Frequently Asked Questions
What does Section 94B of the Income Tax Act 1961 deal with?
Section 94B (Limitation on interest deduction in certain cases (Thin Capitalisation)) Restricts interest deduction to 30% of EBITDA for interest paid to associated enterprises (to prevent profit shifting via heavy debt).
What is the new section number for Section 94B under the Direct Tax Code 2025?
Section 94B of the ITA 1961 maps to Section 193 of the Direct Tax Code 2025 (Income-tax Act, 2025), effective from 1st April 2026.
What is the status of Section 94B under the new tax code?
Section 94B is marked as "Retained" with status "Active". Impact: Critical - Forces MNCs to inject equity rather than just debt into their Indian operations.
What are the key changes to Section 94B under DTC 2025?
Carry forward of disallowed interest for 8 years is maintained, but tracked securely via portal.
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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