Income Tax Act, 2025  ·  Chapter VIII — Deductions in Computing Total Income  ·  Section 147

Section 147
Deductions for income of Offshore Banking Units

IT Act 2025 Chapter VIII Effective 1 April 2026 Old: 80LA
New Provision
Section 147, IT Act 2025
Replaces (IT Act 1961)
80LA
Chapter
Chapter VIII — Deductions in Computing Total Income
Effective From
1 April 2026
Statutory Text — Section 147

(1) Where the following assessee has any income of the nature referred to in sub-section (3), there shall be allowed a deduction equal to 100% of such income:— (a) a scheduled bank, or a bank incorporated under the laws of a country outside India, and having an Offshore Banking Unit in a Special Economic Zone; or (b) a unit of an International Financial Services Centre. (2) The deduction shall be allowed–– (a) for ten consecutive tax years beginning from the relevant tax year in the case of an entity mentioned in sub-section (1)(a); (b) for ten consecutive tax years out of fifteen years beginning from the relevant tax year, at the option of an assessee, in the case of an entity mentioned in sub-section (1)(b). (3) The income referred to in sub-section (1) shall be the income from— (a) an Offshore Banking Unit located in a Special Economic Zone; or (b) the business activities referred to in section 6(1) of the Banking Regulation Act, 1949, with undertakings in a Special Economic Zone or entities that develop, develop and operate, or develop, operate and maintain Special Economic Zone; or (c) the approved business activities of any Unit of an International Financial Services Centre set up in a Special Economic Zone; or (d) transfer of an asset being, an aircraft or a ship, leased by a unit referred to in clause (c) if such unit commenced its business operations by 31st March, 2030. (4) The deduction under this section shall be allowed only if the assessee submits along with the return of income–– (a) a report in the form as may be prescribed, from an accountant certifying the correctness of claim of deduction; and (b) a copy of the–– (i) permission obtained under section 23(1)(a) of the Banking Regulation Act, 1949; or (ii) permission or registration obtained under the International Financial Services Centres Authority Act, 2019.

(5) For the purposes of this section,— (a) “relevant tax year” shall be,— (i) in case of an entity mentioned in sub-section (1)(a), the tax year in which permission under section 23(1)(a) of the Banking Regulation Act, 1949, or permission or registration under the Securities and Exchange Board of India Act, 1992 or any other relevant law was obtained; or (ii) in case of an entity mentioned in sub-section (1)(b), the tax year in which permission under section 23(1)(a) of the Banking Regulation Act, 1949, or permission or registration under the Securities and Exchange Board of India Act, 1992, or permission or registration under the International Financial Services Centre Authority Act, 2019 was obtained; (b) “Unit” shall have the same meaning as assigned to it in section 2(zc) of the Special Economic Zones Act, 2005; (c) “aircraft” and “ship” shall have the meanings respectively assigned to them in Schedule VI (Note 3).

Shahi & Co. — Our Understanding
This section falls under Chapter VIII which provides deductions from gross total income — these reduce your taxable income and directly lower your tax liability.
Practical Note: Unlike exemptions (Chapter III), deductions require active claiming in the ITR. Ensure proper documentation — payment proofs, investment certificates, employer certificates — is maintained for every deduction claimed.
Shahi & Co., Chartered Accountants
Need guidance on Section 147?
Our Direct Tax team advises individuals, businesses, and start-ups on all provisions of the Income Tax Act, 2025. We help you navigate the transition from the old Act with zero disruption to your compliance calendar.
Consult Our Tax Team →
← Previous
Section 146: Deduction in respect of additional employee c
Next →
Section 148: Deduction in respect of certain inter-corpora
← Full IT Act 2025 Index ESOP Taxation Guide TDS under IT Act 2025 NRI Residency Rules
Disclaimer: This is a reproduction of Section 147 of the Income Tax Act, 2025 (No. 30 of 2025) as published in the Official Gazette of India (CG-DL-E-22082025-265620) for informational and reference purposes only. Shahi & Co., Chartered Accountants makes no warranty as to completeness or accuracy. For the official authenticated text refer to egazette.gov.in or incometaxindia.gov.in. This does not constitute legal or tax advice.