Section 115BAA of the 1961 Act → Section 200 of the 2025 Act
The 22% option for domestic companies.
Quick answer
Section 115BAA of the Income-tax Act, 1961 corresponds to Section 200 of the Income-tax Act, 2025. Relationship: Revised. Correspondence verified against both Acts.
How it works
A domestic company can opt for a 22% rate without most deductions; an IFSC unit keeps the section 147 deduction even on this route.
Example
A GIFT IFSC fund management company opts in: eligible income stays fully deducted, and MAT no longer applies.
What you need to do
Fund manager company: decide before the return due date; the option cannot be withdrawn.
What changed?
- It uses the new Act’s term “tax year” in place of “previous year”.
- It opens with “Irrespective of anything…” in place of “Notwithstanding anything…”.
- Rates are stated as figures (for example 22%) rather than in words.
- Read the complete new provision, including its conditions, exceptions and related provisions, when applying it.
The two texts, side by side
1961 · Section 115BAA115BAA. (1) Notwithstanding anything contained in this Act but subject to the provisions of this Chapter, other than those mentioned under section 115BA and section 115BAB, the income-tax payable in respect of the total income of a person, being a domestic company, for any previous year relevant to the assessment year beginning on or after the 1st day of April, 2020, shall, at the option of such person, be computed at the rate of twenty-two per cent, if the conditions contained in sub-section (2) are satisfied: Provided that where the person fails to satisfy the conditions contained in sub-section (2) in any previous year, the option …
2025 · Section 200200. (1) Irrespective of anything contained in this Act but subject to the provisions of Parts A, B, E and this Part (other than sections 199 and 201) of this Chapter, the income-tax payable for a tax year shall be at the rate of 22%, at the option of a person being a domestic company, in respect of the total income of such person computed in the following manner:— (a) without any deduction under— (i) section 45(2) or 47(1)(b); or (ii) Chapter VIII other than provisions of section 146 or 148; or (iii) sections specified in section 205(1)(a) to (g); (b) without set off of any loss carried forward or depreciation from any earlier tax year, if …
Excerpts end with … where the provision continues. Last reviewed 24 October 2026.
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Meet the expert
CS Prashant Kumar
Company Secretary & Compliance Officer
Global Horizons Capital Advisors (IFSC) Private Limited — an IFSCA-licensed investment banker
Published in The Chartered Accountant (Jun 2025, Jan 2025, Mar 2024) and Chartered Secretary (Aug 2023)
Prashant Kumar is a seasoned Company Secretary and corporate governance strategist with more than 13 years of experience advising large corporates, promoter-led groups and global businesses on compliance, regulatory risk and board governance. In GIFT IFSC, the IFSCA regime is his day job rather than a research topic.