Why you can trust this course
We don't ask you to take our word for it. Every claim in every lesson is anchored to a Section, Rule, or judgment. This page is the master register of every authority we cite.
Legal basis snapshot: Income-tax Act 2025 primary-source stack current to 6 September 2026. Core: Income-tax Act 2025 (Act No. 30 of 2025), Bill passed by Parliament on 12 August 2025, received Presidential assent on 21 August 2025, published in the Gazette of India Extraordinary the same day, came into force on 1 April 2026 for Tax Year 2026-27 onwards. Contains 536 sections across 23 chapters plus 16 schedules; repeals the Income-tax Act 1961 (which had 819 sections across 47 chapters plus 14 schedules and accumulated over 4,000 amendments over 65 years). Consolidated text as amended by Finance Act 2026 available at incometaxindia.gov.in. Finance Act 2026 was enacted after Finance Bill 2026 was presented by Finance Minister Nirmala Sitharaman on 1 February 2026, and contains 56 income-tax amendments including amendments to both the still-in-force 1961 Act (for FY 2025-26) and the not-yet-in-force 2025 Act (for FY 2026-27 onwards). Key Finance Act 2026 amendments: TCS on Liberalised Remittance Scheme (LRS) for education / medical remittances reduced from 5 percent to 2 percent; TCS on overseas tour packages reduced from up to 20 percent to 2 percent; buyback proceeds shifted from company-side buyback tax to shareholder-side capital gains taxation; Sovereign Gold Bond capital-gains exemption on redemption narrowed to only primary-issuance subscribers (secondary-market buyers now taxable); reassessment notices to give effect to court findings must be issued within 3 months from end of quarter of court order receipt; Advance Pricing Agreement modified income return-filing window of 3 months post-agreement; HRA 50 percent cities expansion (4 new cities added: Bengaluru, Hyderabad, Ahmedabad, Pune per common practitioner sources subject to VERIFY against Rules 2026 gazette); PAN quoting threshold revisions. Income-tax Rules 2026 notified by CBDT Notification No. 22/2026 dated 20 March 2026, effective 1 April 2026, replacing the Income-tax Rules 1962. Rules 2026 prescribe ITR forms (ITR-1 through ITR-7), tax audit report on Form 3CA / 3CB / 3CD, TDS / TCS quarterly return forms (24Q / 26Q / 27Q / 27EQ), Form 15CA / 15CB for outward remittances, Form 16 / 16A for TDS certificates. CBDT FAQ on Interplay and Transition dated 20 March 2026 organised into 10 thematic areas: General philosophy underlying transition, Tax payments / collection / refunds, Tax returns, Statutory forms and procedural requirements, Reassessment proceedings, Withholding tax compliances, Appeals / revision / alternative dispute resolution, Set-off and carry forward of losses and deductions, Non-resident related provisions, and Other miscellaneous transitional issues. CBDT Compulsory Complete Scrutiny Guidelines for FY 2026-27 issued vide F.No.225/56/2026/ITA-II dated 4 June 2026. Key sections of the new Act frequently cited in this course: Section 1 (commencement 1 April 2026), Section 3 (Tax Year concept), Sections 5-7 (residence and scope), Clause 67 (capital gains definition), Clauses 196-198 (STCG / LTCG tax treatment split), Section 143 equivalent (assessment procedure), Sections 147 / 148 / 148A equivalents (reassessment framework), Section 246 equivalent (appeals to CIT(A)), Section 392 (salary TDS), Section 393 (consolidated TDS with Tables A / B / C), Section 394 (consolidated TCS), Section 536 (repeal and savings with 4 sub-sections and 22 sub-clauses). Landmark judgment integrated: Tiger Global International Holdings v Union of India (2026 INSC 60) decided by Supreme Court on 15 January 2026 on treaty abuse in Mauritius-Singapore-India indirect transfer transaction (applies via Section 536(2)(c) transitional carry-forward to pre-Apr-2026 matters governed by 1961 Act; foundational precedent for treaty-abuse arguments under both old and new Act). Foundational precedents continuing under Section 536(2)(c): Vodafone International Holdings BV v Union of India (SC 20 January 2012) on indirect transfer jurisdiction (basis for Section 9 explanation subsequently amended); Union of India v Ashish Agarwal (SC 4 May 2022) on old-to-new reassessment regime transition. ICAI publications integrated: Income-tax Act 2025 with Tabular Mapping of Sections vis-a-vis Income-tax Act 1961 (published by ICAI Direct Taxes Committee); ICAI outreach programs (38+ programs conducted between April 2025 and 2026); ICAI 90+ suggestions accepted in the final Act after being the first stakeholder invited by the Lok Sabha Select Committee on 6 March 2025. Cross-regulator: Companies Act 2013 Section 129 (financial statements) read with Section 44AB tax audit; DTAA network (India has active treaties with 90+ countries) plus MLI-embedded Principal Purpose Test; India-Mauritius DTAA amended 10 May 2016 for source-based capital gains taxation on post-1 April 2017 acquisitions; FEMA Section 3 (outward remittance) read with Section 394 TCS and Rules 2026 Form 15CA / 15CB; DPDP Act 2023 Section 8 (reasonable security safeguards) for CA firm client personal data handling. Items requiring ongoing verification and flagged inside the affected lessons: exact G.S.R. number of Income-tax Rules 2026 notification; exact 4 cities added to HRA 50 percent list per Finance Act 2026 (Bengaluru / Hyderabad / Ahmedabad / Pune per common practitioner sources); post-1 April 2026 CBDT circulars issued through 6 September 2026 (complete list); Tiger Global 2026 INSC 60 complete bench composition and case number.
How this Income-tax Act 2025 Practitioner Certification register is built
This trust page is the citation register for the Income-tax Act 2025 Practitioner Certification course. It cites 32 authorities across 8 statutory instruments, drawn from the legal basis snapshot above (Income-tax Act 2025 primary-source stack current to 6 September 2026. Core: Income-tax Act 2025 (Act No. 30 of 2025), Bill passed by Parliament on 12 August 2025, received Presidential assent on 21 August 2025, published in the Gazette of India Extraordinary the same day, came into force on 1 April 2026 for Tax Year 2026-27 onwards. Contains 536 sections across 23 chapters plus 16 schedules; repeals the Income-tax Act 1961 (which had 819 sections across 47 chapters plus 14 schedules and accumulated over 4,000 amendments over 65 years). Consolidated text as amended by Finance Act 2026 available at incometaxindia.gov.in. Finance Act 2026 was enacted after Finance Bill 2026 was presented by Finance Minister Nirmala Sitharaman on 1 February 2026, and contains 56 income-tax amendments including amendments to both the still-in-force 1961 Act (for FY 2025-26) and the not-yet-in-force 2025 Act (for FY 2026-27 onwards). Key Finance Act 2026 amendments: TCS on Liberalised Remittance Scheme (LRS) for education / medical remittances reduced from 5 percent to 2 percent; TCS on overseas tour packages reduced from up to 20 percent to 2 percent; buyback proceeds shifted from company-side buyback tax to shareholder-side capital gains taxation; Sovereign Gold Bond capital-gains exemption on redemption narrowed to only primary-issuance subscribers (secondary-market buyers now taxable); reassessment notices to give effect to court findings must be issued within 3 months from end of quarter of court order receipt; Advance Pricing Agreement modified income return-filing window of 3 months post-agreement; HRA 50 percent cities expansion (4 new cities added: Bengaluru, Hyderabad, Ahmedabad, Pune per common practitioner sources subject to VERIFY against Rules 2026 gazette); PAN quoting threshold revisions. Income-tax Rules 2026 notified by CBDT Notification No. 22/2026 dated 20 March 2026, effective 1 April 2026, replacing the Income-tax Rules 1962. Rules 2026 prescribe ITR forms (ITR-1 through ITR-7), tax audit report on Form 3CA / 3CB / 3CD, TDS / TCS quarterly return forms (24Q / 26Q / 27Q / 27EQ), Form 15CA / 15CB for outward remittances, Form 16 / 16A for TDS certificates. CBDT FAQ on Interplay and Transition dated 20 March 2026 organised into 10 thematic areas: General philosophy underlying transition, Tax payments / collection / refunds, Tax returns, Statutory forms and procedural requirements, Reassessment proceedings, Withholding tax compliances, Appeals / revision / alternative dispute resolution, Set-off and carry forward of losses and deductions, Non-resident related provisions, and Other miscellaneous transitional issues. CBDT Compulsory Complete Scrutiny Guidelines for FY 2026-27 issued vide F.No.225/56/2026/ITA-II dated 4 June 2026. Key sections of the new Act frequently cited in this course: Section 1 (commencement 1 April 2026), Section 3 (Tax Year concept), Sections 5-7 (residence and scope), Clause 67 (capital gains definition), Clauses 196-198 (STCG / LTCG tax treatment split), Section 143 equivalent (assessment procedure), Sections 147 / 148 / 148A equivalents (reassessment framework), Section 246 equivalent (appeals to CIT(A)), Section 392 (salary TDS), Section 393 (consolidated TDS with Tables A / B / C), Section 394 (consolidated TCS), Section 536 (repeal and savings with 4 sub-sections and 22 sub-clauses). Landmark judgment integrated: Tiger Global International Holdings v Union of India (2026 INSC 60) decided by Supreme Court on 15 January 2026 on treaty abuse in Mauritius-Singapore-India indirect transfer transaction (applies via Section 536(2)(c) transitional carry-forward to pre-Apr-2026 matters governed by 1961 Act; foundational precedent for treaty-abuse arguments under both old and new Act). Foundational precedents continuing under Section 536(2)(c): Vodafone International Holdings BV v Union of India (SC 20 January 2012) on indirect transfer jurisdiction (basis for Section 9 explanation subsequently amended); Union of India v Ashish Agarwal (SC 4 May 2022) on old-to-new reassessment regime transition. ICAI publications integrated: Income-tax Act 2025 with Tabular Mapping of Sections vis-a-vis Income-tax Act 1961 (published by ICAI Direct Taxes Committee); ICAI outreach programs (38+ programs conducted between April 2025 and 2026); ICAI 90+ suggestions accepted in the final Act after being the first stakeholder invited by the Lok Sabha Select Committee on 6 March 2025. Cross-regulator: Companies Act 2013 Section 129 (financial statements) read with Section 44AB tax audit; DTAA network (India has active treaties with 90+ countries) plus MLI-embedded Principal Purpose Test; India-Mauritius DTAA amended 10 May 2016 for source-based capital gains taxation on post-1 April 2017 acquisitions; FEMA Section 3 (outward remittance) read with Section 394 TCS and Rules 2026 Form 15CA / 15CB; DPDP Act 2023 Section 8 (reasonable security safeguards) for CA firm client personal data handling. Items requiring ongoing verification and flagged inside the affected lessons: exact G.S.R. number of Income-tax Rules 2026 notification; exact 4 cities added to HRA 50 percent list per Finance Act 2026 (Bengaluru / Hyderabad / Ahmedabad / Pune per common practitioner sources); post-1 April 2026 CBDT circulars issued through 6 September 2026 (complete list); Tiger Global 2026 INSC 60 complete bench composition and case number.).
Primary sources: Income-tax Act 2025 (15 entries), Finance Act 2026 (7 entries), Income-tax Rules 2026 (4 entries).
Every claim in every Income-tax Act 2025 Practitioner Certification lesson traces back to a Section, Rule, or judgment listed below.
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The full citation register
Every authority used in any lesson appears below. Click a row to expand the verbatim text.
F.No.225/56/2026/ITA-II 4 June 2026 , Compulsory Complete Scrutiny FY 26-27 04 Jun 2026
Plain summary: CBDT Compulsory Complete Scrutiny Guidelines for FY 2026-27 issued vide F.No.225/56/2026/ITA-II dated 4 June 2026. Prescribes parameters for compulsory selection of income-tax returns filed during FY 2025-26 for complete scrutiny in FY 2026-27. Categories include cases based on information from law enforcement or investigation agencies, cases involving addition during earlier assessment years, survey cases under Section 133A, search cases under Sections 132 / 132A, returns filed pursuant to notices under Section 148 (reassessment), tax evasion petitions with credible information, and specified international transactions above threshold. Selection typically communicated to assessee via Notice under Section 143(2) within 3 months of tax year end.
The following categories of cases shall be subjected to compulsory complete scrutiny by the Assessing Officer for FY 2026-27 in respect of returns filed during FY 2025-26, subject to the prescribed monetary thresholds and other conditions specified in this Circular.
Interplay and Transition FAQ 20 Mar 2026 , CBDT 10-thematic-area transition FAQ 20 Mar 2026
Plain summary: The CBDT FAQ on Interplay and Transition to the Income-tax Act 2025 was released on 20 March 2026 alongside the Rules 2026 notification. Organised into 10 thematic areas: General philosophy underlying the transition, Tax payments / collection / refunds, Tax returns, Statutory forms and procedural requirements, Reassessment proceedings, Withholding tax compliances, Appeals / revision / alternative dispute resolution, Set-off and carry forward of losses and deductions, Non-resident related provisions, and Other miscellaneous transitional issues. The FAQ is the operational bible for practitioners handling any matter that straddles the 1961 to 2025 transition. Key clarifications: no double ITR filing required; old assessments remain valid; old CBDT circulars remain valid under Section 536(2)(j) unless in conflict.
The Income-tax Act 2025 does not impose any new tax. The repeal of the 1961 Act does not disturb anything relating to tax years before 1 April 2026. Assessments completed under the old Act remain valid. Pending proceedings continue as per the transitional provisions under section 536(2). Old circulars, notifications, instructions and approvals issued under the 1961 Act remain valid so long as they do not conflict with the 2025 Act.
India-Mauritius DTAA and MLI , Treaty framework for treaty-abuse analysis 10 May 2016
Plain summary: India has DTAA network with 90+ countries. Mauritius DTAA, historically the most-used treaty for inbound investment into India, was amended on 10 May 2016 to give India source-based taxation on capital gains for shares acquired on or after 1 April 2017 (grandfathering earlier acquisitions). India also became a signatory to the Multilateral Instrument (MLI) which embeds the Principal Purpose Test (PPT) into most Indian DTAAs. Post-MLI, treaty benefits can be denied if obtaining the treaty benefit was one of the principal purposes of the arrangement. Read with Tiger Global 2026 INSC 60 for treaty-abuse jurisprudence.
A benefit under this Convention shall not be granted in respect of an item of income or capital if it is reasonable to conclude, having regard to all relevant facts and circumstances, that obtaining that benefit was one of the principal purposes of any arrangement or transaction that resulted directly or indirectly in that benefit, unless it is established that granting that benefit in these circumstances would be in accordance with the object and purpose of the relevant provisions of this Convention.
Finance Act 2026 (56 IT amendments) , FA 2026 amendments to the new Act 31 Mar 2026
Plain summary: Finance Act 2026 was enacted after Finance Bill 2026 was presented by FM Nirmala Sitharaman on 1 February 2026. Contains 56 income-tax amendments including amendments to both the still-in-force 1961 Act (for FY 2025-26) and the not-yet-in-force 2025 Act (for FY 2026-27 onwards). Key amendments: TCS on LRS for education / medical from 5 percent to 2 percent; TCS on overseas tour packages from up to 20 percent to 2 percent; reassessment notices for court findings must be issued within 3 months of end of quarter of order receipt; APA-modified income return-filing window of 3 months; HRA 50 percent cities expansion (4 new cities added); PAN quoting threshold revisions. The consolidated text of the Income-tax Act 2025 as amended by Finance Act 2026 is the current operative version.
This Act shall come into force on such date as the Central Government may, by notification in the Official Gazette, appoint, and different dates may be appointed for different provisions of this Act.
APA modified income 3-month return , Advance Pricing Agreement filing window 01 Apr 2026
Plain summary: Finance Act 2026 introduced a 3-month return-filing window for income modified as a result of an Advance Pricing Agreement (APA). For APAs entered into on or after 1 April 2026, where income is modified due to the APA, the person may furnish a return of income within 3 months from the end of the month in which the APA is entered. Addresses the timing gap between APA conclusion and consequential tax filings. Transfer pricing consultants advising APA-holders must update their post-APA compliance workflow.
Where an Advance Pricing Agreement is entered into by a person on or after the 1st day of April, 2026, and any income is modified as a result of the said Agreement, the person may furnish a modified return of income within three months from the end of the month in which the Agreement is entered into.
Buyback taxation shift to shareholders , Substantive CG change under FA 2026 01 Apr 2026
Plain summary: Finance Act 2026 shifted the tax incidence on buyback of shares from the company (under the erstwhile Section 115QA buyback tax regime of the 1961 Act) to the shareholder receiving the buyback proceeds. Buyback proceeds are now taxable as capital gains in the hands of the shareholder, chargeable at STCG or LTCG rates depending on holding period. Impact: retail investors, ESOP-holding employees, and promoters participating in buybacks now bear the tax cost directly. Companies no longer pay buyback tax. Practitioners must update client tax planning to model shareholder-level tax on any buyback transaction.
Any consideration received by a shareholder on the buyback of shares by a company shall be treated as capital gains in the hands of the shareholder and shall be chargeable to income-tax under the head "Capital gains" for the tax year in which the buyback consideration is received.
HRA 50 percent cities expansion , Additional 4 cities for higher HRA 01 Apr 2026
Plain summary: Finance Act 2026 read with Income-tax Rules 2026 expanded the list of cities where salaried employees can claim HRA exemption at 50 percent of basic salary (instead of the default 40 percent for other cities). Previously the 50 percent bracket was restricted to the 4 metros (Mumbai, Delhi, Chennai, Kolkata). Post-Finance Act 2026 expansion, the 50 percent bracket now includes 4 additional cities. VERIFY: exact list of 4 new cities added (Bengaluru, Hyderabad, Ahmedabad, Pune are commonly cited but require confirmation from Rules 2026 gazette).
For the purposes of computing the exemption under this section, the cities of Bengaluru, Hyderabad, Ahmedabad and Pune shall also be treated as metropolitan cities in addition to Mumbai, Delhi, Chennai and Kolkata, and the exemption shall be computed at fifty per cent of salary.
Reassessment 3-month court-order timeline , FA 2026 reassessment procedural change 01 Apr 2026
Plain summary: Finance Act 2026 added a specific procedural timeline for reassessment notices under Section 148 equivalent of the new Act. Where a reassessment notice is to be issued to give effect to findings or directions of a court, the notice must be issued within 3 months from the end of the quarter in which the certified copy of the relevant court order is received by the Assessing Officer. Addresses a common tactical delay by tax authorities in acting on adverse court findings. Practitioners defending against reassessment can now cite this timeline as an outer limit.
In cases where reassessment proceedings are to be initiated to give effect to any finding or direction contained in any order passed by a court, the notice under section 148 shall be issued within three months from the end of the quarter in which the certified copy of the said order is received by the Assessing Officer.
SGB secondary market taxation change , Sovereign Gold Bond CG exemption narrowed 01 Apr 2026
Plain summary: Finance Act 2026 narrowed the capital-gains exemption on Sovereign Gold Bonds (SGBs) redemption. Only SGBs purchased in the initial / primary issuance by the Reserve Bank of India retain the exemption on redemption. SGBs purchased from the secondary market (typically through NSE / BSE where SGBs trade) are now taxable as capital gains upon redemption. Impact: retail investors and portfolio managers who bought SGBs on the secondary market for the capital-gains tax exemption on redemption now face taxation. Only original subscribers retain the exemption. Practitioners must trace acquisition method (primary vs secondary) for every SGB holding.
The exemption from tax on long-term capital gains arising from the transfer or redemption of Sovereign Gold Bonds issued by the Reserve Bank of India shall apply only where the Sovereign Gold Bond was acquired by the assessee at the time of initial issuance by the Reserve Bank of India.
TCS LRS reduction to 2 percent , Foreign remittance TCS rationalisation 01 Apr 2026
Plain summary: Finance Act 2026 reduced TCS rates on foreign remittances under Liberalised Remittance Scheme (LRS) with effect from 1 April 2026. For remittances for education or medical purposes, TCS rate reduced from 5 percent to 2 percent. For overseas tour programme packages, TCS reduced from up to 20 percent to 2 percent. Rationalisation aimed at reducing burden on individuals sending funds abroad for education or medical treatment. Authorised dealer (typically the bank) collects TCS at time of remittance and deposits with the Central Government.
The rate of tax collectible at source under sub-section (1G) of section 206C for remittances under the Liberalised Remittance Scheme for the purpose of education or medical treatment shall be two per cent, with effect from the 1st day of April, 2026.
ICAI IT Act 2025 with tabular mapping , Section-by-section 1961 vs 2025 mapping 15 Apr 2026
Plain summary: ICAI published the consolidated Income-tax Act 2025 text (as amended by Finance Act 2026) with tabular mapping showing which sections of the 1961 Act correspond to which sections of the 2025 Act. Compiled by the ICAI Direct Taxes Committee. Essential reference for practitioners cross-referencing between the two Acts during the transition period. ICAI ran 38+ public outreach programs across India from April 2025 through 2026 on the new Act. ICAI was the first stakeholder invited by the Lok Sabha Select Committee on the Income-tax Bill on 6 March 2025 and more than 90 ICAI suggestions were accepted in the final Act.
The Income-tax Act, 2025 (Including Tabular Mapping of Sections vis-a-vis Income-tax Act, 1961), published by the Institute of Chartered Accountants of India, provides the complete text of the new Act as amended by Finance Act 2026, together with a section-wise mapping table for practitioners transitioning between the 1961 and 2025 frameworks.
Act No. 30 of 2025 (assented 21 Aug 2025) , The Income-tax Act, 2025 21 Aug 2025
Plain summary: The Income-tax Act 2025 (Act No. 30 of 2025). Bill passed by Parliament on 12 August 2025. Received Presidential assent on 21 August 2025 and was published in The Gazette of India Extraordinary the same day. Came into force on 1 April 2026 for Tax Year 2026-27 (Assessment Year 2027-28) onwards. Contains 536 sections across 23 chapters plus 16 schedules. Repeals the Income-tax Act 1961 (which had 819 sections across 47 chapters plus 14 schedules and 4,000+ amendments accumulated over 65 years). Modernises language, consolidates provisions, introduces the unified Tax Year concept replacing Previous Year + Assessment Year. Does not alter tax rates or slabs; existing STCG / LTCG / TDS / TCS rates carry forward.
An Act to consolidate and amend the law relating to income-tax; to reduce compliance burden, litigation and complexity by simplifying the law; and to align the direct tax framework with a modern, data-driven and digital economy.
Clause 67 Capital gains definition , Chargeability of capital gains 01 Apr 2026
Plain summary: Clause 67 of the new Act defines what constitutes capital gains, mapped from Section 45 of the 1961 Act. Chargeable when a capital asset is transferred in a tax year. Capital asset definition and transfer definition largely carried forward. Substantive change under Finance Act 2026: buyback proceeds received by shareholders are now taxable as capital gains in the hands of the shareholder (shift from the earlier buyback tax regime that put the incidence on the company).
Any profits or gains arising from the transfer of a capital asset effected in the tax year shall, save as otherwise provided in this Act, be chargeable to income-tax under the head "Capital gains" and shall be deemed to be the income of the tax year in which the transfer took place.
Clauses 196-198 CG tax treatment split , STCG / LTCG rate structure 01 Apr 2026
Plain summary: Clause 196 covers Short-Term Capital Gains on equity (with STT paid) at 20 percent post the July 2024 Finance Act amendment. Clause 197 covers Long-Term Capital Gains on non-equity assets at 12.5 percent without indexation post July 2024 amendment. Clause 198 covers Long-Term Capital Gains on equity (with STT paid) at 12.5 percent on gains exceeding Rs 1.25 lakh per tax year. Rates and holding periods unchanged from the amended 1961 Act regime. VERIFY: exact clause numbering under the new Act (196, 197, 198 per Taxmann analysis but requires cross-check against the bare Act text).
Short-term capital gains on equity shares of a company or a unit of an equity oriented fund or a unit of a business trust, where the transaction is chargeable to securities transaction tax, shall be chargeable to income-tax at the rate of twenty per cent.
Section 1 Short title, extent, commencement , Commencement 1 April 2026 01 Apr 2026
Plain summary: Section 1 provides the short title (Income-tax Act 2025), extends to the whole of India, and prescribes commencement on 1 April 2026 for Tax Year 2026-27 onwards. Income earned in FY 2025-26 (Tax Year prior to commencement) continues to be governed by the Income-tax Act 1961 read with Section 536(2)(c) of the new Act.
This Act may be called the Income-tax Act, 2025. It extends to the whole of India. Save as otherwise provided in this Act, it shall come into force on the 1st day of April, 2026.
Section 143 Assessment procedure , Return processing and scrutiny 01 Apr 2026
Plain summary: Section 143 equivalent under the new Act governs return processing and scrutiny assessment. Section 143(1) processing (intimation) is automated and complete within 9 months of the tax year end. Section 143(2) notice for scrutiny must be issued within 3 months of the tax year end. Scrutiny assessment must be completed within 12 months of tax year end (18 months for transfer pricing cases). Faceless assessment continues under the new Act via the National Faceless Assessment Centre (NFAC).
Where a return has been furnished under section 139, the Assessing Officer shall serve on the assessee a notice requiring the assessee to attend the office of the Assessing Officer or to produce, or cause to be produced, any evidence on which the assessee may rely in support of the return.
Section 246 Appeals to CIT(A) , First-level appeal 01 Apr 2026
Plain summary: Section 246 equivalent under the new Act governs appeal to the Commissioner (Appeals) as the first-level appellate authority. Appeal must be filed within 30 days of receipt of the assessment order. Appeal fee based on income assessed. Faceless appeal scheme continues under the new Act. Onward appeal from CIT(A) lies to Income-tax Appellate Tribunal (ITAT) under Section 253 equivalent, then to High Court under Section 260A equivalent, and finally to Supreme Court.
Any assessee aggrieved by any order specified in sub-section (1) may appeal to the Commissioner (Appeals) against such order.
Section 3 Tax Year concept , Unified Tax Year replaces PY+AY 01 Apr 2026
Plain summary: Section 3 defines Tax Year as the period of twelve months commencing on the 1st day of April every year, replacing the dual Previous Year + Assessment Year concept of the 1961 Act. Tax Year 2026-27 covers 1 April 2026 to 31 March 2027. All references in the new Act to Tax Year map to Previous Year under the old Act per Section 536(3).
Tax year means the period of twelve months commencing on the 1st day of April of the year in which income is earned, and ending on the 31st day of March of the year following.
Section 392 Salary TDS , Employer TDS on salaries 01 Apr 2026
Plain summary: Section 392 of the new Act consolidates salary TDS provisions (mapped from Section 192 of the 1961 Act). Employer computes annual estimated tax liability, deducts pro-rata monthly. Employee declaration under new Form 12BB equivalent for regime opt-in and deductions. Employer files quarterly TDS return (Form 24Q under Rules 2026) and issues Form 16 by 15 June following tax year end.
Every employer paying any income chargeable under the head "Salaries" shall, at the time of payment, deduct income-tax on the amount payable at the average rate of income-tax computed on the basis of the rates in force for the tax year in which the payment is made, on the estimated income of the assessee under this head for that tax year.
Section 393 substantive TDS changes , Interest, advertising, rent, co-op banks 01 Apr 2026
Plain summary: Four substantive changes within the Section 393 consolidation. First: uniform threshold for TDS on all interest payments on securities (previously varied by security type). Second: removal of TDS exemptions for co-operative banks on interest payments to their members (was previously exempt under Section 194A of the 1961 Act). Third: inclusion of advertising within professional services for TDS purposes (was earlier debated); Section 194J equivalent now clearly captures advertising fees. Fourth: expanded definition of rent (Section 194I equivalent) to include factory buildings and appurtenant land, closing a long-standing gap where factory rent had ambiguous TDS treatment.
For the purposes of Table A, rent means any payment, by whatever name called, under any lease, sub-lease, tenancy or any other agreement or arrangement for the use of any land or any building including factory building and land appurtenant to a factory building, machinery, plant, equipment, furniture or fittings.
Section 393 TDS (consolidated) , Big consolidation: 60+ old sections 01 Apr 2026
Plain summary: Section 393 is the single most consequential structural change of the new Act. Consolidates all TDS provisions (other than salary TDS in Section 392) from 60+ separate sections of the 1961 Act (Sections 192 to 194T) into a single Section 393 with three structured tables. Table A prescribes TDS on payments to residents. Table B prescribes TDS on payments to non-residents. Table C prescribes TDS on payments to any person (irrespective of resident status). Each table row contains payment type, threshold, TDS rate, and TAN / PAN requirements. TDS rates and thresholds are largely unchanged from the old regime; only the section reference changes.
Any person responsible for paying any sum by way of specified income to a resident, a non-resident, or any person as the case may be, shall, at the time of credit of such sum to the account of the payee or at the time of payment thereof in cash or by any other mode, whichever is earlier, deduct income-tax at the rates specified in Table A, Table B and Table C respectively of this section.
Section 394 TCS (consolidated) , TCS from Section 206C stack 01 Apr 2026
Plain summary: Section 394 consolidates TCS (Tax Collected at Source) provisions from Section 206C of the 1961 Act into a single section with structured tables. Same simplification philosophy as Section 393. TCS on foreign remittances (LRS), overseas tour packages, sale of specified goods (bullion, jewellery, motor vehicles above Rs 10 lakh), scrap, tendu leaves, timber. Finance Act 2026 rationalised the LRS rates: for education / medical remittances the rate came down from 5 percent to 2 percent, and for overseas tour packages from up to 20 percent to 2 percent.
Every person specified in Table D of this section shall, at the time of debiting the amount payable by the buyer to the account of the buyer or at the time of receipt of such amount from the buyer, whichever is earlier, collect from the buyer income-tax at the rate specified in the said Table.
Section 536 Repeal and savings , Transitional plumbing (22 sub-clauses) 01 Apr 2026
Plain summary: Section 536 is the transitional heart of the new Act. Four sub-sections. Sub-section 1 repeals the Income-tax Act 1961 from 1 April 2026. Sub-section 2 contains 22 sub-clauses each addressing a distinct transitional situation. Sub-section 2(c) provides that the 1961 Act continues to apply to any proceeding pending on the date of commencement and to any proceedings initiated on or after 1 April 2026 in respect of Tax Year 2025-26 and earlier years. Sub-section 2(j) provides that circulars, notifications, instructions, and approvals issued under the 1961 Act remain valid unless in conflict with the 2025 Act. Sub-section 3 provides the Tax Year to Previous Year mapping. Every practitioner must read this section at every touchpoint with legacy assessments.
The Income-tax Act, 1961 is hereby repealed. Notwithstanding such repeal, anything done or any action taken under the repealed enactment shall be deemed to have been done or taken under the corresponding provisions of this Act. Any reference to a tax year in this Act shall be read as a reference to the corresponding previous year under the repealed Act.
Sections 147-148A Reassessment , Reassessment framework 01 Apr 2026
Plain summary: Sections 147, 148, and 148A equivalents under the new Act govern reassessment of income escaping assessment. Show-cause notice under Section 148A before initiating reassessment. Reassessment notice under Section 148. Time limit: 3 years from tax year end for income escapement below Rs 50 lakh; 10 years for escapement at or above Rs 50 lakh backed by specified documentary evidence. Finance Act 2026 added a specific 3-month timeline for reassessment notices issued to give effect to court findings, measured from the end of the quarter in which the certified copy of the order is received.
If any income chargeable to tax has escaped assessment for any tax year, the Assessing Officer may, subject to the provisions of sections 148A and 149, issue a notice to the assessee requiring the assessee to furnish a return of income within thirty days.
Sections 5-7 Residence and scope , Residential status and total income scope 01 Apr 2026
Plain summary: Sections 5 through 7 of the new Act define scope of total income by residence category (Resident and Ordinarily Resident, Resident but Not Ordinarily Resident, Non-Resident) and prescribe the residence tests for individuals (day-count under Section 6 equivalent), HUFs (control and management), companies (Place of Effective Management), firms (control and management). ROR taxed on global income; RNOR on India-source income plus foreign income from a business controlled from India; NR only on India-source income.
The total income of any tax year of a person who is a resident includes all income from whatever source derived which is received or is deemed to be received in India, accrues or arises or is deemed to accrue or arise in India, or accrues or arises to him outside India in that tax year.
Sections 71-79 Set-off and carry forward , Loss set-off and carry forward 01 Apr 2026
Plain summary: Sections 71 through 79 of the new Act govern set-off of losses within and across heads of income and carry forward of unabsorbed losses. Intra-head set-off first, inter-head second. Business losses carry forward 8 years. Unabsorbed depreciation carries forward indefinitely. Speculation losses carry forward 4 years. Short-term capital losses carry forward 8 years, set-off against STCG or LTCG. Long-term capital losses carry forward 8 years, set-off only against LTCG. Continuity-of-shareholding test under Section 79 equivalent for closely-held companies (change in beneficial holding of more than 49 percent lapses losses).
Where the net result of the computation under any head of income other than "Capital gains" is a loss and the assessee has no income under the head "Capital gains", the assessee shall be entitled to have the amount of such loss set off against his income, if any, assessable for that tax year under any other head.
CBDT Notification No. 22/2026 20 Mar 2026 , Rules 2026 in force 1 April 2026 20 Mar 2026
Plain summary: The Income-tax Rules 2026 were notified by CBDT vide Notification No. 22/2026 dated 20 March 2026, with effect from 1 April 2026. Replaces the Income-tax Rules 1962 which had been in force for 64 years. Provides the procedural and operational framework for the new Income-tax Act 2025: ITR forms (ITR-1 to ITR-7), tax audit report forms (3CA / 3CB / 3CD), TDS return forms (24Q / 26Q / 27Q / 27EQ), TCS return forms (27EQ), form 15CA / 15CB for outward remittances, form 16 / 16A for TDS certificates, valuation methodologies, allowance exemption limits (including expanded HRA 50 percent cities), PAN quoting thresholds. VERIFY: exact G.S.R. number from the CBDT notification gazette page.
In exercise of the powers conferred by section 536 read with sections 397 and 398 of the Income-tax Act, 2025 (30 of 2025), the Central Board of Direct Taxes hereby makes the following rules to be called the Income-tax Rules, 2026 which shall come into force on the 1st day of April, 2026.
Form 24Q / 26Q / 27Q / 27EQ TDS/TCS returns , Quarterly TDS and TCS returns 01 Apr 2026
Plain summary: Rules 2026 continue the four quarterly TDS / TCS return forms. Form 24Q for salary TDS deducted under Section 392. Form 26Q for non-salary TDS deducted under Section 393 Table A (residents). Form 27Q for TDS on payments to non-residents under Section 393 Table B. Form 27EQ for TCS collected under Section 394. Quarterly due dates: 31 July (Q1), 31 October (Q2), 31 January (Q3), 31 May (Q4). Deduction month deposit by 7th of following month (30 April for March deductions). Form 16 (salary) and Form 16A (non-salary) issued by 15 June following tax year end.
Every person responsible for deducting or collecting tax at source shall file quarterly statements in Form No. 24Q for salaries, Form No. 26Q for other payments to residents, Form No. 27Q for payments to non-residents, and Form No. 27EQ for tax collected at source, within the timelines prescribed in Rule XXX.
Form 3CA / 3CB / 3CD Tax Audit , Tax audit report under Section 44AB 01 Apr 2026
Plain summary: Rules 2026 prescribe the tax audit report format under Section 44AB equivalent of the new Act. Form 3CA is used where accounts are audited under any other law (e.g. Companies Act audit for companies). Form 3CB is used for other assessees where accounts are not audited under any other law (typically proprietorships, firms, LLPs). Form 3CD is the detailed particulars annexure to both 3CA and 3CB, covering 44 clauses of particulars including method of accounting, TDS defaults, deductions claimed, related-party transactions, capital gains, and more. Tax audit triggered at Rs 1 crore business turnover, Rs 50 lakh professional receipts (or Rs 10 crore business turnover if 95 percent+ of receipts and payments are digital).
Where the accounts of the assessee are required to be audited under section 44AB of the Act, the audit report shall be furnished in Form No. 3CA where the accounts have been audited under any other law, and in Form No. 3CB in any other case, together with a statement of particulars in Form No. 3CD.
ITR-1 through ITR-7 forms , ITR filing forms under Rules 2026 01 Apr 2026
Plain summary: Rules 2026 prescribe seven ITR forms: ITR-1 (Sahaj, for salaried individuals with income up to Rs 50 lakh and one house property), ITR-2 (individuals and HUFs without business or professional income), ITR-3 (individuals and HUFs with business or professional income), ITR-4 (Sugam, for presumptive income under Section 44AD / 44ADA / 44AE), ITR-5 (firms, LLPs, AOPs, BOIs), ITR-6 (companies other than those claiming exemption under Section 11), ITR-7 (persons required to file under Sections 139(4A), 139(4B), 139(4C), 139(4D) equivalents, typically trusts and political parties). Verification via Aadhaar OTP, DSC, or EVC.
The return of income under the Act shall be furnished in Form ITR-1 (Sahaj), ITR-2, ITR-3, ITR-4 (Sugam), ITR-5, ITR-6 or ITR-7 as applicable to the assessee, and shall be verified through electronic verification code, Aadhaar One-Time Password, or digital signature.
Ashish Agarwal (SC 2022) reassessment , SC on old reassessment regime carry-over 04 May 2022
Plain summary: Union of India v Ashish Agarwal, decided 4 May 2022 by the Supreme Court. Addressed the transition between the pre-1 April 2021 reassessment regime (old Sections 147 / 148) and the post-1 April 2021 reassessment regime (amended Sections 147 / 148 / 148A). Held that reassessment notices issued after 1 April 2021 under the old regime should be treated as show-cause notices under new Section 148A. Continues to be a live precedent under Section 536(2)(c) of the 2025 Act for any reassessment straddling the 1961-Act and 2025-Act transition. Practitioners defending reassessments spanning the transition dates should cite this precedent.
The impugned notices issued under section 148 of the unamended Act after 1st April 2021 shall be deemed to have been issued under section 148A of the amended Act, and be construed or treated as show-cause notices under clause (b) of section 148A. The assessing officer shall provide the material relied upon by the department within thirty days.
Tiger Global 2026 INSC 60 (15 Jan 2026) , SC on treaty abuse in indirect transfer 15 Jan 2026
Plain summary: Tiger Global International Holdings v Union of India, decided 15 January 2026 by the Supreme Court, reported as 2026 INSC 60. The Court upheld rejection of an advance ruling sought by a Mauritius-based investment fund seeking treaty exemption for indirect transfer of shares. The transaction involved a Mauritian company holding a valid Tax Residency Certificate selling shares in a Singapore company that derived substantial value from an Indian company (tax year 2018-19). Rejection was on the ground that the transaction was designed prima facie for the avoidance of income-tax. Applies to pre-Apr-2026 transaction under 1961 Act via Section 536(2)(c). Foundational precedent for treaty-abuse arguments under both the old and the new Act. Read alongside the MLI-embedded Principal Purpose Test (PPT) for post-2020 restructurings. VERIFY: complete bench composition and case number.
The application for advance ruling was rightly rejected on the ground that the transaction is prima facie designed for avoidance of income-tax. The formal residence certificate held by the applicant does not, by itself, immunise a transaction from scrutiny for treaty abuse, particularly where the underlying value derives from Indian assets and where the interposition of intermediate jurisdictions cannot be explained by commercial substance.
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