India's Biggest Tax Law Reform in 60 Years

Income Tax Act, 2025.
Everything that changed.

The Income Tax Act, 2025 replaces the 1961 Act from 1 April 2026. Every section number changes. The terminology changes. The structure changes. This guide tells you exactly what changed, why it matters, and what you need to do.

Effective 1 April 2026
Applies to Tax Year 2026-27 onwards
536 Sections · 23 Chapters
Last reviewed: June 2026
Overview

What is the Income Tax Act, 2025?

The Income Tax Act, 2025 is a comprehensive rewrite of India's primary direct tax law — replacing the Income Tax Act, 1961, which had been in force for over 64 years. It was passed by Parliament in 2025 and comes into force on 1 April 2026.

The 1961 Act had grown to over 800 sections, more than 1,200 provisos, and an accumulated body of amendments, explanations, and sub-clauses that made it one of the most complex pieces of legislation in India. The 2025 Act is a structural simplification — the same underlying tax law, but reorganised, reworded, and renumbered to be clearer, shorter, and easier to navigate.

Important for Notice Proceedings: The Income Tax Act, 2025 applies to Tax Year 2026-27 onwards (i.e., proceedings for income earned from 1 April 2026). All proceedings relating to periods up to 31 March 2026 — including notices, assessments, appeals, and penalties — continue to be governed by the Income Tax Act, 1961. Both Acts will operate in parallel during the transition period.

This means: if you receive a notice in April 2026 for your income during 2024-25, it will still cite sections of the 1961 Act. If you receive a notice for income earned after 1 April 2026, it will cite sections of the 2025 Act. Every notice guide on this platform shows both references.


Which Act Applies to You?

The Transition: Which Act Applies When?

The most important practical question is: when you receive a notice or are in proceedings, which Act applies? The answer depends on the period under dispute, not the date you received the notice.

61
Up to 31 March 2026
Income Tax Act, 1961 Applies
All notices, assessments, reassessments, appeals, and penalty proceedings relating to income earned during Assessment Year 2026-27 and earlier are governed by the Income Tax Act, 1961 — regardless of when the notice is issued or the proceeding takes place. The section numbers in such notices will be from the 1961 Act (e.g., Section 148, Section 143(2)).
25
From 1 April 2026 onwards
Income Tax Act, 2025 Applies
All new proceedings for Tax Year 2026-27 (income earned from 1 April 2026 to 31 March 2027) and subsequent years are governed by the Income Tax Act, 2025. Notices for this period will cite new section numbers (e.g., Section 280 instead of 148, Section 244 instead of 143(2)).
The Parallel Period (April 2026 onwards)
Both Acts Operating Simultaneously
For several years, both Acts will be in active use. A notice under Section 148A (1961 Act) for AY 2022-23 may be issued on the same day as a notice under Section 281 (2025 Act) for Tax Year 2026-27. Always check the period under dispute — and the section cited — to confirm which Act governs your proceedings.
Quick Check: Look at the Assessment Year or Tax Year mentioned in the notice. If it says "Assessment Year 2026-27" or earlier, the 1961 Act applies. If it says "Tax Year 2026-27" or later, the 2025 Act applies.

What Changed

4 Key Structural Changes

The Income Tax Act, 2025 makes no significant change to the substantive tax rates or the categories of income. What changes is the structure, language, and procedure — with four changes that matter most for taxpayers dealing with notices.

Single "Tax Year" replaces Previous Year & Assessment Year

The dual-year system — where income earned in one year was taxed in the next — is abolished. A single Tax Year from 1st April to 31st March now governs all filing, assessment, and notice timelines. Any notice for Tax Year 2026-27 onwards will reference a "Tax Year," not an "Assessment Year."

See: Tax Year concept →

536 clean sections — no provisos, no explanations

The 1961 Act had 800+ sections with 1,200+ provisos. The new Act has 536 sections with zero provisos — every exception is a sub-section or clause. All 112 definitions are consolidated in a single section. The legal basis for any notice is now easier to locate, verify, and challenge.

See: Structure of the new Act →

Faceless assessment elevated to a statutory right

What previously existed only as an administrative scheme is now codified directly in the Act under Section 275. All scrutiny notices, reassessment proceedings, and appeals will be conducted through the portal. The quality and precision of your written reply matters more than ever.

New: Section 275 — Faceless Assessment

Updated return window extended to 48 months

Under the 1961 Act, an updated return (ITR-U) could be filed within 24 months of the end of the relevant Assessment Year. The new Act extends this to 48 months from the end of the Tax Year — providing a longer structured path to voluntary compliance.

New Section 263(6) — Updated Return

Terminology Change

The New Tax Year Concept

This is the single most confusing change for most taxpayers — and the most important one to understand when reading a notice.

Concept Income Tax Act, 1961 Income Tax Act, 2025
Income earning period Previous Year (PY)
e.g., 1 Apr 2024 – 31 Mar 2025
Tax Year
e.g., Tax Year 2024-25
Assessment/tax period Assessment Year (AY)
e.g., AY 2025-26 (the year after PY)
Same Tax Year — no separate assessment year
Tax Year 2026-27 covers both earning and assessment
Return filing deadline 31 July of the Assessment Year
e.g., 31 July 2025 for AY 2025-26
31 July of the same Tax Year
e.g., 31 July 2026 for Tax Year 2026-27
Notice referencing the year "For Assessment Year 2025-26" "For Tax Year 2026-27"
Section reference Section 2(9) — Assessment Year
Section 3 — Previous Year
Section 2 — Tax Year (consolidated)
Single unified concept
Practical Impact: The underlying income and tax calculation remain unchanged. What changes is only the label used. If a notice for Tax Year 2026-27 arrives, it refers to income earned from 1 April 2026 to 31 March 2027 — the same period that would have been called "Previous Year 2026-27" and taxed in "Assessment Year 2027-28" under the old Act.

Architecture

Structure of the Income Tax Act, 2025

The 2025 Act is organised into 23 chapters and 536 sections, compared to the 1961 Act's approximately 820 sections. The key structural improvements are:

  • Zero provisos: All 1,200+ provisos of the 1961 Act have been eliminated. Every exception, condition, or qualification is now expressed as a numbered sub-section or clause — making the law easier to read and cite.
  • All 112 definitions in one place: Every defined term is consolidated in Section 2 of the new Act. Under the 1961 Act, definitions were scattered across multiple sections.
  • Tables and formulae: Wherever the 1961 Act described calculations in narrative paragraphs, the 2025 Act uses structured tables and formulae — significantly reducing ambiguity in tax computation.
  • Consistent cross-referencing: Each section clearly identifies related provisions, removing the need to trace amendments back through decades of Finance Acts.

Chapter Overview

Chapter I
Preliminary
Sec 1–2
Chapter II
Basis of Charge
Sec 3–17
Chapter III
Incomes Not Included in Total Income
Sec 18–115
Chapter IV
Computation of Income Under Each Head
Sec 116–191
Chapter V
Income of Other Persons Included in Total Income
Sec 192–197
Chapter VI
Aggregation, Set-Off & Carry Forward
Sec 198–210
Chapter VII
Deductions from Gross Total Income
Sec 117–145
Chapter VIII
Tax on Special Incomes / Alternative Regimes
Sec 193–202
Chapter IX
Tax Administration & Taxpayer Rights
Sec 238–242
Chapter X
Collection & Recovery
Sec 297–335
Chapter XI
Assessment Procedure
Sec 243–290
Chapter XII
Appeals & Revisions
Sec 347–379
Chapter XIII
Penalties
Sec 430–470
Chapter XIV
Prosecution & Offences
Sec 475–497
Chapter XV
Special Provisions (Trusts, NRIs, etc.)
Sec 500–526

Section 275 — New Statutory Right

Faceless Assessment — Now a Statutory Right

Under the 1961 Act, faceless assessment was an administrative scheme introduced through executive orders and notifications — it had no direct statutory backing in the Act itself. Section 144B, which provided the mechanism, was inserted later and operated through scheme documents.

The Income Tax Act, 2025 changes this fundamentally. Section 275 of the new Act gives faceless assessment direct statutory recognition — it is now a right of every taxpayer, not a scheme the government can modify or withdraw through notification.

What Does This Mean in Practice?

  • All scrutiny assessments under Section 244 (new Section 143(2) equivalent) must be conducted entirely through the Income Tax portal — no in-person hearings, no physical document submissions.
  • Reassessment proceedings under Sections 279–282 (equivalents of Sections 147–149) are also faceless — all notices, questionnaires, and replies through the portal.
  • Every word of your reply matters more than ever. Without the ability to appear in person, explain nuances verbally, or submit physical documents in real time, the quality, completeness, and legal precision of your written response determines the outcome.
  • Assessment units, verification units, technical units, and review units are all now statutory — their roles and responsibilities are defined directly in the Act.
Section Mapping Note: Section 144B of the Income Tax Act, 1961 (Faceless Assessment) corresponds to Section 275 of the Income Tax Act, 2025. Any reference to "faceless assessment" in proceedings from Tax Year 2026-27 will cite Section 275.

Section 240 — New Statutory Protection

Taxpayer's Charter — Now in the Act (Section 240)

The Taxpayer's Charter was introduced in August 2020 as a policy document by the Income Tax Department under the Transparent Taxation platform. It listed rights and obligations of taxpayers — but had no legal force. It could be ignored in proceedings without any statutory consequence.

The Income Tax Act, 2025 changes this. Section 240 gives the Taxpayer's Charter direct statutory recognition for the first time in Indian tax law. Violations of Charter rights now carry legal weight in proceedings and appeals.

Your Statutory Rights Under Section 240

  • Right to fair and respectful treatment: Tax officers must treat every taxpayer with dignity and without bias. Coercive or humiliating conduct during proceedings is now a statutory violation.
  • Right to a fair and impartial assessment: The Assessing Officer must consider all facts and submissions objectively. Confirmation bias — where an officer starts with a conclusion and works backwards — is prohibited.
  • Right to representation through an authorised representative: You can be represented by a Chartered Accountant, advocate, or other authorised representative in all proceedings. This right cannot be denied or restricted.
  • Right to complete confidentiality of information: Information you provide to the department is confidential and cannot be shared except as expressly permitted by the Act.
  • Right to file a complaint about officer misconduct: A formal mechanism to raise grievances against tax officers who violate Charter rights is now embedded in the Act.
How to Use This: If you believe an assessment was not fair or impartial — for example, if your submissions were not considered, or you were not given a meaningful opportunity to be heard — you can now cite Section 240 in your appeal. A violation of the Taxpayer's Charter is now a substantive legal ground, not just an administrative complaint.

Section 263(6) — Extended Window

Updated Return Window: Extended to 48 Months

The updated return (ITR-U) was introduced under Section 139(8A) of the 1961 Act in the Finance Act 2022. It allowed taxpayers to voluntarily disclose income missed in their original return — paying a higher rate of tax to avoid penalties and prosecution. Under the 1961 Act, this window was 24 months from the end of the relevant Assessment Year.

Under Section 263(6) of the Income Tax Act, 2025, this window is extended to 48 months from the end of the Tax Year. This significantly expands the opportunity for voluntary compliance.

Aspect1961 Act — Section 139(8A)2025 Act — Section 263(6)
Window to file24 months from end of AY48 months from end of Tax Year
Additional tax — Year 125% of (tax + interest)25% of (tax + interest)
Additional tax — Year 250% of (tax + interest)50% of (tax + interest)
Additional tax — Year 3Not available (window closes)60% of (tax + interest)
Additional tax — Year 4Not available70% of (tax + interest)
Bar on filingCannot file if search/survey conductedCannot file if search/survey conducted
Bar on filingCannot file if assessment completedCannot file if assessment completed
When to Consider This: If you have undisclosed income from prior years, or if you missed a deduction or made an error in your original return, the updated return provides a legally protected path to correct this — without the risk of prosecution. The cost increases each year (higher additional tax), but the window is now significantly wider. Consult a Chartered Accountant before filing.

What Changes for You

Impact on Notices & Proceedings

The most immediate practical impact of the 2025 Act for taxpayers receiving notices is the change in section numbers. Every notice from Tax Year 2026-27 onwards will cite new section numbers. Here are the key notice-related changes:

Type of Notice / Proceeding 1961 Act Section 2025 Act Section Change
Defective return139(9)263(9)Renumbered only
Preliminary inquiry / produce documents142(1)268(1)Renumbered only
Scrutiny notice143(2)270(8)Renumbered only
Assessment order after scrutiny143(3)270(10)Renumbered only
Best judgment assessment144271Renumbered only
Faceless assessment scheme144B275Now statutory right
Income escaping assessment147279Renumbered only
Reassessment notice148280Renumbered only
Show-cause before reassessment148A281Renumbered only
Call for information (third parties)133(6)256Renumbered only
Demand notice156319Renumbered only
Set-off of refund against demand245334Renumbered only
Appeal to CIT(A)246A349Renumbered only
Appeal to ITAT253356Renumbered only
Penalty — under-reporting270A439Renumbered; rates same
Taxpayer's Charter rightsNo statutory provision240NEW statutory right

Complete Section Mapping Table

Download or view the full cross-reference of all major sections from the Income Tax Act, 1961 to the Income Tax Act, 2025 — organised by category with notes on changes.


Common Questions

Frequently Asked Questions

Check the section number and the period under dispute. If the notice relates to Assessment Year 2026-27 or earlier (income earned before 31 March 2026), it will cite sections of the Income Tax Act, 1961 — even if the notice was issued after 1 April 2026. If it relates to Tax Year 2026-27 or later, it will cite the 2025 Act. The section numbers are the quickest indicator: a notice under Section 148A is the 1961 Act; under Section 281, it is the 2025 Act.
No. The Income Tax Act, 2025 is a structural rewrite, not a substantive change to tax rates or the basis of income computation. The tax slabs, deduction limits, capital gains rates, TDS rates, and the fundamental structure of income under five heads (salary, house property, business, capital gains, other sources) remain the same. Finance Acts will continue to modify rates and limits annually — the 2025 Act is the container, not the content of those changes.
The Income Tax Act, 2025 applies to Tax Year 2026-27 (income earned from 1 April 2026 to 31 March 2027) and all subsequent tax years. The return would be filed by 31 July 2027 using the forms prescribed under the new Act and the Income Tax Rules, 2026. All deductions, exemptions, and TDS provisions will be governed by the 2025 Act.
No. The reassessment provisions of the Income Tax Act, 2025 (Sections 279–282) apply only to Tax Year 2026-27 onwards. For reassessment of any period up to and including Assessment Year 2026-27, the provisions of the Income Tax Act, 1961 — specifically Sections 147, 148, 148A, and 149 — continue to apply. If you receive a notice under Section 148 of the 1961 Act after 1 April 2026, it is perfectly valid if the year under dispute is AY 2026-27 or earlier.
No. All pending proceedings — including appeals before CIT(A), ITAT, High Courts, and the Supreme Court — relating to periods governed by the Income Tax Act, 1961 continue to be decided under that Act. The transition to the 2025 Act does not disturb any ongoing proceedings for periods up to 31 March 2026. The appeals process, the powers of the appellate authorities, and the legal framework applicable to those appeals remain unchanged.
Yes, all deductions continue — they are renumbered but not changed in substance. Section 80C (deductions up to Rs 1.5 lakh for LIC, PPF, ELSS, home loan principal, etc.) is now Section 123. Section 80D (health insurance premium) is now Section 124. The deduction limits, eligible instruments, and conditions remain the same. The renumbering is purely structural.