India replaced its income tax statute on 1 April 2026, and both Acts are live
The Income-tax Act 2025 came into force on 1 April 2026, replacing an Act that had governed Indian income tax since 1961 and renumbering every section in it. It did not replace it cleanly, because it could not: FY 2025-26 returns are being filed now under the old Act, and assessments, appeals and updated returns for earlier years will run under it into the next decade. For the next several years every position, every section reference and every form number has to carry both a year label and an Act label. That is the practical reality this practice is built around.
- Written against primary sources, including the Board's own transition guidance, and reviewed by a qualified professional before publication. The section mapping table in guide 1 has been checked directly against the Income-tax Act, 2025 as amended by the Finance Act, 2026.
- Compliance, litigation and strategy are treated as one practice rather than three, because a position taken in a return decides what can be argued in an appeal three years later.
- Every rate, threshold, date and section number sits in a claims register with its source and the date checked.
Compliance, litigation and strategy, run as one practice
Compliance
Return preparation and filing, corporate tax computation and provisioning, advance tax, withholding compliance and quarterly statements, and compliance reviews and health checks. The unglamorous half, and the half that decides what the other two can do.
Litigation
Representation during assessments, responses to notices and departmental queries, appeals before the appellate authorities, assistance with disputes at every level, and liaison with the tax authorities. Most cases are won or lost at the assessment stage, not on appeal.
Strategy
Tax planning and advisory, business and transaction structuring, tax-efficient corporate restructuring, merger and acquisition advisory, and strategic tax risk management. Decisions taken here surface as compliance positions for years.
Three things we do differently
We label every position by year and by Act
With two statutes live simultaneously, an unlabelled section reference is not a shorthand, it is an error waiting to be relied on. Our advice, our workpapers and these pages all carry both labels, and we would rather look pedantic than be misread.
We check section numbers against the statute
A wrong section number is the most damaging kind of error on a tax page, and the renumbering has produced several that circulate widely. Section 366 is the composition of the High Court bench, not the Supreme Court provision. Section 207 is not alternate minimum tax. Section 115QA has no successor rather than a renumbered one. Our mapping table was checked row by row against the enacted Act and says which entries are consolidations rather than one-for-one pairs.
We do not carry forward last year's due dates
The prior year saw two separate extensions to filing deadlines. That is a reason to check, not a reason to assume. Every date on these pages was checked on the date stated, and where an extension could still arrive the page says as at which date it had not.
Four situations
You are filing for FY 2025-26 and planning for tax year 2026-27 at once
Which is every business, right now. The two require different vocabularies and the temptation to use the newer one for both is strong and wrong.
You have a notice
An assessment, a reassessment, a query or a demand. What matters most is the first response, and the window for it is usually shorter than it looks.
You are structuring something
A transaction, a reorganisation, a new holding structure or a cross-border flow. The anti-avoidance rule, the treaty position and the newly reversed buyback treatment all bear on it.
You have a cross-border position that depends on a treaty
Particularly if it depends on the Mauritius treaty, where a protocol signed in 2024 is still not in force and a great deal of published material assumes otherwise.
Five guides across the lifecycle
Guide 1 is the one to read first, because everything else in the set depends on knowing which Act governs which period. Guides 2 to 4 follow a tax position from filing through assessment to dispute. Guide 5 is the forward-looking one.
Two Acts, One Year: What the Income-tax Act 2025 Changes
What actually happened on 1 April 2026, the tax year concept that replaced two others, how the transition provisions allocate a period to an Act, and a section mapping table you can work from.
Compliance: Returns, Withholding and the New Form Numbers
Return due dates for the year being filed now, the updated return window, the 2025 withholding rationalisation that removed two compliance checks entirely, and the form renumbering that catches everyone.
Assessment, Reassessment and the Faceless Process
How an assessment reaches you, what the faceless process changed about responding to it, the reassessment time limits after they were cut, and the closed list of things that can now reopen a year.
Disputes: Appeals, Penalties and Where a Case Is Actually Won
The appellate hierarchy, the monetary limits that decide whether the department appeals at all, the small-case resolution route, the penalty provisions, and the prosecution offences that were softened in 2026.
Planning, Anti-avoidance and Cross-border Positions
Rates and concessional regimes, the general anti-avoidance rule and its grandfathering, treaty positions including the Mauritius protocol that is still not in force, the abolished equalisation levy, and where India actually stands on global minimum tax.
Where the neighbouring work sits
Tax audit
The audit itself sits with our assurance practice, on the audit and assurance pages, including the change of substance in the new Act that may widen who has to be audited at all.
Salary withholding
Employer withholding, the regime election and the renumbered salary forms sit on the payroll pages.
Structuring decisions a finance lead owns
Corporate rates, minimum alternate tax, buybacks and share options in a commercial rather than a compliance frame, on the Virtual CFO pages.
Send an enquiry
Tell us what is in front of you: a return, a notice, a transaction, or a position you want tested before you take it. If it is a notice, please include the date on it, because that usually determines how quickly we need to move.
This page is general information, not professional advice. India is operating two income tax statutes at once. The Income-tax Act 1961 governs FY 2025-26 and everything before it, including assessments, appeals and updated returns for those years, which will run into the 2030s. The Income-tax Act 2025 came into force on 1 April 2026 and governs tax year 2026-27 onward, with every section renumbered and every form renumbered with them. A statement about Indian income tax that carries neither a year label nor an Act label is not a statement anyone can act on. Take professional advice before acting on anything on this page. We are happy to be that adviser, but we do not act on a web page, ours or anyone else's, without one.