Quick Answer
16 min read|Updated: Apr 1, 2026|Income-tax
Featured Answer: The Income Tax Act 2025 renumbers all sections as part of its comprehensive restructuring. This article provides a chapter-wise mapping of the most commonly referenced provisions of the 1961 Act to their equivalents in the 2025 Act.
10. Set-off & Carry Forward (Sections 70-80)
| 1961 Act Section | 2025 Act Equivalent | Notes |
|---|---|---|
| Section 70 (Intra-head set-off) | Set-off chapter | Loss from one source set off against income from another source under same head |
| Section 71 (Inter-head set-off) | Set-off chapter | Loss under one head set off against income under another head; restrictions retained |
| Section 72 (Business loss carry forward) | Carry forward chapter | 8-year carry forward for business losses retained |
| Section 73 (Speculative business loss) | Carry forward chapter | 4-year carry forward; set-off only against speculative income |
| Section 74 (Capital loss carry forward) | Carry forward chapter | 8-year carry forward; LTCL only against LTCG |
| Section 79 (Change in shareholding) | Carry forward chapter | Loss carry forward restricted on >51% change in shareholding for closely held companies |
For details on set-off and carry forward rules, see our Set-off & Carry Forward Guide.
11. TDS (Sections 192-206)
| 1961 Act Section | 2025 Act Equivalent | Notes |
|---|---|---|
| Section 192 (Salary TDS) | TDS chapter — salary | TDS on salary at average rate; new regime default; employer must apply opted regime |
| Section 194A (Interest other than securities) | TDS chapter — interest | Rate rationalised; threshold for senior citizens retained at Rs 50,000 |
| Section 194C (Contracts) | TDS chapter — contracts | Rate rationalised to 2%; individual/HUF 1% may be consolidated |
| Section 194H (Commission/brokerage) | TDS chapter — commission | Rate rationalised to 2% (from 5%) |
| Section 194I (Rent) | TDS chapter — rent | Rate rationalised to 2% (from 2%/10% split for plant vs land/building) |
| Section 194IA (Immovable property) | TDS chapter — immovable property | 1% TDS on property transactions > Rs 50 lakh retained |
| Section 194J (Professional/technical fees) | TDS chapter — professional fees | Unified single rate; dual 2%/10% structure eliminated |
| Section 194Q (Purchase of goods) | TDS chapter — purchase of goods | 0.1% TDS on purchase > Rs 50 lakh retained |
| Section 194S (VDA/crypto TDS) | TDS chapter — VDA | 1% TDS on virtual digital asset transfers retained |
| Section 195 (Non-resident payments) | TDS chapter — non-resident | TDS on payments to NR at rates in force; DTAA relief provisions retained |
| Section 206AB (Higher rate for non-filers) | TDS chapter — higher rate | Higher TDS for non-filers (5% or 2x rate) retained in simplified form |
For the complete TDS rate chart, see our TDS Rate Chart 2026-27.
12. TCS (Section 206C)
| 1961 Act Section | 2025 Act Equivalent | Notes |
|---|---|---|
| Section 206C (TCS — various) | TCS chapter | TCS on foreign remittance (LRS), sale of goods > Rs 50L, motor vehicles, etc. retained |
| Section 206C(1G) (LRS/overseas tour) | TCS chapter — foreign remittance | TCS rates on LRS: 5% (general > Rs 7L) / 20% (non-specified purpose) retained |
13. Advance Tax & Interest (Sections 207-234C)
| 1961 Act Section | 2025 Act Equivalent | Notes |
|---|---|---|
| Section 207/208 (Advance tax liability) | Advance tax chapter | Rs 10,000 threshold; exemption for senior citizens without PGBP income |
| Section 211 (Instalment schedule) | Advance tax chapter | 15%/45%/75%/100% by Jun/Sep/Dec/Mar retained |
| Section 234A (Interest — late filing) | Interest/penalty chapter | 1% per month on unpaid tax from due date to filing date |
| Section 234B (Interest — advance tax shortfall) | Interest/penalty chapter | 1% per month if advance tax paid < 90% of assessed tax |
| Section 234C (Interest — deferment) | Interest/penalty chapter | 1% per month for shortfall in quarterly advance tax instalments |
14. Returns of Income (Sections 139-140)
| 1961 Act Section | 2025 Act Equivalent | Notes |
|---|---|---|
| Section 139(1) (Return filing) | Returns chapter — mandatory filing | Due dates: 31 July (non-audit) / 31 October (audit) / 30 November (TP) retained |
| Section 139(4) (Belated return) | Returns chapter — belated | 31 December of AY deadline retained |
| Section 139(5) (Revised return) | Returns chapter — revised | Revision before 31 December of AY retained |
| Section 139(8A) (Updated return) | Returns chapter — updated | Permanent feature: 24-month window with 25%/50% additional tax |
| Section 140 (Verification) | Returns chapter — verification | Who may sign/verify the return; provisions retained |
15. Assessment (Sections 143-158)
| 1961 Act Section | 2025 Act Equivalent | Notes |
|---|---|---|
| Section 143(1) (Intimation) | Assessment chapter — processing | CPC processing with adjustments; substantially retained |
| Section 143(2) (Notice for scrutiny) | Assessment chapter — scrutiny notice | Notice for scrutiny assessment; faceless as default |
| Section 143(3) (Scrutiny assessment) | Assessment chapter — scrutiny | Regular assessment after examination; faceless by default |
| Section 144 (Best judgment) | Assessment chapter — best judgment | Assessment on best judgment for non-compliance |
| Section 144B (Faceless assessment) | Assessment chapter — default procedure | Faceless is now default; no separate scheme required |
| Section 147/148 (Reassessment) | Assessment chapter — reopening | Time limits tightened: 3 years general, 10 years for significant concealment |
| Section 153A/153C (Search assessment) | Assessment chapter — search | Block assessment for search cases retained with clearer timelines |
| Section 154 (Rectification) | Assessment chapter — rectification | Rectification of mistakes apparent from record; 4-year limit retained |
For detailed assessment procedures, see our Assessment Types Guide.
16. Appeals & Revision (Sections 246A-264)
| 1961 Act Section | 2025 Act Equivalent | Notes |
|---|---|---|
| Section 246A (Appeal to CIT(A)) | Appeals chapter — first appeal | Appeal to CIT(Appeals) / JCIT(Appeals); faceless appeal mechanism retained |
| Section 253 (Appeal to ITAT) | Appeals chapter — ITAT | Appeal to Income Tax Appellate Tribunal retained |
| Section 260A (Appeal to High Court) | Appeals chapter — High Court | Appeal on substantial question of law to HC retained |
| Section 263 (Revision by PCIT/CIT) | Revision chapter | Revision of orders erroneous and prejudicial to revenue; retained |
| Section 264 (Revision on taxpayer application) | Revision chapter | Application for revision by taxpayer; retained |
17. Penalties & Prosecution (Sections 234A-276C)
| 1961 Act Section | 2025 Act Equivalent | Notes |
|---|---|---|
| Section 234F (Late filing fee) | Penalty chapter | Rs 5,000 (Rs 1,000 if income < Rs 5L) late filing fee retained |
| Section 270A (Under-reporting/misreporting) | Penalty chapter — graduated structure | Merged into consolidated penalty framework; 50%/200% structure replaced with graduated approach |
| Section 271(1)(c) (Concealment — legacy) | Penalty chapter — graduated structure | Consolidated with 270A into unified penalty provisions |
| Section 271B (Tax audit penalty) | Penalty chapter | Penalty for failure to get accounts audited; merged into consolidated structure |
| Section 271C (TDS failure penalty) | Penalty chapter | Penalty for failure to deduct/collect/pay TDS/TCS; consolidated |
| Section 276C (Prosecution — wilful evasion) | Prosecution chapter | Criminal prosecution for wilful tax evasion; retained with refinements |
18. Special Tax Rates
| 1961 Act Section | 2025 Act Equivalent | Notes |
|---|---|---|
| Section 115BAA (Corporate 22%) | Special rates chapter | 22% + surcharge + cess for domestic companies; no MAT applicability |
| Section 115BAB (Manufacturing 15%) | Special rates chapter | 15% for new manufacturing companies incorporated and commencing by specified date |
| Section 115BAC (New regime — individuals) | Default slab rate schedule | Now the default regime; not a separate “optional” section |
| Section 115BBH (VDA/crypto — 30%) | Special rates chapter | 30% flat tax on VDA income; no deduction except cost of acquisition; no loss set-off |
| Section 87A (Rebate) | Rebate provision | Enhanced rebate — nil tax up to Rs 12 lakh total income under new regime |
| Section 115JB (MAT) | MAT chapter | Minimum Alternate Tax on book profit; 15% rate retained for applicable companies |
| Section 115JC (AMT) | AMT chapter | Alternate Minimum Tax for non-corporate assessees; retained |
For corporate tax rates, see our Corporate Tax Rates Guide.
19. Other Key Provisions
| 1961 Act Section | 2025 Act Equivalent | Notes |
|---|---|---|
| Chapter X-A (GAAR) | GAAR chapter | General Anti-Avoidance Rules; impermissible avoidance arrangement; retained |
| Chapter X (Transfer pricing — 92-92F) | Transfer pricing chapter | Arm’s length price, APA, safe harbour rules substantially retained |
| Section 269SS/269T (Cash loan restrictions) | Anti-cash provisions | Rs 20,000 cash loan/deposit restrictions; Rs 2 lakh cash transaction limit; retained |
| Section 245D-245R (Settlement Commission) | Transitional / not continued | Settlement Commission was already wound up; replaced by interim board |
20. Quick Reference — 30 Most Searched Sections
| # | 1961 Act Section | Description | 2025 Act Status |
|---|---|---|---|
| 1 | Section 10 | Exemptions from total income | Reorganised into exempt income chapter |
| 2 | Section 24 | Deduction for housing loan interest | Retained in HP chapter |
| 3 | Section 32 | Depreciation on assets | Retained with possible rate changes |
| 4 | Section 43B | Payment basis deductions (statutory dues, MSME) | Retained in PGBP chapter |
| 5 | Section 44AB | Tax audit requirement | Retained in PGBP chapter |
| 6 | Section 44AD | Presumptive taxation — business | Retained with same thresholds |
| 7 | Section 54 | CG exemption on reinvestment in house | Retained in CG chapter |
| 8 | Section 56(2)(viib) | Angel tax on share premium | ABOLISHED — not carried forward |
| 9 | Section 80C | Deduction for investments (Rs 1.5L) | Retained — old regime only |
| 10 | Section 80D | Health insurance premium deduction | Retained — old regime only |
| 11 | Section 87A | Rebate for resident individuals | Enhanced — nil tax up to Rs 12L |
| 12 | Section 112A | LTCG on listed equity (12.5%) | Merged into uniform 12.5% LTCG rate |
| 13 | Section 115BAA | Concessional corporate tax 22% | Retained under new section number |
| 14 | Section 115BAC | New tax regime for individuals | Now the default slab schedule |
| 15 | Section 115BBH | Crypto/VDA income at 30% | Retained under new section number |
| 16 | Section 115JB | MAT on book profit | Retained in MAT chapter |
| 17 | Section 139(1) | Mandatory return filing | Retained in returns chapter |
| 18 | Section 139(8A) | Updated return | Permanent feature in 2025 Act |
| 19 | Section 143(3) | Scrutiny assessment | Faceless by default under 2025 Act |
| 20 | Section 147/148 | Reassessment / reopening | Tightened limits: 3yr / 10yr |
| 21 | Section 192 | TDS on salary | Retained; new regime default for TDS |
| 22 | Section 194C | TDS on contractor payments | Rate rationalised to 2% |
| 23 | Section 194J | TDS on professional/technical fees | Unified single rate |
| 24 | Section 195 | TDS on NR payments | Retained in TDS chapter |
| 25 | Section 234B | Interest for advance tax shortfall | Retained in interest chapter |
| 26 | Section 234F | Late filing fee (Rs 5,000) | Retained in penalty chapter |
| 27 | Section 246A | Appeal to CIT(A) | Retained in appeals chapter |
| 28 | Section 263 | Revision by PCIT | Retained in revision chapter |
| 29 | Section 270A | Penalty for under/misreporting | Consolidated into graduated penalty |
| 30 | Section 206AB | Higher TDS for non-filers | Retained in simplified form |
21. Sections Deleted / Not Carried Forward
| 1961 Act Section | Description | Reason for Deletion |
|---|---|---|
| Section 56(2)(viib) | Angel tax on share premium | Policy decision to promote startup funding; provision was impediment to capital formation |
| Section 10(38) | LTCG on listed equity exemption | Already omitted from AY 2019-20; replaced by Section 112A taxation |
| Various Section 10 clauses | Expired industry-specific exemptions | Sunset clauses expired; exemptions no longer operational |
| Section 271(1)(c) | Legacy concealment penalty | Merged into consolidated penalty framework (was effectively superseded by 270A) |
| Section 245D-245R | Settlement Commission provisions | Settlement Commission wound up; replaced by interim board for pending cases |
| Multiple legacy incentive sections | 80-IA, 80-IB (expired units) | Sunset period expired; no units with unexpired deduction |
22. Sections Merged / Consolidated
| 1961 Act Sections | Consolidated Into | Notes |
|---|---|---|
| 271(1)(c) + 270A + 271AAB | Unified penalty for concealment/under-reporting | Graduated penalty structure replacing overlapping provisions |
| 112 + 112A | Unified LTCG rate provision | Single 12.5% LTCG rate replaces dual rate structure |
| Multiple TDS sections (194H, 194I, etc.) | Rationalised TDS chapter | Similar payment categories consolidated with uniform 2% rate |
| 271A + 271B + 271BA | Consolidated compliance penalty | Book-keeping and audit failure penalties merged |
| Sections 30-37 (business deductions) | Streamlined deduction provisions | Individual deduction sections consolidated into clearer framework |
23. Key Takeaways
- Every section of the 1961 Act has been renumbered in the 2025 Act — practitioners must learn the new numbering.
- Some sections have been consolidated (penalties, TDS, LTCG rates), requiring understanding of the merged provisions.
- Some sections have been deleted entirely (angel tax, expired incentives, legacy penalties).
- The fundamental structure (five heads, deductions, assessment, appeals) is retained but reorganised.
- Case law citing 1961 Act sections remains relevant — courts will interpret 2025 Act provisions in light of established jurisprudence on equivalent 1961 provisions.
- DTAA references to 1961 Act sections are automatically read as references to 2025 Act equivalents.
- All templates, opinions, software, and compliance documents must be updated for new section numbers.
- The official correlation table should be the primary reference; this mapping is an indicative guide for practitioners.
The renumbering exercise is the most immediately visible change for practitioners. While the substantive law changes are limited to specific areas (capital gains, TDS rates, penalties), the section number change affects every aspect of daily practice. I recommend that practitioners create a personal quick-reference card of the 30-50 sections they use most frequently and keep it accessible during the transition period. Within 6-12 months, the new numbers will become familiar.
For detailed transition planning, contact our team.
24. Frequently Asked Questions
The Income Tax Act 2025 is a complete rewrite of the 1961 Act, not merely an amendment. The sections were renumbered as part of the restructuring to create a logically sequenced statute. Chapters are reorganised to follow the taxpayer lifecycle — income computation, deductions, returns, assessment, appeals, and penalties.
The deduction equivalent to Section 80C is available under a new section number in the 2025 Act, but only for taxpayers who opt into the old regime. Under the default new regime, Chapter VI-A deductions including 80C are not available. The substance of the deduction (Rs 1.5 lakh limit for specified investments) remains unchanged for old regime taxpayers. See our Deductions Guide for details.
Section 194J has been mapped to a new section in the 2025 Act. The dual rate structure (2% for technical services and 10% for professional fees) has been unified into a single rate. This eliminates the frequent litigation over classification of payments as technical vs professional services. For the complete chart, see our TDS Rate Chart.
The capital gains exemption for reinvestment in residential property (equivalent of Section 54) continues under the 2025 Act with a new section number. The conditions and limits are substantially similar. Sections 54, 54F, and 54EC equivalents have been carried forward with modifications to align with the simplified capital gains framework. See our Capital Gains Guide.
Use the mapping tables provided in this article, which cover all major provisions chapter-wise. The Government has also published an official correlation table. For professional guidance, practitioners should cross-reference both the official table and the Act text, as some sections have been split or merged and the mapping is not always one-to-one.
Yes. Several provisions were not carried forward, including Section 56(2)(viib) (angel tax), certain expired industry-specific exemptions under Section 10, legacy incentive provisions with expired sunset clauses, redundant procedural sections superseded by faceless mechanisms, and the Settlement Commission provisions (already wound up). See the deleted sections table above for details.
Double Taxation Avoidance Agreements continue to apply without modification. References to 1961 Act section numbers in treaties are read as references to the corresponding provisions of the 2025 Act. The transitional provisions explicitly address this to avoid any interpretational issues.
Yes. Several sections have been merged. Key examples include: TDS sections for similar payment categories consolidated into single sections, penalty provisions (271(1)(c), 270A, 271A, 271B etc.) merged into a graduated penalty framework, Sections 112 and 112A merged into a uniform 12.5% LTCG rate, and multiple assessment-related sections consolidated into streamlined procedures.
Yes. The presumptive taxation scheme equivalent to Section 44AD (for businesses with turnover up to Rs 2 crore / Rs 3 crore for digital receipts) and Section 44ADA (for professionals with gross receipts up to Rs 75 lakh) continue under new section numbers in the 2025 Act with substantially similar provisions. See our Presumptive Taxation Guide.
Practitioners should: (1) Study the official correlation table published by the Government, (2) Use mapping references like this article as a quick-reference tool, (3) Update all standard templates, opinions, and advisory documents with new section numbers, (4) Note that some sections have been split or merged and the mapping is not always one-to-one, and (5) Attend CPE seminars on the 2025 Act structure. For professional assistance, contact Virtual Auditor.
