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Do you know that as of April 1, 2026, the Income Tax 2025 section numbers replaced the Income Tax Act 1961 section numbers? While the basic taxation rules largely remain the same. Additionally, most of the section numbers have been changed and considered under the new act. However, because of these modifications, it can be difficult for taxpayers to determine which new section relates to the older provision.
Considering this, to help you out, this blog provides you with complete section mapping. Apart from this, it will help you understand the new section numbers stated under the Income Tax Act, 2025, key structural changes, impact, benefits, and the challenges of the new act for taxpayers. So read on and gather all the information.
- The Income Tax Act, 2025, has restructured the direct tax framework of India. It came into effect from April 1, 2026, replacing the Income Tax Act, 1961.
- The primary goal of the Income Tax Act 2025 is to provide statutory simplification, removing outdated language and reducing the legislation volume.
- No changes in the deduction and exemption benefits, but their section number have been revised.
- All TDS and TCS sections that previously stated under sections 192 to 194T are now mentioned under section 393.
- The new income tax act does not introduce any new taxes or withdraw any tax exemption.
Why Was the Income Tax Act Replaced in 2025?
Before moving to the section mapping, let's first know why the Income Tax Act 2025 replaced the Income Tax Act 1961. The Income Tax Act, 1961, consists of more than 298 sections, hundreds of sub-sections, and thousands of provisions, along with many amendments. It was first started with a reasonably structured statute, but now creating difficulty to work with, even for tax experts. Additionally, in this, the Direct Tax Code review committee and subsequent government consultations identified three key issues:
- The language used across sections was inconsistent and outdated.
- In many cases, provisions and explanations become longer than the main sections they were meant to clarify.
- The chapter structure was unable to showcase how tax compliance works practically.
The Income Tax Act 2025 resolved all these issues. It modernizes the language, integrating and reducing the provisions, and reorganising the chapter structure to make a clear flow. It starts with general concepts, followed by the calculation of income, deductions, filing, tax assessment, and appeals.
So, here is why the Income Tax Act 2025 replaced the Income Tax Act 1991. Now, to get a better idea of this, let's compare both acts.
Difference Between Income Tax Act 2025 and Income Tax Act 1961
The table below showcases the difference between the Income Tax Act 2025 and the Income Tax Act 1961:
|
Feature |
Income Tax Act 1961 |
Income Tax Act 2025 |
|---|---|---|
|
Enactment Year |
1961 |
2025 |
|
Effective From |
AY 1962-63 |
Tax Year 2026-27 |
|
Total Sections/ Clauses |
~298 Sections |
~536 Clauses across 23 Chapters |
|
Language Style |
Dense, outdated, and heavily amended. |
Simple, modern, and consolidated. |
|
Provision and Explanations |
Extensive- often longer than main sections. |
Integrated and reduced into the main section. |
|
Chapter Structure |
23 Chapters with multiple later amendments. |
Properly reorganised into logical compliance flow. |
|
Section Numbering |
Due to the amendments not being properly sequential. |
Systematic and clean numbering. |
|
Tax Rates and Policy |
Base/ original law |
Largely preserved with structural simplification. |
|
NRI Applicability |
Yes |
Yes, it continues the same taxation principles. |
|
DTAA and Foreign Income Relief |
Sections 90 and 91 |
Sections 159 and 160 (renumbered provisions) |
|
Residential Status Rules |
Section 6 |
Section 6 (retained largely) |
|
Capital Gains Provisions |
Sections 45 to 55A |
Sections 67 to 91 |
|
TDS Provisions |
Sections 192 to 206CCA |
Consolidated under Chapter XII |
|
Return Filing Provisions |
Section 139 series |
Section 263 onwards |
|
New Tax Regime Reference |
Section 174 (renumbered) |
|
|
Crypto/ VDA Taxation |
Section 115BBH |
Section 179 |
|
Ease of interpretation |
Due to decades of amendments, it is complex. |
Simple to navigate and read. |
|
Compliance Structure |
Across multiple chapters, scattered. |
It is grouped by practical compliance categories. |
|
Drafting Focus |
Legalistic drafting style. |
User-friendly legislative drafting. |
|
Impact on Taxpayers |
Familiar but hard to interpret. |
It is intended to ease compliance without any major policy overhaul. |
This was all about the difference between the Income Tax Act 1961 and the Income Tax Act 2025. Now, moving ahead, let's know the key structural changes in the new Income Tax Act 2025.
Key Structural Changes in the New Income Tax Act 2025
The key structural changes in the new Income Tax Act 2025 are as follows:
Simplified Section Numbering System
One of the most practical changes that was conducted in the new Income Tax Act 2025 is renumbering the sections. The Income Tax Act 1961 had an irregular numbering system for its 298 sections. Additionally, multiple amendments had added several sections like 80C, 80CCC, 80CCCD, 115BAC, and 115BBH, having a numbering pattern with no logical flow.
Further, this issue is resolved with the introduction of the Income Tax Act 2025 section numbers. The Tax Act 2025 provides you with a clear, sequential numbering system. It has grouped the related provisions under consistent number ranges, making it easy to identify the relevant section.
Reduction in Provisions and Explanations
Under the Income Tax Act 1961, it was common for one section to carry 5 to 6 provisions along with two to three explanations. For instance, to read section 10 (exempt income) or section 48 (capital gains computation), you need to go through several provisions. It is simplified in the 2025 Act by integrating most of the provisions into the main text or making separate sub-sections. This further helps non-tax experts to easily understand the Indian taxation system.
Reorganized Chapters and Compliance Structure
The chapters mentioned in the 2025 Act follow a natural order of tax compliance. For instance, who has tax liability, what income is covered under what section, how tax deductions work, how to file ITR, and how to pay and appeal in case of disputes. This structure showcases how accountants and taxpayers work through an ITR.
Shorter and More Readable Legal Language
In the Act 2025, legal drafting uses shorter sentences, active voices where possible, and is more concise. This reduces the requirement of reading multiple sections together, which was done in the 1961 Act, as it contains many rules within a clear, single provision where possible.
These are the key structural changes made in the new Income Tax Act. Moving further, let's know the number of sections included in the Income Tax Act.
What is the Total Number of Sections in the Income Tax Act?
The Income Tax Act 1961 consists of around 298 sections, which, over time, have grown significantly through multiple amendments. In contrast, the Income Tax Act 2025 contains around 536 clauses spread across 23 Chapters and 16 schedules. This increased number showcases better organization, as many provisions that were part of sub-sections or lengthy explanations are now represented as standalone, clear clauses. Rather than complexity, these higher numbers provide more transparency to taxpayers.
*Note: It is advisable in the Gazette notification of the Income Tax Act 2025 to check the official section and chapter number.
Complete Chapter-Wise Mapping: Income Tax Act 1961 and Income Tax Act 2025
CATEGORY 1 — RESIDENTIAL STATUS AND SCOPE OF INCOME
|
Section (2025) |
Section (1961) |
What It Covers |
Applicable To |
|---|---|---|---|
|
2 |
2 |
Definitions — including “person”, “assessee”, “income”, “tax year” |
All |
|
3 |
3 |
Definition of “tax year” (replaces previous FY/AY terminology) |
All |
|
5 |
5 |
Scope of total income — what income is taxable in India |
All |
|
6 |
6 |
Residential status rules — determines NRI vs resident classification |
All — critical for NRIs |
|
9 |
9, 9A |
Income deemed to accrue or arise in India |
NRIs — primary applicability |
CATEGORY 2 — INCOME HEADS AND COMPUTATION
|
Section (2025) |
Section (1961) |
What It Covers |
Applicable To |
|---|---|---|---|
|
13 |
14 |
Five heads of income |
All |
|
15–19 |
15–17, 16 |
Salary income, perquisites, standard deduction |
Residents, NRIs |
|
20–22 |
22–24 |
House property income and deductions |
Residents, NRIs |
|
26 |
28 |
Business and profession income |
Business, NRIs |
|
33 |
32 |
Depreciation deduction |
Business |
|
34 |
37 |
General business expenditure deduction |
Business |
|
37 |
43B |
Deductions allowed on actual payment basis |
Business |
|
58 |
44AD, 44ADA, 44AE |
Presumptive taxation |
Residents (small businesses) |
|
59 |
44DA |
Royalty and technical services income |
NRIs, Foreign companies |
|
60 |
44C |
Head office expenditure deduction |
NRIs, Foreign companies |
|
61 |
44B–44BBD |
Presumptive taxation for non-resident business activities |
NRIs |
|
62 |
44AA |
Maintenance of books of account |
Business |
|
63 |
44AB |
Tax audit provisions |
Business |
|
67 |
45 |
Capital gains charging section |
All |
|
72 |
48 |
Capital gains computation |
All |
|
73 |
49 |
Cost of acquisition rules |
All |
|
78 |
50C |
Stamp duty value for property transactions |
Residents, NRIs |
|
82 |
54 |
Capital gains exemption on house property reinvestment |
Residents, NRIs |
|
85 |
54EC |
Exemption through specified bonds |
All |
|
86 |
54F |
Exemption on reinvestment in residential house |
Residents, NRIs |
|
92 |
56 |
Income from other sources |
All |
CATEGORY 3 — EXEMPT INCOME
|
Section (2025) |
Section (1961) |
What It Covers |
Applicable To |
|---|---|---|---|
|
11 |
10 |
Exempt income — agricultural income, PPF, gratuity, NRE interest, etc. |
All |
|
12 |
13A, 13B |
Exempt income of political parties/electoral trusts |
Political entities |
CATEGORY 4 — DEDUCTIONS FROM TOTAL INCOME
|
Section (2025) |
Section (1961) |
What It Covers |
Applicable To |
|---|---|---|---|
|
123 |
80C, 80CCC, 80CCE |
LIC, ELSS, home loan principal, etc. |
Residents, limited NRI applicability |
|
124 |
80CCD |
NPS deductions |
Residents, NRIs |
|
126 |
80D |
Health insurance premiums |
Residents, NRIs |
|
129 |
80E |
Education loan interest |
Residents, NRIs |
|
133 |
80G |
Donations to approved institutions |
Residents, NRIs |
|
137 |
80GGC |
Political contributions |
Residents, NRIs |
|
153 |
80TTA, 80TTB |
Savings and FD interest deduction |
Residents |
|
154 |
80U |
Disability deduction |
Residents |
CATEGORY 5 — REBATES, RELIEFS, AND DTAA
|
Section (2025) |
Section (1961) |
What It Covers |
Applicable To |
|---|---|---|---|
|
155 |
87 |
Rebate in computing income tax |
Residents |
|
156 |
87A |
Rebate under old/new regime |
Residents only |
|
157 |
89 |
Relief on salary arrears |
Residents, NRIs |
|
158 |
89A |
Relief for overseas retirement accounts |
NRIs |
|
159 |
90, 90A |
DTAA relief provisions |
NRIs, Residents |
|
160 |
91 |
Unilateral foreign tax relief |
NRIs, Residents |
CATEGORY 6 — SPECIAL TAX RATES
|
Section (2025) |
Section (1961) |
What It Covers |
Applicable To |
|---|---|---|---|
|
194 |
115A |
Tax on NRI investment income and LTCG |
NRIs |
|
195 |
115AD |
Tax on FII/FPI income |
NRIs |
|
199 |
115BBA |
Tax on non-resident sportsmen/entertainers |
NRIs |
|
201 |
115BAA |
22% concessional corporate tax |
Business |
|
202 |
115BAB |
15% tax for manufacturing companies |
Business |
|
203 |
115BAC |
New tax regime |
Residents, NRIs |
|
215 |
115BBH |
Crypto/VDA taxation |
All |
|
216 |
115BBJ |
Online gaming winnings tax |
All |
|
218 |
112A |
LTCG on listed equity |
All |
|
219 |
111A |
STCG on listed equity |
All |
|
220 |
112 |
LTCG on other assets |
All |
CATEGORY 7 — TDS AND TCS
|
Section (2025) |
Section (1961) |
What It Covers |
Applicable To |
|---|---|---|---|
|
385 |
192 |
TDS on salary |
Residents, NRIs |
|
387 |
193 |
TDS on securities interest |
Residents, NRIs |
|
388 |
194 |
TDS on dividends |
Residents, NRIs |
|
389 |
194A |
TDS on bank interest and FDs |
Residents, NRIs |
|
392 |
194C |
TDS on contractors |
Business |
|
397 |
194I |
TDS on rent |
Residents, NRIs |
|
398 |
194J |
TDS on professional fees |
Business, NRIs |
|
399 |
195 |
TDS on payments to non-residents |
NRIs |
|
403 |
197 |
Lower/Nil TDS certificate |
All |
|
404 |
197A |
Form 15G/15H declarations |
Residents |
|
410 |
201 |
Failure to deduct TDS |
Business |
|
413 |
206C(1G) |
TCS on foreign remittance under LRS |
Residents, NRIs |
|
416 |
206AB, 206CCA |
Higher TDS/TCS for non-filers |
All |
CATEGORY 8 — RETURN FILING AND ASSESSMENT
|
Section (2025) |
Section (1961) |
What It Covers |
Applicable To |
|---|---|---|---|
|
262 |
139A, 139AA |
PAN and Aadhaar linking |
All |
|
263 |
139 |
ITR filing provisions |
All |
|
266 |
140A |
Self-assessment tax |
All |
|
267 |
140B |
Updated return (ITR-U) |
All |
|
272 |
143(1) |
Summary assessment |
All |
|
273 |
143(3) |
Scrutiny assessment |
All |
|
275 |
144B |
Faceless assessment |
All |
|
290 |
234A |
Interest for late filing |
All |
|
291 |
234B |
Interest for advance tax default |
All |
|
292 |
234C |
Interest for deferment of advance tax |
All |
|
294 |
234F |
Late filing fee |
All |
CATEGORY 9 — ADVANCE TAX
|
Section (2025) |
Section (1961) |
What It Covers |
Applicable To |
|---|---|---|---|
|
380 |
208 |
Liability to pay advance tax |
All |
|
382 |
209 |
Computation of advance tax |
All |
|
383 |
211 |
Advance tax instalments |
All |
CATEGORY 10 — INTERNATIONAL TAX AND TRANSFER PRICING
|
Section (2025) |
Section (1961) |
What It Covers |
Applicable To |
|---|---|---|---|
|
159 |
90, 90A |
DTAA treaty relief |
NRIs |
|
160 |
91 |
Unilateral relief |
NRIs |
|
161 |
92 |
Transfer pricing provisions |
Business, NRIs |
|
165 |
92C |
Arm’s length pricing |
Business |
|
167 |
92CB |
Safe harbour rules |
Business |
|
168 |
92CC |
Advance Pricing Agreements |
Business |
|
178 |
95 |
GAAR provisions |
All |
CATEGORY 11 — PENALTIES
|
Section (2025) |
Section (1961) |
What It Covers |
Applicable To |
|---|---|---|---|
|
441 |
270A |
Penalty for under-reporting income |
All |
|
442 |
271F |
Penalty for failure to file return |
All |
|
445 |
271B |
Penalty for failure to conduct audit |
Business |
|
446 |
271BA |
Failure to report international transactions |
Business, NRIs |
|
448 |
271C |
Failure to deduct TDS |
Business |
|
450 |
Black Money Act |
Penalty for non-disclosure of foreign assets |
NRIs |
CATEGORY 12 — APPEALS AND DISPUTE RESOLUTION
|
Section (2025) |
Section (1961) |
What It Covers |
Applicable To |
|---|---|---|---|
|
320 |
246A |
Appeal before CIT(A) |
All |
|
325 |
253 |
Appeal before ITAT |
All |
|
328 |
260A |
Appeal before High Court |
All |
|
329 |
261 |
Appeal before Supreme Court |
All |
|
330–331 |
263, 264 |
Revision powers of Commissioner |
All |
|
297–310 |
245Q–245V |
Advance ruling provisions |
NRIs |
CATEGORY 13 — REFUNDS
|
Section (2025) |
Section (1961) |
What It Covers |
Applicable To |
|---|---|---|---|
|
430 |
237 |
Refund of excess tax |
All |
|
431 |
239 |
Claiming refund |
All |
|
435 |
244A |
Interest on delayed refunds |
All |
|
436 |
245 |
Set-off of refund against tax demand |
All |
|
437 |
241A |
Withholding of refund |
All |
CATEGORY 14 — IMPORTANT NRI SECTIONS AT A GLANCE
|
Section (2025) |
Section (1961) |
Why It Matters for NRIs |
|---|---|---|
|
6 |
6 |
Determines NRI/RNOR/Resident status |
|
9 |
9 |
Defines taxable Indian income |
|
11 |
10 |
NRE account interest exemption |
|
158 |
89A |
Overseas retirement account relief |
|
159 |
90, 90A |
DTAA benefit provisions |
|
160 |
91 |
Relief where DTAA absent |
|
194 |
115A |
Special NRI tax rates |
|
203 |
115BAC |
New tax regime applicability |
|
215 |
115BBH |
Crypto taxation for NRIs |
|
263 |
139 |
NRI ITR filing obligation |
|
289 |
230 |
Tax clearance certificate |
|
297–310 |
245Q–245V |
Advance ruling mechanism |
|
399 |
195 |
TDS on NRI payments |
|
403 |
197 |
Lower TDS certificate |
CATEGORY 15 — SECTIONS REMOVED OR DISCONTINUED IN THE 2025 ACT
|
Provision |
Section (1961) |
What Changed |
Impact |
|---|---|---|---|
|
Settlement Commission |
245A–245M |
Abolished |
Appeals route required |
|
Dividend Distribution Tax |
115-O |
Removed |
Dividend taxable in shareholder’s hands |
|
Multiple standard deduction provisions |
Various |
Simplified and consolidated |
Cleaner computation structure |
This was all about the total number of sections in the Income Tax Act. Moving forward, let's know the impact of new section numbers on taxpayers and professionals.
Impact of New Section Numbers on Taxpayers and Professionals
The impact of new section numbers on taxpayers and professionals is as follows:
- Changes in ITR Filing References: Starting from Tax Year 2026-27, for ITR filing, taxpayers will use new section numbers. For many individual taxpayers, it is a minor update as the tax deductions, exemptions, and filing requirements are the same. The key change is only how the tax deductions are now cited in the form.
- Impact on Tax Compliance Software: All the tax filing platforms for 2026-27 ITR filings need to update their section references. Considering this, while filing your ITR, ensure that you are using an updated tax filing software.
- Effect on Tax Litigation and Case Law Reference: This is a major transition challenge. It is because of decades of High Court, Supreme Court, and ITAT judgements using the section numbers mentioned in the Act 1961. Considering this, before tribunals and courts, legal practitioners will need to maintain a cross-reference for citing. Although during this transaction, courts are expected to accept both references, no formal notification has been issued yet.
- Challenges for CA and Tax Professionals: CAs and tax professionals need to update their section knowledge as per the new Act 2025, revise the compliance checklist, and re-train their staff. Considering this, it is expected that ICAI will issue updated study material and guidance notes. Additionally, during the transition period, they need to pay careful attention to where both Act references may be used for at least two or three tax filing cycles.
So, this is the impact of new section numbers on taxpayers and professionals. Moving ahead, now let's look at the benefits of the new income tax act structure.
Benefits of the New Income Tax Act Structure
Here are the benefits of the new income tax act structure for taxpayers:
- Without needing an expert to resolve any query, taxpayers can now easily understand routine provisions.
- Fewer provisions mean fewer ambiguities, resulting in less interpretational disputes.
- The logical and organized flow of the chapter makes it simple to locate relevant sections.
- Clear numbering eases cross-referencing in assessments, notices, and appeals.
- For non-English first readers, the use of modern languages has reduced the risk of misinterpretation.
- Additionally, to understand a single term, the introduction of unified definitions has reduced the requirement to move through different sections.
- Under sections 159 and 160, NRIs and foreign investors get benefits from a cleaner DTAA and foreign income provisions.
These are some of the key benefits of the new income tax act structure for taxpayers. Now, moving further, let's know the challenges faced by taxpayers and professionals during the transition from the 1961 Act to the 2025 Act.
Challenges During the Transition from the 1961 Act to the 2025 Act
The challenges taxpayers and professionals faced during the transition from the 1961 Act to the 2025 Act are as follows:
- All existing tribunal orders, case law, and court judgements use the sections of the 1961 Act. Considering this, for at least two to three filing cycles, they need to maintain parallel mapping.
- Before the Tax Year 2026-27 ITR filing season, tax software needs to update its sections on the portal.
- Payroll processors and HR teams need updated TDS section references.
- Educational and professional examination materials need to be revised fully across all tax bodies.
- NRIs, depending on tax advisors for DTAA claims, should confirm with their experts that they are working according to the new act references.
- Before new section references, a transition period of two to three years is likely to be used for universal adoption.
So, these are some key challenges that taxpayers and professionals face during the transition from the 1961 Act to the 2025 Act section numbers.
With Savetaxs, file your ITR with the top tax experts of India and maximise your refunds.
Final Thoughts
Lastly, the Income Tax Act 2025 provides a new structure with renumbered and reorganised provisions, effective from April 1, 2026. Additionally, the Income Tax Act 2025 section numbers have changed, but the tax rates, exemptions, deductions, and compliance obligations that taxpayers use every day are safe under these sections. This master mapping section blog helps you simply identify the corresponding provisions between both acts.
Furthermore, if you are still confused and looking for a reliable NRI tax expert, connect with Savetaxs. We have a team of professionals who will help you in resolving all your tax-related queries and assist you in fulfilling your tax obligations.
Note: This guide is for information purposes only. The views expressed in this guide are personal and do not constitute the views of Savetaxs. Savetaxs or the author will not be responsible for any direct or indirect loss incurred by the reader for taking any decision based on the information or the contents. It is advisable to consult either a CA, CS, CPA or a professional tax expert from the Savetaxs team, as they are familiar with the current regulations and help you make accurate decisions and maintain accuracy throughout the whole process.
Hatim Dudhiyawala is a Certified Public Accountant (CPA) with SaveTaxs and specializes in Indian and NRI taxation. He advises individuals, NRIs, and businesses on income tax filing, capital gains taxation, DTAA benefits, fund repatriation, and tax compliance. With experience in cross-border tax matters, Hatim helps taxpayers understand complex regulations and make informed decisions. Through his articles, he shares practical insights to help readers stay compliant and manage their tax obligations with confidence. See Full Bio
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