NRI Income Tax Compliance

Income Tax Act 2025: Complete Section-Wise Mapping from the 1961 Act

Hatim Dudhiyawala
Updated on: June 8, 202617 mins Editorial Standards
Income Tax Act 2025 vs Income Tax Act 1961: Complete Section Mapping

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. 

Key Takeaways
  • 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  • The primary goal of the Income Tax Act 2025 is to provide statutory simplification, removing outdated language and reducing the legislation volume.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  • The language used across sections was inconsistent and outdated.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 115BAC

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. 

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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.

About Author
Hatim Dudhiyawala
Hatim Dudhiyawala Certified Public Accountant (CPA)

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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Frequently Asked Questions

No, the Income Tax Act is a structural reorganisation. Considering this, it does not change tax rates, slabs, deductions, and exemption threshold governed by the Annual Finance Act.

The Income Tax Act 2025 comes into effect on April 1, 2026. It covers income earned from April 1, 2026, onwards.

The Income Tax Act 2025 contains 536 sections across 23 chapters and 16 schedules. The higher count of sections showcases better-organised provisions with modern language.

The new section number for section 80C is section 123 (read with Schedule XV) in the Income Tax Act 2025. In this, the tax deduction limit and eligible instruments remain the same.

No, DTAA provisions do not change for NRIs. They carry forward as sections 159 and 160 in the Income Tax Act 2025. Additionally, the treaty claim process and unilateral relief remain the same.