New Income Tax Act 2025: Complete Section Mapping Guide for CAs

The Income Tax Act 2025, effective from April 1, 2026, is not yet enacted., replaces the 64-year-old Income Tax Act 1961. With 819 sections condensed into 536 sections across 23 chapters, this is the most significant structural overhaul of India's direct tax law in living memory. For practicing Chartered Accountants, the transition demands immediate attention — every notice response, return filing, and advisory opinion must now reference the new section numbers.

This guide provides a practical, section-by-section mapping of the provisions CAs use most frequently, along with analysis of what has actually changed versus what is merely renumbered.

Why the New Act Matters for Day-to-Day Practice

The new Act is not merely a renumbering exercise. While the government has emphasized that the substantive law remains largely unchanged, there are critical structural differences that affect how CAs work:

• Consolidated TDS provisions: All TDS sections (previously scattered across 194, 194A through 194S, 195, 196A-196D) are now consolidated under a single Section 393 framework with sub-sections
• Simplified deduction structure: Chapter VI-A deductions are reorganized with cleaner categorization
• Penalty rationalization: The penalty and prosecution framework has been streamlined
• Reassessment overhaul: New sections 147A and related provisions address longstanding jurisdictional issues
• Digital-first approach: Several provisions now explicitly account for electronic communication and digital records

The immediate practical impact: every template, every precedent letter, every notice response that references old section numbers must be updated. Notices issued after April 1, 2026 will reference the new sections. Notices issued before that date will still reference old sections, meaning CAs must be fluent in both numbering systems for the next several years.

Complete Section Mapping Table: Most Used Provisions

Income Heads and Computation

Old Act (1961)	New Act (2025)	Subject Matter	Key Changes
Section 2	Section 2	Definitions	Expanded and reorganized; new definitions added for digital assets, virtual digital assets
Section 4	Section 3	Charge of income tax	Substantially unchanged
Section 5	Section 4	Scope of total income	Substantially unchanged
Section 10	Sections 11-13	Exempt income	Split into three sections: general exemptions, allowances, and specific categories
Section 14	Section 14	Heads of income	Same five heads retained
Section 15-17	Sections 15-18	Salary income	Reorganized with clearer treatment of perquisites
Section 22-27	Sections 19-23	House property income	Simplified; standard deduction mechanism unchanged
Section 28-44	Sections 24-44	Business/profession income	Largely reorganized but substantively similar
Section 45-55	Sections 67, 196-198	Capital gains	Significant restructuring; holding period, indexation rules consolidated
Section 56-59	Sections 83-85	Other sources	Streamlined

Deductions Under Chapter VI-A (Now Chapter VIII)

Old Act (1961)	New Act (2025)	Subject Matter	Key Changes
Section 80C	Section 80C	Investments and expenditure deduction	Same Rs 1.5 lakh limit; qualifying investments list updated
Section 80CCC	Section 123(1)(viii)	Pension fund contribution	Merged into Section 123 as a sub-clause
Section 80CCD(1)	Section 123(1)(ix)	NPS employee contribution	Merged into Section 123
Section 80CCD(1B)	Section 124	Additional NPS deduction	Separate section retained; Rs 50,000 limit unchanged
Section 80CCD(2)	Section 125	Employer NPS contribution	14% limit for government, 10% for others unchanged
Section 80D	Section 126	Medical insurance premium	Rs 25,000/50,000 limits unchanged; preventive health check-up included
Section 80DD	Section 127	Disabled dependent	Rs 75,000/1,25,000 limits unchanged
Section 80DDB	Section 128	Medical treatment	Limits unchanged
Section 80E	Section 129	Education loan interest	No time limit change
Section 80EEA	Section 80EEA	Affordable housing interest	Sunset clause expired; not carried forward
Section 80G	Section 131	Donations	Restructured with clearer categorization of 100% and 50% eligible entities
Section 80GG	Section 132	Rent paid (no HRA)	Rs 5,000/month limit updated to Rs 10,000/month
Section 80GGA	Section 133	Donations for scientific research	Substantially unchanged
Section 80GGC	Section 134	Political party contributions	Substantially unchanged
Section 80TTA	Section 137	Savings account interest	Rs 10,000 limit unchanged
Section 80TTB	Section 138	Senior citizen interest income	Rs 50,000 limit unchanged
Section 80U	Section 139	Person with disability	Rs 75,000/1,25,000 limits unchanged

TDS Provisions (Consolidated Under Section 393)

This is the most significant structural change. Previously, TDS provisions were scattered across nearly 30 separate sections. The new Act consolidates them under a single section framework. For a comprehensive walkthrough, read our complete guide to TDS under Section 393.

Old Act (1961)	New Act (2025)	Subject Matter
Section 192	Section 392	TDS on salary
Section 193	Section 393(1)	TDS on interest on securities
Section 194	Section 393(2)	TDS on dividends
Section 194A	Section 393(3)	TDS on interest other than securities
Section 194B	Section 393(4)	TDS on lottery/game winnings
Section 194BB	Section 393(5)	TDS on horse race winnings
Section 194C	Section 393(6)	TDS on contractor payments
Section 194D	Section 393(7)	TDS on insurance commission
Section 194DA	Section 393(8)	TDS on life insurance payout
Section 194H	Section 393(9)	TDS on commission/brokerage
Section 194I	Section 393(10)	TDS on rent
Section 194IA	Section 393(11)	TDS on immovable property transfer
Section 194IB	Section 393(16)	TDS on rent by individuals
Section 194J	Section 393(17)	TDS on professional/technical fees
Section 194K	Section 393(18)	TDS on mutual fund income
Section 194N	Section 393(20)	TDS on cash withdrawal
Section 194O	Section 393(21)	TDS on e-commerce
Section 194Q	Section 393(22)	TDS on purchase of goods
Section 194R	Section 393(23)	TDS on perquisites/benefits
Section 194S	Section 393(24)	TDS on virtual digital assets
Section 195	Section 393(25)	TDS on payments to non-residents
Section 206C	Section 394	TCS provisions (consolidated similarly)

Assessment, Appeals, and Penalties

Old Act (1961)	New Act (2025)	Subject Matter	Key Changes
Section 139	Section 263	Filing of returns	Sub-sections reorganized
Section 139(9)	Section 263(9)	Defective return	Substantially unchanged
Section 142(1)	Section 269	Inquiry before assessment	Substantially unchanged
Section 143(1)	Section 270	Summary/intimation assessment	Processing logic unchanged; reference to CPC streamlined
Section 143(2)	Section 270(2)	Scrutiny notice	Faceless assessment explicitly referenced
Section 143(3)	Section 270(3)	Scrutiny assessment order	Substantially unchanged
Section 144	Section 271	Best judgment assessment	Substantially unchanged
Section 147	Section 279	Income escaping assessment (reassessment)	Significant changes — see Section 147A discussion below
Section 148	Section 280	Notice for reassessment	New safeguards added
Section 148A	Section 280A	Procedure before issuing 148	Inquiry procedure retained with modifications
Section 154	Section 295	Rectification of mistakes	Substantially unchanged
Section 156	Section 298	Notice of demand	Substantially unchanged
Section 246A	Section 356	Appeals to CIT(A)	Substantially unchanged
Section 253	Section 370	Appeals to ITAT	Substantially unchanged
Section 260A	Section 378	Appeal to High Court	Substantially unchanged
Section 263	Section 380	Revision by PCIT/CIT	Substantially unchanged
Section 264	Section 381	Revision by PCIT/CIT on application	Substantially unchanged
Section 271(1)(c)	Section 271(1)(c)	Penalty for misreporting/under-reporting	Already changed in 2016; new Act retains 270A framework under Section 440
Section 270A	Section 440	Under-reporting and misreporting penalty	50%/200% penalty structure retained
Section 271AAB	Section 271AAB	Penalty for undisclosed income in search	Merged into general penalty framework
Section 271B	Section 441	Failure to get accounts audited	Rs 1.5 lakh limit unchanged
Section 276C	Section 482	Prosecution for willful evasion	Substantially unchanged

What Actually Changed vs. What Is Just Renumbered

Substantive Changes CAs Must Know

1. Simplified Residency Rules (Section 5-7) The new Act consolidates the residency determination framework. The 182-day and 60-day rules remain, but the conditions for "not ordinarily resident" status are stated more clearly. The deemed residency provision for Indian income exceeding Rs 15 lakh (previously in Section 6(1A)) is now in Section 6 with clearer language.

2. Capital Gains Overhaul (Sections 67-82) The holding period for all assets is now standardized at 24 months for long-term classification, except for listed securities (12 months) and immovable property (24 months). The indexation provisions are simplified following the July 2024 Budget changes. The new Act codifies the removal of indexation benefit for properties sold after July 23, 2024.

3. TDS Consolidation Benefits Beyond mere renumbering, the consolidated TDS framework under Section 393 introduces a unified threshold and rate table in the First Schedule. This reduces the complexity of determining which section applies when multiple TDS provisions could potentially apply to the same transaction.

4. Penalty Framework Simplification The new Act reduces the number of penalty provisions from 33 to 21. Several overlapping penalties have been merged, and the discretionary vs. mandatory penalty distinction is clearer.

What Stays the Same (Just Renumbered)

• The five heads of income structure
• Basic deduction limits under what was Chapter VI-A
• The assessment and appeal hierarchy
• The search and seizure framework
• Advance tax and self-assessment provisions
• TDS rates (only the section numbers change, not the rates)
• Audit thresholds under Section 44AB (now Section 62)

Practical Transition Tips for CAs

1. Update All Templates Immediately

Every notice response template, advisory letter, and opinion format that references section numbers must be updated. Maintain dual-reference templates for the transition period — many assessments will still be under the old Act for AYs up to 2025-26.

2. Cross-Reference Table for Pending Matters

For ongoing litigation and pending assessments (which reference old section numbers), maintain a quick-reference mapping. Courts and tribunals will need to deal with both numbering systems for years.

3. Client Communication

Proactively communicate the change to clients. Many clients who are familiar with "80C" or "194C" will need to understand that the law has not changed — only the numbering has. Miscommunication here can cause unnecessary client anxiety.

4. Software and ERP Updates

Ensure that your tax software, practice management tools, and ERP systems are updated to reflect new section numbers. Check that return preparation software handles the new numbering correctly.

5. Continuing Professional Education

ICAI is expected to release detailed mapping guides and CPE courses. Attend these sessions — there are subtle changes buried in the reorganization that are easy to miss.

How AI Tools Can Help With the Transition

The transition from 1961 to 2025 numbering creates a unique challenge: CAs must be fluent in both systems simultaneously. AI-powered tools can significantly ease this burden.

TaxNoticeAI's legal corpus has been updated to map all section references across both Acts. When you upload a notice referencing old section numbers, the system automatically identifies the corresponding new Act provisions and vice versa. This dual-mapping capability is critical during the transition period when you may receive notices under either framework.

Additionally, AI tools can help identify whether a substantive change (not just renumbering) affects a particular notice response — flagging cases where the old precedent may not apply identically under the new framework. This is especially important for capital gains computation, TDS compliance, and penalty proceedings where the new Act introduces meaningful differences.

The section mapping in this guide will be updated as CBDT issues clarifications and the new Act's rules are notified. Bookmark this page and check back for the latest mapping information.