Income Tax Act 2025 vs Income Tax Act 1961: Key Section Changes

Priya Bhatia Relan 22 Feb 2026 3,522 Views 0 comment Print Income Tax | Articles

The New Income Tax Act, 2025, effective for income earned from April 1, 2026, introduces a restructured and renumbered framework of sections while largely retaining the conceptual structure of the five heads of income under the Income Tax Act, 1961. To ensure smoother transition and better interpretation, a comparative mapping of old and new sections is essential. The Act reorganises provisions relating to Salaries (Sections 15–19), House Property (20–25), Profits and Gains of Business or Profession (26–66), Capital Gains (67–91), and Income from Other Sources (92–95). While core principles remain intact, numbering has been streamlined and grouped logically for clarity and readability. Business income provisions see significant structural consolidation, and capital gains provisions are sequentially arranged for easier reference. The renumbering aims to enhance accessibility, reduce interpretational confusion, and modernise statutory presentation. Understanding the old-to-new section mapping is crucial for professionals, taxpayers, and students to accurately interpret the new law once it becomes operational in FY 2026–27.

The comparative chart of section of five heads of income is as follows-

S. No.	Income Tax Act 2025		Income Tax Act 1961
A	Income from Salary
1	Salaries- Due/ Advanced	15	15 – Salaries
2	Income from Salary	16	17 – “Salary”, “perquisite” and “profits in lieu of salary” defined
3	Perquisites	17	17 – “Salary”, “perquisite” and “profits in lieu of salary” defined
4	Profits in lieu of Salary	18	17 – “Salary”, “perquisite” and “profits in lieu of salary” defined
5	Deduction from Salaries	19	10(10) – Gratuity, 10(10A) – Pension, 10(10AA) – Leave Salary, 10(10B) – Retrenchment Compensation, 10(10C) – Voluntary Retirement Compensation, 16 – Deductions from salaries

B	Income from House Property
6	Income from house property	20	22 – Income from house property
7	Determination of annual value	21	23 – Annual value how determined, 27 – “Owner of house property”, “annual charge”, etc., defined
8	Deductions from income from house property	22	24 – Deductions from income from house property, 25 – Amounts not deductible from income from house property
9	Arrears of rent and unrealised rent received subsequently	23	25A – Special provision for arrears of rent and unrealised rent received subsequently
10	Property owned by co-owners	24	26 – Property owned by co-owners
11	Interpretation	25	27 – “Owner of house property”, “annual charge”, etc., defined

C	Profits and gains of business or profession
12	Income under head “Profits and gains of business or profession	26	28 – Profits and gains of business or profession
13	Manner of computing profits and gains of business or profession	27	29 – Income from profits and gains of business or profession, how computed
14	Rent, rates, taxes, repairs and insurance	28	30 – Rent, rates, taxes, repairs and insurance for buildings, 31 – Repairs and insurance of machinery, plant and furniture, 38 – Building, etc., partly used for business, etc., or not exclusively so used
15	Deductions related to employee welfare	29	36 – Other deductions, 40A – Expenses or payments not deductible in certain circumstances
16	Deduction on certain premium	30	36 – Other deductions
17	Deduction for bad debt and provision for bad and doubtful debt	31	36 – Other deductions
18	Other deductions	32	36 – Other deductions
19	Deduction for depreciation	33	32 – Depreciation 38 – Building, etc., partly used for business, etc., or not exclusively so used
20	General conditions for allowable deductions	34	37 – General
21	Amounts not deductible in certain circumstances	35	40 – Amounts not deductible
22	Expenses or payments not deductible in certain circumstances	36	40A – Expenses or payments not deductible in certain circumstances
23	Certain deductions allowed on actual payment basis only	37	43B – Certain deductions to be only on actual payment
24	Certain sums deemed as profits and gains of business or profession	38	41 – Profits chargeable to tax
25	Computation of actual cost	39	43 – Definitions of certain terms relevant to income from profits and gains of business or profession
26	Special provision for computation of cost of acquisition of certain assets	40	43C – Special provision for computation of cost of acquisition of certain assets
27	Written down value of depreciable asset	41	43 – Definitions of certain terms relevant to income from profits and gains of business or profession
28	Capitalising impact of foreign exchange fluctuation	42	43A – Special provisions consequential to changes in rate of exchange of currency
29	Taxation of foreign exchange fluctuation	43	43AA – Taxation of foreign exchange fluctuation
30	Amortisation of certain preliminary expenses	44	35D – Amortisation of certain preliminary expenses
31	Expenditure on scientific research.	45	35 – Expenditure on scientific research
32	Capital expenditure of specified business	46	35AD – Deduction in respect of expenditure on specified business
33	Expenditure on agricultural extension project and skill development project	47	35CCC – Expenditure on agricultural extension project, 35CCD – Expenditure on skill development project
34	Tea development account, coffee development account and rubber development account	48	33AB – Tea development account, coffee development account and rubber development account
35	Site Restoration Fund	49	33ABA – Site Restoration Fund
36	Special provision in case of trade, profession or similar association	50	44A – Special provision for deduction in the case of trade, professional or similar association
37	Amortisation of expenditure for prospecting certain minerals	51	35E – Deduction for expenditure on prospecting, etc., for certain minerals
38	Amortisation of expenditure for telecommunications services, amalgamation, demerger, scheme of voluntary retirement, etc	52	35ABA – Expenditure for obtaining right to use spectrum for telecommunication services, 35ABB – Expenditure for obtaining licence to operate telecommunication services, 35DD – Amortisation of expenditure in case of amalgamation or demerger, 35DDA – Amortisation of expenditure incurred under voluntary retirement scheme
39	Full value of consideration for transfer of assets other than capital assets in certain cases	53	43CA – Special provision for full value of consideration for transfer of assets other than capital assets in certain cases
40	Business of prospecting for mineral oils	54	43CA – Special provision for full value of consideration for transfer of assets other than capital assets in certain cases
41	Insurance business	55	44 – Insurance business
42	Special provision in case of interest income of specified financial institutions	56	43D – Special provision in case of income of public financial institutions, etc.
43	Revenue recognition for construction and service contracts	57	43CB – Computation of income from construction and service contracts
44	Special provision for computing profits and gains of business or profession on presumptive basis in case of certain residents	58	44AA – Maintenance of accounts by certain persons carrying on profession or business, 44AB – Audit of accounts of certain persons carrying on business or profession, 44ADA – Special provision for computing profits and gains of profession on presumptive basis, 44AE – Special provision for computing profits and gains of business of plying, hiring or leasing goods carriages
45	Computation of royalty and fee for technical services in hands of non-residents	59	44DA – Special provision for computing income by way of royalties, etc., in case of non-residents
46	Deduction of head office expenditure in case of non-residents	60	44C – Deduction of head office expenditure in the case of non-residents
47	Special provision for computation of income on presumptive basis in respect of certain business activities of certain non-residents	61	44B – Special provision for computing profits and gains of shipping business other than cruise shipping in case of non-residents, 44BB – Special provision for computing profits and gains in connection with the business of exploration, etc., of mineral oils, 44BBA – Special provision for computing profits and gains of the business of operation of aircraft in the case of non-residents, 44BBB – Special provision for computing profits and gains of foreign companies engaged in the business of civil construction, etc., in certain turnkey power projects, 44BBC – Special provision for computing profits and gains of business of operation of cruise ships in case of non-residents, 44BBD – Special provision for computing profits and gains of non-residents engaged in business of providing services or technology for setting up an electronics manufacturing facility or in connection with manufacturing or producing electronic goods, article or thing in India
48	Maintenance of books of account	62	44AA – Maintenance of accounts by certain persons carrying on profession or business
49	Tax audit	63	44AB – Audit of accounts of certain persons carrying on business or profession
50	Special provision for computing deductions in case of business reorganisation of co-operative banks	64	44DB – Special provision for computing deductions in the case of business reorganization of co-operative banks
51	Interpretation for purposes of section 64	65	44DB – Special provision for computing deductions in the case of business reorganization of co-operative banks
52	Interpretation	66	28 – Profits and gains of business or profession, 32 – Depreciation, 35 – Expenditure on scientific research, 35DDA – Amortisation of expenditure incurred under voluntary retirement scheme, 36 – Other deductions, 40 – Amounts not deductible, 41 – Profits chargeable to tax, 42 – Special provision for deductions in the case of business for prospecting, etc., for mineral oil, 43 – Definitions of certain terms relevant to income from profits and gains of business or profession, 43A – Special provisions consequential to changes in rate of exchange of currency, 43B – Certain deductions to be only on actual payment, 43D – Special provision in case of income of public financial institutions, etc., 44BB – Special provision for computing profits and gains in connection with the business of exploration, etc., of mineral oils, 44DA – Special provision for computing income by way of royalties, etc., in case of non-residents

D	Capital Gains
	Capital Gains	67	45 – Capital gains
	Capital gains on distribution of assets by companies in liquidation	68	46 – Capital gains on distribution of assets by companies in liquidation
	Capital gains on purchase by company of its own shares or other specified securities	69	46A – Capital gains on purchase by company of its own shares or other specified securities
	Transactions not regarded as transfer	70	47 – Transactions not regarded as transfer
	Withdrawal of exemption in certain cases	71	47A – Withdrawal of exemption in certain cases
	Mode of computation of capital gains	72	48 – Mode of computation
	Cost with reference to certain modes of acquisition	73	49 – Cost with reference to certain modes of acquisition
	Special provision for computation of capital gains in case of depreciable assets	74	50 – Special provision for computation of capital gains in case of depreciable assets
	Special provision for cost of acquisition in case of depreciable asset	75	50A – Special provision for cost of acquisition in case of depreciable asset
	Special provision for computation of capital gains in case of Market Linked Debenture	76	50AA – Special provision for computation of capital gains in case of Market Linked Debenture
	Special provision for computation of capital gains in case of slump sale	77	50B – Special provision for computation of capital gains in case of slump sale
	Special provision for full value of consideration in certain cases	78	50C – Special provision for full value of consideration in certain cases
	Special provision for full value of consideration for transfer of share other than quoted share	79	50CA – Special provision for full value of consideration for transfer of share other than quoted share
	Fair market value deemed to be full value of consideration in certain cases	80	50D – Fair market value deemed to be full value of consideration in certain cases
	Advance money received	81	51 – Advance money received
	Profit on sale of property used for residence	82	54 – Profit on sale of property used for residence
	Capital gains on transfer of land used for agricultural purposes not to be charged in certain cases	83	54B – Capital gain on transfer of land used for agricultural purposes not to be charged in certain cases
	Capital gains on compulsory acquisition of lands and buildings not to be charged in certain cases	84	54D – Capital gain on compulsory acquisition of lands and buildings not to be charged in certain cases
	Capital gains not to be charged on investment in certain bonds	85	54EC – Capital gain not to be charged on investment in certain bonds
	Capital gains on transfer of certain capital assets not to be charged in case of investment in residential house	86	54F – Capital gain on transfer of certain capital assets not to be charged in case of investment in residential house
	Exemption of capital gains on transfer of assets in cases of shifting of industrial undertaking from urban area	87	54G – Exemption of capital gains on transfer of assets in cases of shifting of industrial undertaking from urban area
	Exemption of capital gains on transfer of assets in cases of shifting of industrial undertaking from urban area to any Special Economic Zone	88	54GA – Exemption of capital gains on transfer of assets in cases of shifting of industrial undertaking from urban area to any Special Economic Zone
	Extension of time for acquiring new asset or depositing or investing amount of capital gains	89	54H – Extension of time for acquiring new asset or depositing or investing amount of capital gain
	Meaning of “adjusted”, “cost of improvement” and “cost of acquisition”.	90	55 – Meaning of “adjusted”, “cost of improvement” and “cost of acquisition”
	Reference to Valuation Officer	91	55A – Reference to Valuation Officer

E	Income from other sources
	Income from other sources	92	56 – Income from other sources
	Deductions	93	57 – Deductions
	Amounts not deductible	94	58 – Amounts not deductible
	Profits chargeable to tax	95	59 – Profits chargeable to tax