Comparative Study of Provisions of Income Tax Act 2025 & Income Tax Act 1961 By Taxmann – 2nd Edition 2026

India’s direct tax framework has undergone its most consequential structural transformation since independence. The Income-Tax Act 2025 is not an amendment to the Income-Tax Act 1961—it is a complete legislative replacement. It rebuilds the statute from the ground up: sections have been renumbered across an entirely new numerical range stretching past 530 (against 298 in the 1961 Act), sub-clauses within provisions have been reordered, provisos have been surgically trimmed, voluminous narrative text has been converted into structured tables, over a hundred Section 10 exemptions have been redistributed across multiple categorised Schedules, and a new unified concept of ‘tax year’ has replaced the decades-old Previous Year/Assessment Year framework across every procedural provision in the statute.

This is not a change that can be absorbed incrementally. It requires a complete, structured, side-by-side mapping of both statutes—at every level of the legislative text.

Comparative Study of Provisions of Income-Tax Act 2025 & Income-Tax Act 1961 is precisely that. Now in its 2^nd Edition, updated to incorporate all amendments made by the Finance Act, 2026 to both statutes, this reference places the complete operative text of the 1961 Act and the 2025 Act in direct two-column alignment—section by section, sub-section by sub-section, clause by clause, sub-clause by sub-clause, proviso by proviso, and Explanation by Explanation—with typographically coded change mark-up that makes every deletion, modification, simplification, and new insertion instantly visible. It is the single most comprehensive primary-text comparative reference available for the 1961 → 2025 transition.

A companion volume, the Comparative Study of Income-Tax Rules 2026 & Income-Tax Rules 1962, extends this framework to the subordinate legislation—together, the two volumes cover the complete regulatory framework governing Indian direct taxation across both regimes.

This book is intended for the following audience:

• Tax Professionals, Chartered Accountants & Senior Departmental Officers — This book operates as a systematic migration map, showing not only which section of the 2025 Act corresponds to a familiar 1961 Act provision, but also exactly what changed within it, what was trimmed, what was reordered, and what was restructured. Institutional knowledge built over decades does not go to waste; it gets precisely translated
• Newer Professionals, CA/Law Students & Compliance Teams — This book provides the ability to understand the 2025 Act not in isolation, but in the legislative context from which it emerged, with the historical text of the 1961 Act serving as the baseline against which every design choice in the new statute becomes legible
• Litigators and Appellate Practitioners — This book will address the disputes arising from assessments governed by the 1961 Act, which will continue to be adjudicated alongside matters under the 2025 Act, often involving the same set of facts spanning both regimes. This requires precise knowledge of how provisions align, where language diverges, and where new sub-clauses lacking 1961 Act counterparts introduce new statutory areas
• Researchers & Policy Analysts — This book provides a granular ledger of six decades of statutory evolution compressed into a single comparative framework

The Present Publication is the 2^nd Edition | 2026, amended by Finance Act 2026. This book is edited/authored by Taxmann’s Editorial Board, with the following noteworthy features:

• [Word-to-Word Textual Comparison in a Dual-Column Format] The operative provisions of the 1961 Act are placed on the left; the corresponding provisions of the 2025 Act on the right. The comparison is not summarised, paraphrased, or abridged—both statutes speak in their own words, placed in direct confrontation with each other
• [Granular Alignment to the Smallest Operative Unit] The alignment does not rest at the section level. Every sub-section, clause, sub-clause, item, sub-item, proviso, and Explanation of each 1961 Act provision is aligned against its precise counterpart in the 2025 Act. Where sub-clauses within a provision have been reordered in the 2025 Act, the alignment reflects the actual structural correspondence rather than the positional sequence—a distinction that matters critically for provisions where internal clause order has been reversed or reorganised
• [Typographically Coded Change Identification] Two distinct visual signals operate throughout:
  • Text from the 1961 Act shown in bold with strikethrough indicates language that has been deleted or modified in the 2025 Act
  • Text from the 2025 Act shown in bold indicates language that is simplified, changed, or newly inserted relative to the 1961 Act
• [Comprehensive Cross-Mapping Table of Contents] A front-loaded cross-reference grid spanning the full table of contents maps every section of the 1961 Act to its corresponding section(s) in the 2025 Act, with page references for both. This enables navigation from either statute’s reference frame—a practitioner thinking in 1961 Act section numbers can locate the 2025 Act equivalent instantly, and vice versa
• [Standalone Compilation of 2025 Act Provisions Without 1961 Counterparts] Provisions of the 2025 Act that have no corresponding provision in the 1961 Act are compiled separately at the end of the book—covering definitional expansions, new structural mechanisms, and provisions specific to the consolidated design of the new statute. This compilation ensures the comparative coverage is total, with nothing left outside the reader’s view
• [Finance Act 2026 Incorporated in Both Statutes] Both the 1961 Act and the 2025 Act are reproduced as amended by the Finance Act 2026, making this the most current edition available and ensuring that the comparison reflects the law as it stands for Tax Year 2025-26 onwards
• [An Unmatched Editorial Standard] The comparative alignment in this book is a precision-engineering task that cannot be approximated. The 2025 Act’s 530+ sections do not map to the 1961 Act’s 298 sections in any predictable sequence—one section may fan out across multiple sections and Schedules, while several may collapse into one. Sub-clauses within provisions have been reordered, operative provisos quietly dropped, and narrative text restructured into tables. Every entry reflects editorial judgment applied at the level of individual legislative sub-elements—none of it algorithmic

The structure of the book is as follows:

• How to Read This Book — Opens with a precise guide establishing the dual-column convention, the typographic change-marking system, and the treatment of multi-to-one and one-to-many section correspondences
• Cross-Mapping Table of Contents — A bilateral index mapping every 1961 Act section against its 2025 Act counterpart(s), with page references, covering the full legislative architecture of both statutes
• Corresponding Provision — For each provision or group of provisions, a cross-reference table showing the 1961 ↔ 2025 mapping at the sub-section level, with the distribution across multiple sections or Schedules explicitly shown where applicable
• Textual Comparison — The main body in dual-column format with change mark-up, proceeding in the sequence of the 1961 Act; where a 1961 Act provision maps to provisions distributed across multiple sections or Schedules of the 2025 Act, all relevant 2025 Act text is brought into the comparison at that entry point
• 2025 Act Provisions Without a 1961 Act Counterpart — A standalone compilation at the end covering definitional additions, structural provisions unique to the 2025 Act’s architecture, and substantively new legislative territory, ensuring the comparative view is complete