India's direct tax architecture has undergone its most consequential structural overhaul since independence. The Income-Tax Act 2025 is not an amendment to the Income-Tax Act 1961—it is a full legislative replacement, rebuilding the statute from the ground up. Sections have been renumbered across an entirely new range stretching beyond 530, against 298 in the 1961 Act, sub-clauses reordered, provisos trimmed, narrative text converted into structured tables, over a hundred Section 10 exemptions redistributed across categorised Schedules, and the Previous Year/Assessment Year framework replaced by the unified concept of "tax year". The Income-Tax Rules 2026 follow in parallel, extending this structural reorganisation into subordinate legislation, including the migration of computational and procedural provisions previously embedded within the Act itself.
This Two-Volume Set is the complete primary-text response to that transformation.
- Volume 1 — Comparative Study of Provisions of Income-Tax Act 2025 & Income-Tax Act 1961 (2nd Edition, amended by Finance Act 2026) maps the substantive legislative transition at the level of the parent statute—section by section, sub-section by sub-section, clause by clause, sub-clause by sub-clause, proviso by proviso, and Explanation by Explanation—in a dual-column format with typographically coded change mark-up.
- Volume 2 — Comparative Study of Provisions of Income-Tax Rules 2026 & Income-Tax Rules 1962 extends this framework to the subordinate legislation—rule by rule, form by form—with identical structural rigour and a dedicated reference architecture that maps both rules and prescribed forms across the two regimes, including a separate identification of provisions migrated from the Acts into the new Rules.
Together, the two volumes constitute a complete, word-for-word, top-to-bottom comparative reference covering what has changed, what has been retained, and what is entirely new across both the parent statute and the rules that give it operational force. Neither volume is complete without the other.
Who Should Use This Book?
- Tax Professionals, Chartered Accountants & Senior Departmental Officers: Decades of institutional knowledge built on the 1961 Act and 1962 Rules require precise translation. This set functions as a systematic migration map, showing which section or rule of the new framework corresponds to a familiar legacy provision, exactly what changed within it, what was trimmed, what was reordered, and what was restructured.
- Newer Professionals, CA/Law Students & Compliance Teams: The 2025 Act and 2026 Rules are understood most efficiently in the legislative context from which they emerged. With the full historical text of the 1961 Act and 1962 Rules serving as the baseline, every design choice in the new framework becomes legible and contextually grounded.
- Litigators and Appellate Practitioners: Assessments governed by the 1961 Act will continue to be adjudicated alongside matters under the 2025 Act. Precise knowledge of where provisions align, where statutory language diverges, and where new sub-clauses without 1961 Act counterparts introduce new legislative territory is essential for competent appellate work.
- Corporate Tax and Legal Teams: Practitioners managing transfer pricing, safe harbour elections, TDS/TCS obligations, and return filings under the transitional framework require granular procedural clarity at the level of individual rules and prescribed forms.
- Tax Administrators and Revenue Officers: A structured and authoritative reference for the new legislative framework, anchored in the text of both statutes and both sets of Rules.
- Researchers, Policy Analysts & Academics: A granular record of statutory evolution at both the Act and subordinate legislation levels, updated to reflect the law as amended by the Finance Act 2026 and all notifications issued up to 31st March 2026.
Present Publication: 2026 Edition
Editor/Author: Taxmann's Editorial Board
Key Features
- Word-for-Word Dual-Column Comparative Format: The operative text of the legacy framework, comprising the 1961 Act and 1962 Rules, appears on the left, while the corresponding text of the new framework, comprising the 2025 Act and 2026 Rules, appears on the right. Neither column is summarised, paraphrased, or abridged.
- Typographically Coded Change Identification: Two visual signals operate consistently throughout both volumes:
- Bold + Strikethrough in the legacy column: Language deleted or modified in the new framework.
- Bold in the new framework column: Language newly inserted, simplified, or changed relative to the legacy text.
This system allows the reader to identify the nature and extent of every change at the sub-provision level without reading both columns in full.
- Granular Alignment to the Smallest Operative Unit: Every sub-section, sub-rule, clause, sub-clause, item, sub-item, proviso, and Explanation is aligned against its precise counterpart. Where internal clause order has been reversed or reorganised in the new framework, alignment reflects actual structural correspondence rather than positional sequence.
- Standalone Compilation of New Provisions Without Legacy Counterparts: Provisions of the 2025 Act and 2026 Rules that have no corresponding provision in the 1961 Act or 1962 Rules are compiled separately, ensuring that entirely new legislative territory remains fully visible.
- Volume 1 — Specific to the Act
- Comprehensive Cross-Mapping Table of Contents: A bilateral index mapping every section of the 1961 Act against its corresponding section(s) in the 2025 Act, with page references for both.
- Finance Act 2026 Incorporated in Both Statutes: Both the 1961 Act and the 2025 Act are reproduced as amended by the Finance Act 2026, ensuring the comparison reflects the law as it stands for Tax Year 2025-26 onwards.
- Sub-Provision Cross-Reference Tables at Each Entry Point: Dedicated cross-reference tables show the 1961 ↔ 2025 mapping at the sub-section level, including distributions across multiple sections or Schedules.
- Volume 2 — Specific to the Rules
- Four Cross-Reference Tables Covering Both Rules and Forms: Bilateral mapping in both directions for Rules and prescribed Forms, with each entry showing the rule/form number and heading under both frameworks.
- Dedicated Section on Provisions Migrated from the Acts into the Rules: Identifies computational and procedural provisions previously embedded in the Income-Tax Act 1961 or 2025 that have been moved into the Income-Tax Rules 2026.
Structure of the Combo
- Volume 1 — Internal Structure
- How to Read This Book: A guide establishing the dual-column convention, typographic change-marking system, and treatment of multi-to-one and one-to-many section correspondences.
- Cross-Mapping Table of Contents: A bilateral index spanning the legislative architecture of both statutes, mapping every 1961 Act section to its 2025 Act counterpart(s) with page references.
- Corresponding Provision Tables: Sub-section-level cross-reference tables showing the precise 1961 ↔ 2025 mapping, including distributions across multiple sections or Schedules.
- Textual Comparison (Main Body): Dual-column comparative text with typographic change mark-up, proceeding in the sequence of the 1961 Act.
- 2025 Act Provisions Without a 1961 Act Counterpart: A standalone compilation covering definitional additions, structural provisions unique to the 2025 Act, and substantively new legislative areas.
- Volume 2 — Internal Structure
- Section I | Reference Tables and Transitional Mapping: Contains all four cross-reference tables covering Rules and Forms, the section identifying provisions migrated from the Acts into the 2026 Rules, and the complete list of new 2026 Rules with no 1962 counterpart.
- Section II | Comparative Study of Provisions: Rules are presented in the order of the 1962 Rules, with the corresponding 2026 Rule positioned alongside. Where a 1962 Rule maps to multiple 2026 Rules or vice versa, all relevant provisions are displayed together. Where a 1962 Rule has no 2026 counterpart, this is indicated by the absence of a corresponding column entry.
- Every comparative entry preserves the exact legislative text, including provisos, Explanations, tables, and sub-items, with the visual coding system applied throughout.
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