Taxmann’s Transition Reference Combo For Direct Taxes – Comparative Study Of Income-tax Act & Rules [1961/1962 : 2025/2026]

Description

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 decades-old Previous Year/Assessment Year framework replaced wholesale 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 the only available reference that provides complete, word-for-word, top-to-bottom comparative coverage of 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.

This set is designed for every category of professional and institutional reader who must work across both legislative regimes—whether advising, litigating, complying, administering, or researching:

Tax Professionals, Chartered Accountants & Senior Departmental Officers — Decades of institutional knowledge built on the 1961 Act and 1962 Rules does not become obsolete—it requires precise translation. This set functions as a systematic migration map, showing not only which section or rule of the new framework corresponds to a familiar legacy provision, but 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 not in isolation, but 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, frequently involving the same underlying facts spanning both regimes. Precise knowledge of where provisions align, where statutory language diverges, and where new sub-clauses without 1961 Act counterparts introduce new legislative territory is not optional—it is the foundation of 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. The Rules volume’s four cross-reference tables—covering both rules and forms in both directions—directly serve this need
Tax Administrators and Revenue Officers — A structured, authoritative reference for the new legislative framework, anchored in the text of both statutes and both sets of Rules as they currently stand
Researchers, Policy Analysts & Academics — A granular ledger of six decades of statutory evolution—at the Act level and at the subordinate legislation level—compressed into a single comparative framework and updated to reflect the law as amended by the Finance Act 2026 and all notifications issued up to 31st March 2026
The Present Publication is the 2026 Edition, edited/authored by Taxmann’s Editorial Board, with the following noteworthy features:

[Word-for-Word Dual-Column Comparative Format] The operative text of the legacy framework (1961 Act/1962 Rules) appears on the left; the corresponding text of the new framework (2025 Act/2026 Rules) on the right. Neither column is summarised, paraphrased, or abridged. Both legislative instruments speak in their own words, placed in direct confrontation with each other
[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 that is 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] Alignment does not rest at the section or rule level. 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 is not buried within the comparison and 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, enabling 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
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 comparative edition available and ensuring the comparison reflects the law as it stands for Tax Year 2025-26 onwards
Sub-Provision Cross-Reference Tables at Each Entry Point — For each provision or group of provisions, a dedicated cross-reference table shows the 1961 ↔ 2025 mapping at the sub-section level, with the distribution across multiple sections or Schedules explicitly shown where applicable
Volume 2 — Specific to the Rules
Four Cross-Reference Tables Covering Both Rules and Forms — Bilateral mapping in both directions for rules (1962 → 2026 and 2026 → 1962) and for prescribed forms (1962 → 2026 and 2026 → 1962), each entry showing both the rule/form number and heading under both frameworks. Of particular value to compliance officers and fiduciaries who need to identify which new form corresponds to a legacy form
Dedicated Section on Provisions Migrated from the Acts into the Rules — A structural feature of the legislative reorganisation is the movement of certain computational and procedural provisions previously embedded in the Income-Tax Act 1961 or 2025 into the Income-Tax Rules 2026. This volume identifies those migrations explicitly, with direct implications for interpretation and applicability
The structure of the Combo is as follows:

Volume 1 — Internal Structure
How to Read This Book — 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, including situations where a single 1961 Act section fans out across multiple sections and Schedules of the 2025 Act, or where several converge into one
Cross-Mapping Table of Contents — A bilateral index spanning the full legislative architecture of both statutes, mapping every 1961 Act section to its 2025 Act counterpart(s) with page references in both directions
Corresponding Provision Tables — At each entry point within the comparison, a sub-section-level cross-reference table showing the precise 1961 ↔ 2025 mapping, with explicit notation of distributions across multiple sections or Schedules
Textual Comparison (Main Body) — The dual-column comparative text with typographic 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 areas, ensuring the comparative view is total with nothing left outside the reader’s field of vision
Volume 2 — Internal Structure
Section I | Reference Tables and Transitional Mapping — The navigation backbone of the volume. Contains all four cross-reference tables (Rules 1962 → 2026; Rules 2026 → 1962; Forms 1962 → 2026; Forms 2026 → 1962), the section identifying provisions migrated from the Acts into the 2026 Rules, and the complete list of new 2026 Rules with no 1962 counterpart. This section enables rapid look-up and transitional mapping without entering the main comparative text
Section II | Comparative Study of Provisions — The core body. 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. The volume opens with a standalone section covering provisions of the 2026 Rules that have no corresponding 1962 Rule. Every comparative entry preserves the exact legislative text—including provisos, Explanations, tables, and sub-items—with the visual coding system applied throughout