Which Act Governs What After 01 April 2026? — The Complete Guide to Pending Proceedings, Parallel Compliance, and the Two-Act World
Quick Summary Box
| Proceeding Type | Old AY (up to AY 2026-27) | New Tax Year (TY 2026-27+) |
|---|---|---|
| Return filing | IT Act, 1961 | IT Act, 2025 |
| Scrutiny notice (143(2)) | IT Act, 1961 | IT Act, 2025 |
| Reassessment notice (148A) | IT Act, 1961 (Section 148A) | IT Act, 2025 (Section 281) |
| Penalty proceedings | IT Act, 1961 | IT Act, 2025 (Section 295) |
| CIT(A) appeal | IT Act, 1961 | IT Act, 2025 |
| ITAT appeal | IT Act, 1961 | IT Act, 2025 |
| TDS deduction (from Apr 2026) | IT Act, 2025 (Section 392/393) | IT Act, 2025 |
| Advance tax (from June 2026) | IT Act, 2025 | IT Act, 2025 |
| Old registrations/approvals | Deemed valid under IT Act, 2025 | IT Act, 2025 |
| Old CBDT circulars | Valid (unless inconsistent with new Act) | Valid |
Which Income Tax Act Governs Your Proceedings After 01 April 2026? — Complete Guide to Old Act vs New Act: Assessments, Notices, Appeals, TDS, and Penalties
The repeal of the Income Tax Act, 1961 on 01 April 2026 does not mean that practitioners can simply put the old Act aside and work exclusively with the new one. The reality is precisely the opposite: for many years after 01 April 2026, Indian income tax practice will be a simultaneously two-Act world. Assessment proceedings for AY 2024-25 will be governed by the old Act. TDS deductions from April 2026 will be under the new Act. An appeal filed in October 2026 relating to AY 2021-22 will be argued under the old Act. A penalty proceeding initiated in 2027 for Tax Year 2026-27 will fall under the new Act.
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