DIRECT TAX

The New Income-tax Act, 2025 — Effective 1 April 2026

India's six-decade-old Income-tax Act, 1961 has been replaced by the Income-tax Act, 2025, which came into force on 1 April 2026. We decode what changes, what stays the same, and what businesses must do now.

Apr 2026  ·  Direct Tax

A Re-codification, Not a New Tax

The Income-tax Act, 2025 received Presidential assent on 21 August 2025 and came into effect on 1 April 2026, repealing the 1961 Act. Importantly, it is a structural re-write — tax rates, slabs, deductions and core principles remain substantially unchanged. The Act condenses the law into 536 sections across 23 chapters (down from 819 sections), with clearer language and a more logical structure.

Key Structural Changes

  • The "Previous Year" and "Assessment Year" concepts are replaced by a single, simpler "Tax Year"
  • Virtually every section has been renumbered — references in agreements, SOPs and software must be remapped
  • The Income-tax Rules, 2026 replace the 1962 Rules from the same date
  • Transitional provisions allow pending proceedings for earlier years to continue under the 1961 Act

What Businesses Should Do Now

While the tax outcome is largely unchanged, the renumbering has practical consequences — every internal document, engagement letter, tax position paper and accounting system that cites a section number needs updating. We recommend a mapping exercise of old-to-new sections for your recurring filings and a review of any contracts that reference specific provisions of the 1961 Act.

GST

GST 2.0 — The 56th Council Meeting and the New Two-Slab Structure

The 56th GST Council meeting delivered the most sweeping overhaul since 2017 — collapsing four slabs into two, with a special rate for sin and luxury goods. Effective 22 September 2025, here's what changed and how to prepare.

Sep 2025  ·  GST

The New Rate Structure

Chaired by Finance Minister Nirmala Sitharaman on 3 September 2025, the Council adopted a dual-rate regime effective 22 September 2025. The 12% and 28% slabs were abolished — most former 28% items moved to 18%, and most 12% items moved to 5%. A special 40% rate now applies to sin and luxury goods such as tobacco, pan masala, aerated drinks and high-end vehicles.

Key Changes

  • Two core rates: 5% (merit) and 18% (standard), plus 40% for sin/luxury goods
  • Essentials such as milk, paneer and roti exempted; cement reduced from 28% to 18%
  • Faster compliance — registration within 3 working days for non-risky applicants and quicker export refunds
  • Inverted duty corrections in textiles, footwear and fertilisers

Action Points for Businesses

Every business needs to re-map its product and service catalogue to the new rates, update ERP and billing masters, revise published price lists, and reconcile transitional input tax credit. Contracts straddling the 22 September cut-off need careful treatment. We are advising clients on rate re-classification and the working-capital impact of the changes.

DIRECT TAX

Budget 2025-26: Zero Tax up to ₹12 Lakh and Other Key Reliefs

The Union Budget 2025-26 delivered major relief to the middle class — no income tax up to ₹12 lakh under the new regime, an enhanced rebate, and a longer window for updated returns. Here's our analysis.

Feb 2025  ·  Direct Tax

Personal Tax — The Headline Relief

Presented on 1 February 2025, the Budget made income up to ₹12 lakh effectively tax-free under the new regime (₹12.75 lakh for salaried taxpayers, after the ₹75,000 standard deduction), via an enhanced Section 87A rebate. The slab structure under the new regime was widened across the board, increasing take-home pay for the middle class.

Other Key Proposals

  • TDS limit on interest for senior citizens doubled from ₹50,000 to ₹1 lakh
  • Time limit to file updated returns extended from 2 years to 4 years
  • Annual value of two self-occupied properties can be treated as nil, without conditions
  • Registration period for small charitable trusts extended from 5 years to 10 years
  • New reporting obligations introduced for crypto-asset (virtual digital asset) transactions

Our View

For most salaried individuals with income up to ₹12-13 lakh and limited deductions, the new regime is now clearly more attractive. Those with significant HRA, home-loan interest or 80C investments should still run a comparison before opting. Individual analysis remains advisable before filing.

TRANSFER PRICING

Transfer Pricing Safe Harbour — Threshold Raised to ₹300 Crore

The CBDT has expanded the transfer pricing safe harbour regime — raising the eligibility threshold to ₹300 crore, adding EV batteries to "core auto components", and extending applicability to AY 2025-26 and AY 2026-27.

Mar 2025  ·  Transfer Pricing

What Changed

Through Notification No. 21/2025 dated 25 March 2025, the CBDT amended the safe harbour rules under Section 92CB. Safe harbour rules let the tax authority accept the taxpayer's declared transfer price where prescribed margins and conditions are met — reducing audit exposure and litigation.

Key Amendments

  • Eligibility threshold for specified international transactions raised from ₹200 crore to ₹300 crore
  • "Core auto components" expanded to include lithium-ion batteries for electric and hybrid vehicles
  • Applicability extended to AY 2025-26 and AY 2026-27
  • Safe harbour margin rates themselves remain unchanged

Practical Impact for MNCs

The higher threshold brings more service providers (IT, ITeS, KPO, contract R&D) and EV-linked manufacturers within reach of safe harbour. Opting in remains a commercial decision — the fixed margins may exceed actual profitability. India's APA programme also continues strongly, with a record 174 APAs signed in FY 2024-25, reinforcing the dispute-prevention toolkit. We help clients model whether safe harbour or an APA is the better route.

FEMA

RBI's Updated Foreign Investment Master Direction — FOCC Clarity

The RBI's updated Master Direction on Foreign Investment (20 January 2025) resolves long-standing ambiguities for Foreign-Owned or Controlled Companies (FOCCs) on downstream investments, share swaps and deferred consideration.

Jan 2025  ·  FEMA

What Changed

On 20 January 2025, the RBI issued an updated Master Direction on Foreign Investment in India, clarifying several grey areas under the NDI Rules — particularly for FOCCs (companies with foreign ownership exceeding 50% or foreign control). The update also absorbed the August 2024 NDI amendments that facilitated cross-border M&A via secondary share swaps.

Key Clarifications

  • FOCCs can now undertake downstream investment via swap of equity instruments, with clearer conditions
  • Deferred consideration (up to 25%, for up to 18 months) is now available for FOCC transactions, aligning them with FDI
  • Compliance and filing requirements for downstream investments and rights issues spelt out
  • Continued caution under Press Note 3 for investments linked to land-border-sharing countries

Action Points

Foreign-controlled groups structuring acquisitions in India now have more certainty on swaps and earn-out structures. We recommend that FOCCs revisit pending or planned transactions in light of the clarified position, and that all entities with overseas links keep their FEMA filings current — the RBI's broader push (including draft rules for foreign offices and the PRAVAAH portal) signals tighter, technology-driven oversight.

INTERNATIONAL TAX

Pillar Two — Global Minimum Tax: India's Position and Impact

The OECD's Pillar Two Global Minimum Tax framework continues to reshape international tax planning. We analyse India's position and the practical implications for Indian multinationals and MNCs operating in India.

2025  ·  International Tax

What is Pillar Two?

The OECD's Pillar Two framework establishes a global minimum corporate tax rate of 15% for multinational enterprises with consolidated revenues exceeding €750 million. Where an MNC is taxed below 15% in a jurisdiction, other countries may impose a top-up tax to reach that floor.

India's Position

  • India's effective corporate tax rate for large companies already exceeds 15%, so Indian companies are not directly impacted
  • Indian subsidiaries of foreign MNCs may still face top-up taxes in their parent company's jurisdiction
  • India's adoption of a Qualified Domestic Minimum Top-up Tax (QDMTT) remains a key watch item with significant revenue implications

Action Points for MNCs

MNCs with Indian operations should model their Pillar Two exposure across all jurisdictions. Indian subsidiaries benefiting from SEZ exemptions or tax holidays may inadvertently trigger top-up taxes in the parent jurisdiction — this requires careful planning as the rules take effect across countries.