CA Umesh Sharma
Quick Summary
In a dialogue inspired by Arjuna and Krishna, this piece explains the transition from the Income Tax Act, 1961 to the Income Tax Act, 2025, with a focus on ongoing litigation. It reassures taxpayers that any appeals pending as of 1st April 2026, whether before CIT(A), ITAT, or higher courts, will co
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FAQ :
Appeals pending before the CIT(A), ITAT, or higher courts as of April 1, 2026, will continue to be governed by the Income Tax Act, 1961, until their final resolution.
No, you do not need to refile your appeals. The new Act ensures continuity, and pending proceedings will be disposed of as if the 2025 Act had not been enacted.
If a fresh appeal is filed after April 1, 2026, but relates to an Assessment Year prior to Tax Year 2026-27, it must follow the procedures of the old Income Tax Act, 1961.
If a search or requisition was initiated before April 1, 2026, all connected proceedings, including block assessments, will remain under the Income Tax Act, 1961.
While the power of revision remains, the 2025 Act provides better clarity. If the remaining time to pass a revision order is less than 60 days, it will be automatically extended to 60 days to ensure a proper hearing for the taxpayer.
No, the core principles of justice, the appellate hierarchy (from CIT(A) to the Supreme Court), and procedural fairness remain intact, even though section numbers may change.
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