Income Tax Act 2025 Changes for Foreign Owned Companies in India

Written by CA Nandini, Krystal7 Consultants. Last updated 1 October 2026.

The Income Tax Act, 2025 (Act 30 of 2025) replaced the Income Tax Act, 1961 on 1 Apr 2026. Income earned from that date falls in tax year 2026-27 under the new Act. FY 2025-26 returns, tax audits and Form 3CEB filed in 2026 stay under the 1961 Act. The visible changes are new form numbers, a 14 percent MAT without new credit and fixed fees for late reports. Form 3CEB, for example, is now Form 48.

This page maps the sections and forms that a foreign owned Indian subsidiary uses from the 1961 Act to the 2025 Act. It shows which law governs each filing in 2026 and 2027, with a worked example and a checklist.

What is the Income Tax Act, 2025 and when did it take effect?

The Income Tax Act, 2025 is India's new income tax law. The President gave assent on 21 Aug 2025, and the Act came into force on 1 Apr 2026. It replaces the Income Tax Act, 1961. The Income Tax Rules, 2026 replace the Income Tax Rules, 1962 from the same date.

The rewrite is mainly structural. The Central Board of Direct Taxes (CBDT) says the new Act adds no new tax (transition FAQ Q1.3). Dozens of old TDS sections, for example, are now serial numbers in the tables of section 393.

Item	Income Tax Act, 1961	Income Tax Act, 2025
Sections (count)	819	536
Schedules (count)	14	16
Rules (count)	511 (1962 Rules)	333 (2026 Rules)
Forms (count)	399	190
Year concept	Previous year and assessment year	Tax year (section 3)
In force	Up to 31 Mar 2026, then saved for earlier years	From 1 Apr 2026

Source for the counts: CBDT, FAQs on Interplay and Transition, Q1.5 (read 27 Sep 2026).

The Finance Act, 2026 (Act 4 of 2026, assent 30 Mar 2026) amended the new Act before it started. The department publishes that amended text on incometaxindia.gov.in. Section 536 repeals the 1961 Act but keeps it alive for tax years that began before 1 Apr 2026.

What is a tax year, and what happened to previous year and assessment year?

Section 3 of the 2025 Act defines a tax year as the financial year from 1 April to 31 March. The tax year replaces both the previous year and the assessment year. Income earned from 1 Apr 2026 to 31 Mar 2027 is tax year 2026-27, and the department assesses it under that same label.

Under the 1961 Act, income of the previous year 2025-26 was assessed in assessment year 2026-27. That split often confuses finance teams abroad. A first tax year can be shorter. A business set up on 1 Dec 2026 has a first tax year ending 31 Mar 2027 (Q1.10).

Period of income	1961 Act label	2025 Act label	Law that governs it
1 Apr 2025 to 31 Mar 2026	Previous year 2025-26, AY 2026-27	Not applicable	1961 Act, saved by section 536
1 Apr 2026 to 31 Mar 2027	Not applicable	Tax year 2026-27	2025 Act
1 Apr 2027 to 31 Mar 2028	Not applicable	Tax year 2027-28	2025 Act

There is no gap year. Under section 536(3), a reference to a tax year before 1 Apr 2026 means the matching previous year. On the portal, CBDT asks payers to pick "Tax Year 2026-27" for payments relating to FY 2026-27 (Q2.23). The "AY 2026-27" option still exists for FY 2025-26, so a wrong click parks advance tax in the wrong year.

Which law applies to FY 2025-26 returns and audits filed in 2026?

The 1961 Act applies. Section 536 of the 2025 Act keeps the old law in force for tax years that began before 1 Apr 2026. So FY 2025-26 is filed as assessment year 2026-27 on the old forms. They include ITR-6, Forms 3CA and 3CD, Form 3CEB, Form 3CEAA and Form 27Q for January to March 2026.

CBDT confirms that the FY 2025-26 return is filed for AY 2026-27 under the 1961 Act (Q3.5). The tax audit uses Forms 3CA or 3CB with 3CD, and Form 26 starts with tax year 2026-27 (Q4.32, Q4.33). By statute, a company's return is due on 31 Oct 2026, or 30 Nov 2026 where a transfer pricing report is required (Q3.3). The Explanation to section 44AB fixes the tax audit report one month before the return due date. That gave 30 Sep 2026, the date CBDT gives in Q4.32, or 31 Oct 2026 in a transfer pricing case. Form 3CEB is also due on 31 Oct 2026.

CBDT Circular No. 07/2026 of 28 Sep 2026 extended the first pair of dates for AY 2026-27. Companies and other audited cases without a transfer pricing report now file the tax audit report by 21 Oct 2026. Their return is due by 21 Nov 2026. Transfer pricing cases keep 31 Oct 2026 for the audit and Form 3CEB, and 30 Nov 2026 for the return. Our planned guide to tax audit under section 63 covers Form 26 in detail.

TDS follows a different trigger: the earlier of credit or payment. If either happened by 31 Mar 2026, the 1961 Act governs the deduction, even if the deposit falls in April (Q2.9). Tax deducted on credit before 1 Apr 2026 is not deducted again on payment (Q2.10).

Remittance forms follow the remittance date. For money sent from 1 Apr 2026, the payer files Forms 145 and 146 (updated FAQ, Q4.25). The FAQ does not deal with an invoice raised before that date. We file Forms 145 and 146 for any payment that leaves India from 1 Apr 2026.

Filing	FY 2025-26 (AY 2026-27)	Tax year 2026-27 onwards
Company return	ITR-6, section 139	New return form, section 263 (Q3.12)
Tax audit report	Forms 3CA or 3CB with 3CD, section 44AB	Form 26, section 63
Transfer pricing report	Form 3CEB, section 92E	Form 48, section 172
Master file	Form 3CEAA, section 92D	Form 56, section 171
MAT report	Form 29B, section 115JB	Form 66, section 206
Non resident TDS statement	Form 27Q, January to March 2026	Form 144, from April 2026
TDS certificate, non salary	Form 16A	Form 131
Remittance forms	Forms 15CA and 15CB, money sent by 31 Mar 2026	Forms 145 and 146, money sent from 1 Apr 2026
Treaty claim form	Form 10F	Form 41
Annual information statement	Form 26AS and AIS	Form 168 (Q2.24)

A belated return for AY 2026-27 is possible up to 31 Dec 2026 (Q3.8). An updated return under section 139(8A) stays open (Q3.9). The Finance Act, 2026 stretched the revised return window from nine to twelve months, with a fee after nine months. For the 1961 Act, it changed section 139(5) and added a fee in section 234-I, in force from 1 Mar 2026. So a revised return for AY 2026-27 can be filed up to 31 Mar 2027, or before the assessment ends if earlier. A revision after 31 Dec 2026 costs INR 1,000, or INR 5,000 where total income exceeds INR 5,00,000.

Which sections of the 2025 Act matter to a foreign owned company?

About three dozen sections cover almost everything a foreign owned subsidiary files. The core ones are section 3 (tax year), 6 (residence), 9 (source rules) and 159 (treaty relief). Then come 161 to 172 (transfer pricing) and 200 and 206 (company tax and MAT). The list ends with 207 (non resident rates), 263 (returns) and 393 to 397 (TDS).

Each 2025 Act number below comes from the Act text, a department section page, a CBDT FAQ or a form title under the 2026 Rules. Where the Act moved an old rule into a clause, the row names the clause.

Topic	1961 Act section	2025 Act section	Note
Residence, including place of effective management	6	6	Test for the foreign parent
Income through a business connection	9(1)(i)	9(2)(c)	Meaning in 9(9), including significant economic presence
Dividend paid by an Indian company outside India	9(1)(iv)	9(4)	Dividend to the parent
Interest	9(1)(v)	9(5)	Loan from the parent
Royalty	9(1)(vi)	9(6)	Brand, software, technology
Fees for technical services	9(1)(vii)	9(7)	Management and technical fees
Indirect transfer of Indian assets	9(1)(i), Explanation 5	9(10)	Group restructures
Disallowance where no TDS on a payment to a non resident	40(a)(i)	35(b)(ii)	Full disallowance until the tax is paid
Royalty and fees of a non resident with a PE	44DA	59	Audit report in Form 24
Tax audit	44AB	63	Form 26
Treaty relief and tax residency certificate	90, 90A	159	159(4) more beneficial rule; 159(8) TRC
Arm's length computation	92	161	International transactions
Associated enterprise	92A	162	Parent and group companies
Arm's length price and tolerance range	92C	165	Up to 3% in 165(3)
Safe harbour and advance pricing agreement	92CB, 92CC	167, 168	Forms 49 and 51
Transfer pricing documents and master file	92D	171	Form 56
Transfer pricing report	92E	172	Form 48
Rates on a non resident's dividend, interest, royalty and fees	115A	207	20% of the gross amount
Concessional rate for domestic companies	115BAA	200	22%
MAT and MAT credit	115JB, 115JAA	206	14% from 1 Apr 2026
Return of income and due dates	139	263	Due dates in 263(1)(c)
TDS on payments to residents	194 series	393(1)	One table
TDS on payments to non residents	195	393(2), serial number 17 of the table	Form 144
Grossing up	195A	393(10)	Net of tax contracts
Lower or nil deduction certificate	197	395(1)	Form 128
Quarterly TDS statements	200(3)	397(3)(b)	Forms 138, 140, 144
Remittance information and certificate	195(6)	397(3)(d)	Forms 145 and 146
Interest on TDS default	201(1A)	398(3)(a)	1% and 1.5% a month
Late fee on TDS statements	234E	427	INR 200 a day
Advance tax and interest	211, 234B, 234C	408, 424, 425	Same four dates
Country by country report	286	511	Forms 58 to 60
Repeal and savings	Not applicable	536	Keeps the 1961 Act for earlier years

Many old sections became serial numbers inside a table, so cite both. Section 195 is now serial number 17 of the table in section 393(2), per the guidance note for Form 145. One new section can also replace several old ones, as section 159 does for sections 90 and 90A.

Which income tax forms changed for a foreign owned company?

Almost all of them changed. The Income Tax Rules, 2026 cut the forms from 399 to 190 and renumbered them. Form 3CEB is now Form 48, and Forms 3CA, 3CB and 3CD merged into Form 26. Form 27Q is Form 144, Forms 15CA and 15CB are Forms 145 and 146, and Form 10F is Form 41.

The department lists all 190 forms beside their old numbers on the page "FAQs and Guidance Notes on Forms as per Income Tax Rules, 2026". Each form has a guidance note, and the rule numbers below come from those notes.

Old form (1962 Rules)	New form (2026 Rules)	What it is	2025 Act section (2026 rule)
3CA, 3CB, 3CD	26	Tax audit report and statement of particulars	63 (rule 47)
3CEB	48	Accountant's report on international transactions	172 (rule 85)
3CEAA	56	Master file	171 (rule 123)
3CEAB	57	Intimation by the designated entity for the master file	171
3CEAC	58	Intimation by an Indian entity of a group with a foreign parent	511
3CEAD	59	Country by country report	511
3CEAE	60	Intimation on behalf of the group	511
3CEFA, 3CEFB, 3CEFC	49	Application to opt for safe harbour	167
3CED, 3CEDA	51	Application for an advance pricing agreement	168
29B	66	Report on book profit for MAT	206(1) (rule 137)
10F	41	Information from a non resident claiming treaty relief	159(8)(b) (rule 75)
10FA, 10FB	42, 43	Application for, and issue of, an Indian residence certificate	159
13	128	Application for a lower or nil deduction certificate	395(1) (rule 213)
15E	129	Payer's application to fix the taxable part of a payment	395(2) (rule 214)
24Q, 26Q	138, 140	Quarterly TDS statements, salary and residents	397(3)(b)
27Q	144	Quarterly TDS statement, non residents	397(3)(b) (rule 219)
16, 16A	130, 131	TDS certificates	395, 395(4)(a) (rule 215)
15CA	145	Information on a payment to a non resident	397(3)(d) (rule 220)
15CB	146	Accountant's certificate for a payment to a non resident	397(3)(d) (rule 220)
49C	162	Annual statement of a liaison office	505 (rule 234)

Existing PAN and TAN numbers stay valid (Q4.5). Two transfer pricing forms have no old equivalent. Form 46 records an option under section 166(9) on arm's length price, and Form 54 renews an advance pricing agreement. CBDT says the company return form for tax year 2026-27 will be notified before the due date (Q3.12).

What changes for payments to the foreign parent?

The tax stays the same, but the sections and forms change. From 1 Apr 2026, TDS on a royalty, fee, interest or dividend paid to the parent sits in section 393(2). The rate is in section 207 and treaty relief in section 159. The forms are 41, 145, 146, 144 and 131.

Section 207 taxes a non resident's dividends, royalty, technical fees and interest on foreign currency loans at 20 percent of the gross amount. Surcharge and 4 percent cess sit on top. Section 207(5) allows no expenses against that income, the same rule as section 115A.

The treaty rate usually wins. Section 159(4) applies the Act only where it is more beneficial. To claim the treaty, the parent needs a tax residency certificate (TRC) under section 159(8) and must file Form 41 online. The guidance note for Form 41 says treaty benefit "is available only with filing of Form 41". PAN is optional, and one filing covers a tax year.

Form 145 replaces Form 15CA and is filed before the money leaves India. Its four parts work as before:

1. Part A covers a taxable payment of up to INR 5,00,000 in the tax year.
2. Part B covers a larger taxable payment backed by a certificate under section 395(1) or 395(2).
3. Part C covers a larger taxable payment backed by an accountant's certificate in Form 146.
4. Part D covers a payment that is not chargeable to tax.

Form 146 replaces Form 15CB. A Chartered Accountant certifies the nature of the payment, the treaty article, the TRC and Form 41 details, and the TDS rate. Some payments need no Form 145 at all, such as those under the specified purpose codes. A Form 145 default can cost INR 1,00,000 under section 462.

Payment to the foreign parent	Source rule and TDS section	Rate under the Act before treaty	India US treaty rate	Forms from 1 Apr 2026
Dividend	9(4); 393(2)	20% plus surcharge and cess, section 207(1)	15% if the parent owns at least 10% of voting stock, else 25% (Article 10)	41, 145 Part C, 146, 144, 131
Interest on a foreign currency loan	9(5); 393(2)	20% plus surcharge and cess, section 207(1)	10% if a bank or similar financial institution owns the interest, else 15% (Article 11)	41, 145 Part C, 146, 144, 131
Royalty for brand, software or technology	9(6); 393(2)	20% plus surcharge and cess, section 207(2)	15% (Article 12)	41, 145 Part C, 146, 144, 131
Technical or management fees	9(7); 393(2)	20% plus surcharge and cess, section 207(2)	15% if "included services" under Article 12, else often not taxable	41, 145 Part C or D, 146, 144, 131
Payment not chargeable to tax in India	Not applicable	Nil	Not needed	145 Part D, or none for an exempt purpose code

Treaty rates come from the India US treaty text of 12 Sep 1989 published by the US Internal Revenue Service. Other treaties differ, and our planned India Singapore treaty guide covers that corridor.

Three rules carry over in substance. Section 393(10) grosses up a payment where the Indian company bears the tax. Interest on a TDS default stays at 1 percent a month for late deduction and 1.5 percent for late deposit (Q2.13). A payment made without TDS is still disallowed until the tax is paid, as under section 40(a)(i).

Lower deduction certificates move to section 395. The parent applies in Form 128 under section 395(1), or the payer applies in Form 129 under section 395(2). An old section 197 certificate works after 1 Apr 2026 only if it was issued for projected receipts of tax year 2026-27 (Q2.12). Our planned guide to Form 128 for non residents covers the application.

For the full withholding picture, see our TDS guide for payments to non residents. Forms 145 and 146 follow our Form 15CA and 15CB guide part by part. Dividends have their own planned article on the dividend from an Indian subsidiary to its foreign parent.

What changes for transfer pricing?

The substance stays and the numbers move. Sections 92 to 92F of the 1961 Act are now sections 161 to 173. The report under section 172 is Form 48 (was 3CEB), due one month before the return. Master file and country by country filings move to Forms 56 to 60 under sections 171 and 511.

Section 161 keeps the arm's length rule for international transactions, and section 162 defines an associated enterprise (AE). Section 165 sets the methods and a tolerance range of up to 3 percent. Section 171 requires the documents and master file, and section 172 requires the report.

Form 48 reports each transaction in a set format across six parts, A to F. The guidance note says taxpayers file about 44,000 such reports a year. The Form 48 FAQs put the due date at one month before the return due date under section 263(1). For a company with international transactions, that means 31 Oct 2027 for tax year 2026-27. Our Form 3CEB guide explains the content that Form 48 carries forward.

The master file tests did not change. Part A of Form 56 is due from every constituent entity of an international group, whatever its size. Part B applies when group revenue exceeds INR 500 crore and international transactions exceed INR 50 crore, or intangible transactions exceed INR 10 crore. The country by country report (CbCR) applies above INR 6,400 crore of group revenue. Our master file and CbCR guide walks through each form.

Filing	Old form	New form	Who files	Due for tax year 2026-27
Transfer pricing report	3CEB	48	Every person with an international transaction	31 Oct 2027
Master file, Part A	3CEAA	56	Every constituent entity of an international group	30 Nov 2027
Master file, Part B	3CEAA	56	Groups above the INR 500 crore and transaction tests	30 Nov 2027
Designated entity intimation	3CEAB	57	Groups with more than one Indian entity	30 days before Form 56
CbCR intimation	3CEAC	58	Indian entity of a group above INR 6,400 crore with a foreign parent	Two months before Form 59 is due
Country by country report	3CEAD	59	Parent or alternate reporting entity	12 months after the reporting year ends

Sources: guidance notes for Forms 48 and 56 (read 27 Sep 2026).

The Budget speech of 1 Feb 2026 (paragraphs 125 to 127) announced a new safe harbour for IT services. It puts software development, IT enabled services and knowledge process outsourcing into one "Information Technology Services" category. It sets one margin of 15.5 percent and raises the threshold from INR 300 crore to INR 2,000 crore. Approval will be automated and can run for five years.

The Income Tax Rules, 2026, notified on 20 Mar 2026, now carry an IT services category under section 167. Under the Form 49 FAQs, an IT services company opts for five consecutive tax years. It files Form 49 by 30 June after the first of them. Read the margin and threshold in the notified rule before you reprice, since the FAQs do not restate them.

Paragraph 128 added a two year fast track for IT services APAs. Our safe harbour guide explains the older margins.

From tax year 2026-27, a late Form 48 attracts a fee under section 428(d). It is INR 50,000 for up to one month, then INR 1,00,000. For FY 2025-26, a late Form 3CEB still falls under section 271BA of the 1961 Act, a penalty of INR 1,00,000. Our transfer pricing advisory team prepares the study and Form 48.

Did tax rates change for companies in 2026?

No base rate changed. The Finance Bill, 2026 memorandum keeps 22 percent under section 200 and 25 or 30 percent for other domestic companies. Foreign companies stay at 35 percent. The change is MAT, cut to 14 percent from 1 Apr 2026 and made a final tax with no new credit.

Taxpayer	Base rate (%)	Surcharge (%)	Cess (%)	Where the rate sits
Domestic company under the 22% option	22	10 flat	4	Section 200
Domestic company, turnover up to INR 400 crore in FY 2024-25	25	7 above INR 1 crore; 12 above INR 10 crore	4	Finance Act, 2026
Other domestic company	30	7 above INR 1 crore; 12 above INR 10 crore	4	Finance Act, 2026
Foreign company, such as a branch or project office	35	2 above INR 1 crore; 5 above INR 10 crore	4	Finance Act, 2026
Non resident's dividend, interest, royalty or fees	20	As for the recipient	4	Section 207
MAT on book profit, from 1 Apr 2026	14	As for the company	4	Section 206

Sources: Finance Bill, 2026 memorandum, which keeps the FY 2025-26 rates for tax year 2026-27. Also the MAT and AMT page and the section 207 page (read 27 Sep 2026). The effective rate under the 22 percent option is 25.168 percent.

Many Indian subsidiaries of foreign groups already use the 22 percent option, first given in section 115BAA. Section 200 says the option, once exercised, applies to later tax years and cannot be withdrawn. Section 536(2)(f) deems an option exercised under the 1961 Act to be exercised under the matching provision of the 2025 Act. So an existing section 115BAA option carries into section 200, and no fresh option is needed.

MAT is the real change. The Budget speech (paragraph 143) and the department's MAT and AMT page set out four moves:

1. The MAT rate in section 206 falls from 15 percent to 14 percent of book profit.
2. MAT becomes a final tax from 1 Apr 2026, and no new MAT credit arises.
3. A domestic company can use old MAT credit only after moving to section 200, capped at 25 percent of the tax payable under that regime.
4. A foreign company can keep using old credit where its regular tax exceeds MAT.

Old credit survives the transition and runs for 15 years from the year it arose (Q2.25, Q2.26). A domestic company sitting on MAT credit under the old regime should model a move to section 200 now. Our corporate tax rates guide has worked comparisons.

One wording point can confuse. The Budget 2026 FAQs say the MAT amendment applies "in relation to the tax year 2025-26 and subsequent tax years". FY 2025-26 is not a tax year under the 2025 Act. The department's Tax rates page keeps MAT at 15 percent under section 115JB for AY 2026-27. Its MAT and AMT page applies 14 percent from tax year 2026-27. So FY 2025-26 book profit bears 15 percent.

Buybacks changed too. From 1 Apr 2026, buyback consideration is capital gains for every shareholder. A promoter that is not a domestic company, such as a foreign parent, bears an aggregate 30 percent (Budget 2026 FAQs).

What are the due dates in tax year 2026-27?

For a foreign owned company with international transactions, the anchors are the four advance tax instalments and the quarterly TDS statements. Forms 26 and 48 fall due on 31 Oct 2027, and the return and Form 56 on 30 Nov 2027. FY 2025-26 filings under the 1961 Act run in parallel until 30 Nov 2026.

Date	Filing or payment	Law	Form
31 May 2026	TDS statements, January to March 2026	1961 Act	24Q, 26Q, 27Q
15 Jun 2026	TDS certificates for that quarter	1961 Act	16, 16A
15 Jun 2026	Advance tax, 15% of the tax	2025 Act	Challan, tax year 2026-27
31 Jul 2026	TDS statements, April to June 2026	2025 Act	138, 140, 144
15 Sep 2026	Advance tax, 45% cumulative	2025 Act	Challan
21 Oct 2026	Tax audit, FY 2025-26, no transfer pricing report (moved from 30 Sep 2026)	1961 Act; CBDT Circular No. 07/2026	3CA or 3CB, with 3CD
31 Oct 2026	Tax audit and transfer pricing report, FY 2025-26	1961 Act	3CA or 3CB with 3CD; 3CEB
31 Oct 2026	TDS statements, July to September 2026	2025 Act	138, 140, 144
21 Nov 2026	Return, FY 2025-26, no transfer pricing report (moved from 31 Oct 2026)	1961 Act; CBDT Circular No. 07/2026	ITR-6
30 Nov 2026	Return and master file, FY 2025-26, transfer pricing case	1961 Act	ITR-6, 3CEAA
15 Dec 2026	Advance tax, 75% cumulative	2025 Act	Challan
31 Jan 2027	TDS statements, October to December 2026	2025 Act	138, 140, 144
15 Mar 2027	Advance tax, 100%	2025 Act	Challan
31 May 2027	TDS statements, January to March 2027	2025 Act	138, 140, 144
31 Oct 2027	Tax audit and transfer pricing report	2025 Act	26, 48
30 Nov 2027	Return and master file, transfer pricing case	2025 Act	New return form, 56

Sources: CBDT transition FAQ Q2.19, Q3.3, Q4.32 and Q4.33; Explanation to section 44AB of the 1961 Act; CBDT Circular No. 07/2026. Also sections 263(1)(c) and 408 of the 2025 Act, and the FAQs for Forms 26, 48, 56, 131 and 144.

Monthly TDS is deposited within seven days from the end of the month, and by 30 April for tax deducted in March. Rule 218(2) of the 2026 Rules sets these dates. Form 131 is due within 15 days from the due date of the quarterly statement, under rule 215(1). That gives 15 Aug, 15 Nov, 15 Feb and 15 Jun.

The Finance Act, 2026 moved the return date for non audit business cases and trusts from 31 July to 31 August. The Budget 2026 FAQs apply this to AY 2026-27 as well. Companies are unaffected, because every company files by 31 October or 30 November. For FY 2025-26 only, Circular No. 07/2026 moved the 31 October date to 21 Nov 2026. Our planned compliance calendar for 2026-27 adds the FEMA and company law dates.

Which penalties became fees, and what interest applies?

The Finance Act, 2026 turned the penalties for a late tax audit report and a late transfer pricing report into fixed fees. They sit in clauses (c) and (d) of section 428. From 1 Apr 2026, a late Form 26 costs INR 75,000 for up to one month, then INR 1,50,000. A late Form 48 costs INR 50,000, then INR 1,00,000.

The Budget 2026 FAQs add that these fees apply automatically, without the reasonable cause defence that the old penalties allowed.

Default	1961 Act (FY 2025-26)	2025 Act (tax year 2026-27)
Tax audit report late or missing	Section 271B: 0.5% of turnover, capped at INR 1,50,000	Section 428(c) fee: INR 75,000 up to one month, INR 1,50,000 after
Transfer pricing report late or missing	Section 271BA: INR 1,00,000	Section 428(d) fee: INR 50,000 up to one month, INR 1,00,000 after
TDS not deducted	Interest 1% a month	Interest 1% a month, section 398(3)(a)
TDS deducted, not deposited	Interest 1.5% a month	Interest 1.5% a month, section 398(3)(a)
TDS statement filed late	Section 234E: INR 200 a day, capped at the TDS amount	Section 427: INR 200 a day, capped at the TDS amount
Form 15CA or 145 missing or wrong	Section 271-I: INR 1,00,000	Section 462: INR 1,00,000

In our reading, the 1961 Act penalties still apply to FY 2025-26 reports filed in 2026. Section 536 keeps the old Act for years before 1 Apr 2026.

Does the new Act change business connection and permanent establishment?

No change in substance. Income from a business connection in India is deemed to accrue in India under section 9(2)(c). The meaning of business connection, including significant economic presence and dependent agents, now sits in section 9(9). Permanent establishment (PE) still comes from the treaty, and section 159(4) applies the Act only where it is more beneficial.

The practical risks for a foreign parent are unchanged. Seconded staff, a dependent agent who concludes contracts or a fixed place used by the parent can each create a PE. Our guide on how to avoid permanent establishment risk in India covers the controls.

Residence of the parent is a separate test in section 6. A foreign company becomes resident in India if its place of effective management is in India.

What stays the same?

Most of the tax a foreign owned subsidiary pays stays the same. Company rates, TDS rates and thresholds, and tax audit thresholds did not change. Nor did the transfer pricing methods, the 3 percent range, treaty relief, TDS interest rates or advance tax dates. The 2025 Act moved these rules to new section numbers.

Item	Position under both Acts	Section, 2025 Act	Source
Base company tax rates	22%, 25%, 30%, 35%	Finance Act, 2026	Finance Bill 2026 memorandum
TDS rates and thresholds	Unchanged	392 to 394	CBDT transition FAQ
Tax audit thresholds	INR 1 crore; INR 10 crore where cash is 5% or less of receipts and of payments	63	Guidance note for Form 26
Transfer pricing tolerance range	Up to 3%	165(3)	Section 165 page
Treaty relief	More beneficial of Act or treaty, with a TRC	159(4), 159(8)	Section 159 page
Interest on TDS default	1% and 1.5% a month	398(3)(a)	CBDT transition FAQ Q2.13
Company return due dates	31 Oct; 30 Nov with transfer pricing	263(1)(c)	CBDT transition FAQ Q3.3
Master file and CbCR thresholds	INR 500, 50 and 10 crore; INR 6,400 crore	171, 511	Guidance note for Form 56

What changed in 2026

The table lists each 2026 change that a foreign owned subsidiary should build into its tax calendar and contracts.

Area	Old rule	New rule	Date	Instrument
Governing law	Income Tax Act, 1961	Income Tax Act, 2025	1 Apr 2026	Act 30 of 2025, sections 1 and 536
Year label	Previous year and assessment year	Tax year	1 Apr 2026	Section 3
Forms	399 forms, 1962 Rules	190 forms, renumbered	1 Apr 2026	Income Tax Rules, 2026
Remittance forms	15CA and 15CB	145 and 146	Money sent from 1 Apr 2026	Rule 220
Treaty claim	Form 10F	Form 41	1 Apr 2026	Section 159(8), rule 75
MAT rate	15% of book profit	14%, final tax	1 Apr 2026	Finance Act, 2026
MAT credit	New credit arose each year	No new credit; domestic companies use old credit only under section 200, capped at 25% of tax	1 Apr 2026	Finance Act, 2026
Late tax audit report	Penalty under section 271B	Fee of INR 75,000 or INR 1,50,000	1 Apr 2026	Finance Act, 2026, section 428(c)
Late transfer pricing report	Penalty of INR 1,00,000	Fee of INR 50,000 or INR 1,00,000	1 Apr 2026	Finance Act, 2026, section 428(d)
Revised return	9 months from year end	12 months, fee of INR 1,000 or INR 5,000 after 9 months	1 Mar 2026 for AY 2026-27; 1 Apr 2026 for tax years	Finance Act, 2026: sections 139(5) and 234-I (1961 Act); sections 263(5) and 428(b) (2025 Act)
FY 2025-26 audit report and return, no transfer pricing report	30 Sep 2026 and 31 Oct 2026	21 Oct 2026 and 21 Nov 2026; transfer pricing cases keep 31 Oct and 30 Nov 2026	28 Sep 2026	CBDT Circular No. 07/2026
Buyback	Deemed dividend	Capital gains; 30% aggregate for promoters other than domestic companies	1 Apr 2026	Finance Act, 2026
Safe harbour for IT services	Separate categories, INR 300 crore threshold	One category; announced at 15.5% margin and INR 2,000 crore threshold; five tax years per option	Announced 1 Feb 2026; rules notified 20 Mar 2026	Budget speech, paragraphs 125 to 127; Income Tax Rules, 2026
Liaison office statement	Form 49C within 8 months of the year end (60 days before 7 Feb 2025), rule 114DA	Form 162 within 8 months of the tax year end	Tax year 2026-27	Rule 234

Worked example

Take a hypothetical US owned subsidiary, IndiaCo Private Limited. It provides software development services to its US parent at cost plus 15 percent. It pays the parent a royalty for the group software platform, and it opted for the 22 percent regime years ago. Group revenue is INR 900 crore.

The FY 2025-26 figures are:

1. Operating cost, including the royalty: INR 34,80,00,000.
2. Mark up at 15 percent: INR 5,22,00,000.
3. Revenue from the parent: INR 40,02,00,000.
4. Royalty credited on 31 Mar 2026 and paid on 20 May 2026: INR 1,20,00,000.
5. Tax at 25.168 percent on INR 5,22,00,000 of profit: INR 1,31,37,696.

A tax audit applies because turnover is above INR 1 crore. The service fee and royalty are international transactions, so a transfer pricing report is due. Those transactions total INR 41.22 crore, below the INR 50 crore test, so IndiaCo files only Part A of the master file. Group revenue is under INR 6,400 crore, so no CbCR form applies, and MAT does not apply under the 22 percent regime.

Royalty TDS	Under the Act (INR)	Under the India US treaty (INR)
Royalty credited	1,20,00,000	1,20,00,000
Rate	21.216% (20% plus 2% surcharge plus 4% cess)	15%
TDS	25,45,920	18,00,000
Extra TDS if the TRC and treaty form are missing	7,45,920	Not applicable
TDS if the contract is net of Indian tax (grossed up royalty 1,41,17,647)	Not applicable	21,17,647
Extra tax if no TDS is deducted (royalty disallowed at 25.168%)	30,20,160	30,20,160

The transition rules decide the forms for this one royalty. IndiaCo credited it on 31 Mar 2026, so it deducts TDS under section 195 of the 1961 Act. The parent's Form 10F and TRC for FY 2025-26 should be on file before that credit.

IndiaCo deposits the TDS by 30 Apr 2026, reports it in Form 27Q by 31 May 2026 and issues Form 16A by 15 Jun 2026. The money leaves India on 20 May 2026, so the remittance needs Form 145 Part C and Form 146. No second TDS applies on payment (Q2.10).

Filing	FY 2025-26, 1961 Act	Due	Tax year 2026-27, 2025 Act	Due
Treaty documents	TRC and Form 10F	Before the first deduction	TRC and Form 41	Before the first deduction
Remittance forms	Forms 15CA and 15CB	Before money sent by 31 Mar 2026	Forms 145 Part C and 146, including the May 2026 royalty	Before each remittance
Non resident TDS statement	Form 27Q, last quarter	31 May 2026	Form 144	31 Jul, 31 Oct, 31 Jan, 31 May
TDS certificate to the parent	Form 16A	15 Jun 2026	Form 131	15 Aug, 15 Nov, 15 Feb, 15 Jun
Advance tax	Final instalment	15 Mar 2026	Four instalments	15 Jun, 15 Sep, 15 Dec 2026; 15 Mar 2027
Tax audit	Form 3CA with 3CD	31 Oct 2026	Form 26	31 Oct 2027
Transfer pricing report	Form 3CEB	31 Oct 2026	Form 48	31 Oct 2027
Master file	Form 3CEAA, Part A	30 Nov 2026	Form 56, Part A	30 Nov 2027
Return	ITR-6	30 Nov 2026	New company return form	30 Nov 2027

IndiaCo files Form 3CEB, so CBDT Circular No. 07/2026 does not move its FY 2025-26 dates. Without international transactions, its audit would fall due on 21 Oct 2026 and its return on 21 Nov 2026.

If profit stays the same in tax year 2026-27, the cumulative advance tax schedule is:

1. INR 19,70,654 by 15 Jun 2026 (15 percent).
2. INR 59,11,963 by 15 Sep 2026 (45 percent).
3. INR 98,53,272 by 15 Dec 2026 (75 percent).
4. INR 1,31,37,696 by 15 Mar 2027 (100 percent).

The safe harbour trade looks like this. At the 15.5 percent margin announced in the Budget speech, the same costs give a mark up of INR 5,39,40,000. That is INR 17,40,000 more profit and INR 4,37,923 more tax than at 15 percent. In return, the tax officer accepts the price without a transfer pricing audit, if IndiaCo meets the conditions of the notified rule.

Common mistakes

Check for these nine errors now.

1. Filing the FY 2025-26 tax audit on Form 26. Form 26 starts with tax year 2026-27. Fix: file Forms 3CA or 3CB with 3CD (Q4.32).
2. Assuming Form 3CEB is due with the return. It is due a month earlier, on 31 Oct 2026. Fix: diarise 31 Oct 2026 for Form 3CEB and 31 Oct 2027 for Form 48.
3. Using Forms 15CA and 15CB for an old invoice paid after 31 Mar 2026. The remittance date decides the form. Fix: file Forms 145 and 146 for money sent from 1 Apr 2026.
4. Deducting TDS twice on a March accrual paid in April. Tax deducted on credit covers the payment. Fix: deduct once, per CBDT FAQ Q2.10.
5. Selecting AY 2026-27 on a challan for FY 2026-27 advance tax. The credit lands in the wrong year. Fix: select "Tax Year 2026-27" (Q2.23).
6. Skipping Form 41 because the parent has a PAN. Treaty benefit depends on Form 41 and the TRC. Fix: have the parent file Form 41 for each tax year before the first payment.
7. Planning to use MAT credit while staying in the old regime. A domestic company now needs to be under section 200 to use it. Fix: model the move before the next advance tax date.
8. Leaving 1961 section numbers in intercompany contracts. Clauses citing sections 195, 195A or 90 point to repealed text for future years. Fix: cite sections 393(2), 393(10) and 159.
9. Applying the 21 Oct 2026 extension to a transfer pricing case. CBDT Circular No. 07/2026 covers only audited cases without a transfer pricing report. Fix: keep 31 Oct 2026 for Forms 3CA, 3CD and 3CEB, and 30 Nov 2026 for the return.

What should a finance team update first?

Work through these steps in order before the next quarterly TDS date.

1. Map every recurring payment to the parent and group companies to its 2025 Act section, rate basis and forms.
2. Collect the parent's TRC for tax year 2026-27 and have the parent file Form 41 before the first payment.
3. Switch the remittance workflow to Forms 145 and 146 for all money sent from 1 Apr 2026.
4. Update the TDS software and ERP to Forms 138, 140 and 144 and to the tax year field on challans.
5. Check the period on each lower deduction certificate, and file Form 128 or Form 129 where a gap exists.
6. Amend intercompany agreements so that tax clauses cite sections 159, 161, 393(2) and 393(10).
7. Agree a FY 2025-26 tax audit date on Forms 3CA and 3CD: by 21 Oct 2026, or by 31 Oct 2026 with Form 3CEB.
8. Book Form 3CEB for 31 Oct 2026 and Form 48 for 31 Oct 2027, with the study ready a month earlier.
9. Rerun the MAT position at 14 percent and decide whether moving to section 200 releases old MAT credit.
10. Compare the intercompany IT services mark up with the notified safe harbour margin. File Form 49 by 30 June after the first tax year if you opt in.

To have us map your payments and filings to the new sections, send last year's Form 3CEB through our contact page.

Frequently Asked Questions

Is the Income Tax Act, 1961 fully repealed?+

Yes. Section 536 of the Income Tax Act, 2025 repeals the 1961 Act from 1 Apr 2026 but saves it for tax years that began before that date. Assessments, appeals, returns and penalties for FY 2025-26 and earlier years continue under the old Act. Old circulars stay valid where they are consistent with the new Act, under section 536(2)(j).

Do PAN and TAN numbers change under the new Act?+

No. Existing PAN and TAN numbers stay valid (CBDT transition FAQ Q4.5). The new application forms, Forms 93 to 96 for PAN and Forms 134 and 135 for TAN, apply only to fresh applications from 1 Apr 2026. A new foreign shareholder applies for PAN in Form 95 or Form 96, which replaced Form 49AA.

Which return form does a company use for FY 2025-26?+

A company files ITR-6 under the 1961 Act for AY 2026-27 (CBDT transition FAQ Q3.5 and Q3.6). The due date is 30 Nov 2026 where a transfer pricing report applies. For other companies, CBDT Circular No. 07/2026 moved it from 31 Oct 2026 to 21 Nov 2026. For tax year 2026-27, the company return is a new form under the Income Tax Rules, 2026, which CBDT says it will notify before the due date (Q3.12).

When is Form 3CEB due for FY 2025-26?+

Form 3CEB for FY 2025-26 is due on 31 Oct 2026, one month before the 30 Nov 2026 return date. Section 92E of the 1961 Act still governs it through section 536. From tax year 2026-27 the report becomes Form 48 under section 172, due on 31 Oct 2027 for a company.

When is the first advance tax instalment under the new Act?+

The first instalment for tax year 2026-27 fell due on 15 Jun 2026, and CBDT says it arises and is paid under the new Act (FAQ Q2.19). The later dates are 15 Sep 2026, 15 Dec 2026 and 15 Mar 2027, at 45, 75 and 100 percent cumulative. Select "Tax Year 2026-27" on each challan.

What is Form 144?+

Form 144 is the quarterly TDS statement for payments other than salary to non residents and foreign companies. It replaced Form 27Q from April 2026, under section 397(3)(b) and rule 219. The due dates are 31 Jul, 31 Oct, 31 Jan and 31 May. A late statement attracts a fee of INR 200 a day under section 427, capped at the TDS amount.

What replaced Form 10F?+

Form 41 replaced Form 10F. A non resident files it online under section 159(8) and rule 75 to claim treaty relief, with a TRC from its home country. The guidance note says treaty benefit is available only with Form 41 on file. PAN is optional, and one filing covers one tax year.

When is Part C of Form 145 needed?+

Part C applies when a taxable payment to a non resident exceeds INR 5,00,000 in the tax year and the payer holds no certificate under section 395. The payer first obtains a Chartered Accountant's certificate in Form 146. Both forms go on the income tax portal before the money leaves India.

Is a section 197 certificate still valid after 1 Apr 2026?+

Only in one case. CBDT says a lower or nil deduction certificate under section 197 of the 1961 Act stays valid from 1 Apr 2026 if it was issued for projected receipts of tax year 2026-27 (FAQ Q2.12). Otherwise the payee applies again in Form 128 under section 395(1).

What is the MAT rate for tax year 2026-27?+

MAT is 14 percent of book profit, plus surcharge and cess, under section 206 as amended by the Finance Act, 2026. MAT is now a final tax, and no new credit arises from 1 Apr 2026. A domestic company under section 200 is outside MAT. So, as a rule, is a foreign company from a treaty country without a PE in India.

Can a foreign company still use its MAT credit?+

Yes. The department's MAT and AMT page and the Budget 2026 FAQs say a foreign company can keep setting off old MAT credit where its regular tax exceeds MAT in the year. The credit still lapses 15 years after it first arose. Domestic companies face a tighter rule tied to section 200.

What is the fee for a late tax audit report under the new Act?+

For tax year 2026-27 onwards, a late Form 26 attracts a fee under section 428(c). It is INR 75,000 for a delay of up to one month and INR 1,50,000 after that. The fee applies automatically. FY 2025-26 reports remain under section 271B of the 1961 Act.

Is the tax audit threshold different under section 63?+

No. Section 63 keeps the section 44AB thresholds. A business needs a tax audit above INR 1 crore of turnover, or INR 10 crore where cash receipts and cash payments are each 5 percent or less. Professionals need one above INR 50 lakh of receipts. The report is Form 26.

How is a buyback taxed for a foreign parent from 1 Apr 2026?+

Buyback consideration is taxed as capital gains from 1 Apr 2026, not as a deemed dividend. For a promoter that is not a domestic company, such as a foreign parent, an extra tax brings the aggregate to 30 percent (Budget 2026 FAQs). Check the treaty before the buyback, since it may change the result.

Does the new Act change the liaison office annual statement?+

Only the form and rule numbers. Form 162 under section 505 and rule 234 replaced Form 49C. The department's guidance note says it is due within eight months from the end of the tax year. Form 49C already had eight months under rule 114DA, after the Income Tax (Fourth Amendment) Rules, 2025 of 7 Feb 2025. So Form 49C for FY 2025-26 is due by 30 Nov 2026. The statement still needs a Chartered Accountant's annual activity certificate.

Sources

• Income Tax Department, Income Tax Act, 2025 (Act 30 of 2025, assent 21 Aug 2025) as amended by the Finance Act, 2026, read 27 Sep 2026, https://www.incometaxindia.gov.in/documents/d/guest/income_tax_act_2025_as_amended_by_fa_act_2026-pdf
• CBDT, FAQs on Interplay and Transition from the Income Tax Act, 1961 to the Income Tax Act, 2025 (updated version), April 2026, https://www.incometaxindia.gov.in/documents/81799/11848482/Updated-FQAs-on-Interplay&Transitions.pdf/e10ad2b6-9495-de90-58d3-20606d8954ae?t=1775128640970
• CBDT, FAQs on Interplay and Transition (first version), March 2026, https://www.incometaxindia.gov.in/documents/81799/11848482/FAQs-on-Interplay-and-Transition.pdf/05f80c1a-073c-a5d7-fb6f-55509242be53?t=1774082865717
• Income Tax Department, FAQs and Guidance Notes on Forms as per Income Tax Rules, 2026, read 27 Sep 2026, https://www.incometaxindia.gov.in/faqs-and-guidance-notes-on-forms-as-per-income-tax-rules-2026
• Income Tax Department, Form Mapping Guide from the Income Tax Act, 1961 to the Income Tax Act, 2025, March 2026, https://www.incometax.gov.in/iec/foportal/sites/default/files/2026-03/Guide%20to%20IT%20Act%202025%20forms.pdf
• Income Tax Department, guidance note and FAQs for Form 26, https://www.incometaxindia.gov.in/documents/d/guest/fn-26 and https://www.incometaxindia.gov.in/documents/d/guest/form-26-faqs
• Income Tax Department, guidance note for Form 41, https://www.incometaxindia.gov.in/documents/d/guest/fn-41
• Income Tax Department, guidance note and FAQs for Form 48, https://www.incometaxindia.gov.in/documents/d/guest/fn-48 and https://www.incometaxindia.gov.in/documents/d/guest/form-48-faqs
• Income Tax Department, guidance note for Form 56, https://www.incometaxindia.gov.in/documents/d/guest/fn-56
• Income Tax Department, guidance note for Form 66, https://www.incometaxindia.gov.in/documents/d/guest/fn-66
• Income Tax Department, guidance notes for Forms 128 and 129, https://www.incometaxindia.gov.in/documents/d/guest/fn-128 and https://www.incometaxindia.gov.in/documents/d/guest/fn-129
• Income Tax Department, guidance note and FAQs for Form 144, https://www.incometaxindia.gov.in/documents/d/guest/fn-144 and https://www.incometaxindia.gov.in/documents/d/guest/form-144-faqs
• Income Tax Department, guidance notes and FAQs for Forms 145 and 146, https://www.incometaxindia.gov.in/documents/d/guest/fn-145, https://www.incometaxindia.gov.in/documents/d/guest/form-145-faqs and https://www.incometaxindia.gov.in/documents/d/guest/fn-146
• Income Tax Department, guidance note and FAQs for Form 162, https://www.incometaxindia.gov.in/documents/d/guest/fn-162 and https://www.incometaxindia.gov.in/documents/d/guest/form-162-faqs
• Income Tax Department, section pages of the Income Tax Act, 2025 for sections 9, 159, 161, 165, 200, 206 and 207, read 27 Sep 2026, https://www.incometaxindia.gov.in/w/section-9-1, https://www.incometaxindia.gov.in/w/section-159-89, https://www.incometaxindia.gov.in/w/section-161-83, https://www.incometaxindia.gov.in/w/section-165-81, https://www.incometaxindia.gov.in/w/section-200-75, https://www.incometaxindia.gov.in/w/section-206-75, https://www.incometaxindia.gov.in/w/section-207-78
• Income Tax Department, MAT and AMT, read 27 Sep 2026, https://www.incometaxindia.gov.in/w/mat-and-amt
• Income Tax Department, Tax rates, read 27 Sep 2026, https://www.incometaxindia.gov.in/w/tax-rates%E2%80%8B
• Income Tax Department, FAQs on Budget 2026 (updated), February 2026, https://www.incometaxindia.gov.in/documents/20117/15766092/FAQs-Budget-2026+Updated.pdf/daf54d14-aca9-c4ea-b786-598fd2f8d4c4?t=1771846962606
• Ministry of Law and Justice, Finance Act, 2026 (Act 4 of 2026), 30 Mar 2026, https://www.incometaxindia.gov.in/documents/d/guest/finance-act-2026-pdf-1
• Ministry of Finance, Budget 2026-2027 Speech, 1 Feb 2026, https://www.indiabudget.gov.in/doc/budget_speech.pdf
• Ministry of Finance, Memorandum explaining the provisions in the Finance Bill, 2026, 1 Feb 2026, https://www.indiabudget.gov.in/doc/memo.pdf
• Press Information Bureau, The Income Tax Act, 2025 to come into effect from 1st April, 2026, 1 Feb 2026, https://www.pib.gov.in/PressReleasePage.aspx?PRID=2221416
• US Internal Revenue Service, Convention between India and the United States for the avoidance of double taxation, signed 12 Sep 1989, https://www.irs.gov/pub/irs-trty/india.pdf
• Income Tax Department, section pages of the Income Tax Act, 2025 for sections 35, 263, 393, 397, 398, 408, 427, 428 and 536, read 27 Sep 2026, https://www.incometaxindia.gov.in/w/section-35-174, https://www.incometaxindia.gov.in/w/section-263-74, https://www.incometaxindia.gov.in/w/section-393-6, https://www.incometaxindia.gov.in/w/section-397-6, https://www.incometaxindia.gov.in/w/section-398-6, https://www.incometaxindia.gov.in/w/section-408-6, https://www.incometaxindia.gov.in/w/section-427-6, https://www.incometaxindia.gov.in/w/section-428-6, https://www.incometaxindia.gov.in/w/section-536-1
• Income Tax Department, sections 44AB and 234-I of the Income Tax Act, 1961, read 27 Sep 2026, https://www.incometaxindia.gov.in/w/section-44ab-38 and https://www.incometaxindia.gov.in/w/section-234i
• Income Tax Department, Return of income and Penalties under the Income Tax Law, read 27 Sep 2026, https://www.incometaxindia.gov.in/w/return-of-income and https://www.incometaxindia.gov.in/w/penalties-under-the-income-tax-law
• Income Tax Department, rule 218 of the Income Tax Rules, 2026, read 27 Sep 2026, https://www.incometaxindia.gov.in/w/rule-218-1
• Ministry of Finance, Income Tax Rules, 2026, notified 20 Mar 2026, https://www.incometaxindia.gov.in/documents/d/guest/en-notified-it-rules-2026-20-03-2026-pdf
• Income Tax Department, guidance note and FAQs for Form 49, FAQs for Forms 66 and 131, https://www.incometaxindia.gov.in/documents/d/guest/fn-49, https://www.incometaxindia.gov.in/documents/d/guest/form-49-faqs, https://www.incometaxindia.gov.in/documents/d/guest/form-66-faqs and https://www.incometaxindia.gov.in/documents/d/guest/form-131-faqs
• Income Tax Department, income tax portal latest news, read 1 Oct 2026, https://www.incometax.gov.in/iec/foportal/latest-news
• CBDT, Circular No. 07/2026, extension of timelines for audit reports and returns for AY 2026-27, 28 Sep 2026, https://www.incometax.gov.in/iec/foportal/sites/default/files/2026-09/Circular-7-2026.pdf
• Income Tax Department, rule 114DA of the Income Tax Rules, 1962, as substituted by the Income Tax (Fourth Amendment) Rules, 2025 from 7 Feb 2025, read 1 Oct 2026, https://www.incometaxindia.gov.in/w/rule-114da