Section 25A was introduced (as part of the Income-tax Act, 1961) to address the asymmetry that would otherwise arise where rent unpaid by a tenant during a PY was nevertheless included in ALV under section 23(1)(a) (reasonable expected rent) — and then, when recovered in a later year, would have to be re-included. Pre-FA 2016, the framework was fragmented across section 25A (unrealised rent recovery) and section 25B (arrears of rent received subsequently). FA 2016 consolidated both into the present unified section 25A with effect from AY 2017-18.
The substantive principle: where arrears of rent OR unrealised rent are received in a later PY, they are charged in that later PY's HP income — even if the assessee is no longer the owner of the property in the year of receipt. A flat 30% deduction is allowed under section 25A(2) — equivalent to the section 24(a) standard deduction available on regular rental.
Practitioner relevance — section 25A captures recovery scenarios commonly arising in tenant-disputes, eviction proceedings, court-decreed arrears, settlement payments at exit. The 30% deduction prevents the cumulative-recovery from being taxed at the full slab rate without expense allowance. Carry-forward of past HP losses may set off against current-year s. 25A income.
The transition to the Income-tax Act, 2025 preserves section 25A architecture.
Facts. The Department sought to apply a surcharge provision retrospectively to block-period assessments. The assessee contended that the amendment was substantive and could not have retrospective operation absent express legislative direction.
Issue. Whether amendments to taxing statutes operate prospectively unless the legislature has expressly or by necessary implication conferred retrospective effect.
HELD. The Constitution Bench reaffirmed the general rule against retrospectivity of taxing statutes. A taxing provision must be construed prospectively unless the language compels otherwise; mere insertion or substitution by amendment is not sufficient to deny vested rights.
“Of the various rules guiding how a legislation has to be interpreted, one established rule is that unless a contrary intention appears, a legislation is presumed not to be intended to have a retrospective operation.”
Relevance. Anchor authority for any argument that an amendment to a charging or computational provision must apply only from the AY notified — useful in transitional disputes around FA 2025 and the 1961 → 2025 changeover.
▸ Commissioner of Income-tax v. Excel Industries Ltd. (2013) 358 ITR 295 ; (2014) 2 SCC 1 (Supreme Court)
Facts. The assessee, an export-oriented unit, received DEPB licences and Advance Licences. The Department sought to tax the value of these incentives on accrual at the time of issue; the assessee contended that no income accrued until the licence was actually used or sold.
Issue. When does income accrue under the mercantile system — at the moment a right is created, or at the moment the right becomes enforceable as a debt?
HELD. Income accrues only when there is a corresponding liability of the other party. Mere creation of a contingent or unmatured right does not amount to accrual; the right must crystallise into a debt before tax incidence.
“Income accrues when there arises in favour of the assessee a debt — when there is a corresponding liability of the other party to pay the amount. It is not enough that the right has come into being; the right must ripen into a debt.”
Relevance. Anchor for accrual-vs-receipt timing disputes under section 5 / section 145 — relevant for retention monies, export incentives, contingent claim settlements, milestone-based contracts.
Facts. Section 52(2) (since deleted) deemed sale consideration to be FMV where FMV exceeded the declared consideration by 15%. The Department applied it on a literal reading even when the assessee had not in fact received more than the declared price.
Issue. Whether a deeming provision in a charging schema can be construed literally where its plain reading produces a result manifestly contrary to legislative object.
HELD. The Court read down section 52(2) to apply only where the assessee had actually received consideration in excess of the declared sum. A literal construction yielding absurd or unjust results must yield to an object-based interpretation; the CBDT's contemporaneous Circular No. 96 was held binding on the Revenue.
“It is well settled that a literal construction of a statutory provision ought not to be adopted if it produces a manifestly unjust result… Where a literal construction creates an anomaly, the courts will adopt that construction which avoids the anomaly.”
Relevance. Anchor authority for purposive construction of deeming fictions across the 1961 Act — applies wherever a deeming clause (e.g., s. 50C, s. 56(2)(x), s. 2(22)(e)) yields a result contrary to legislative purpose.
▸ Commissioner of Income-tax v. B.C. Srinivasa Setty (1981) 128 ITR 294 ; (1981) 2 SCC 460 (Supreme Court)
Facts. The assessee transferred goodwill of a self-generated nature. The Department sought to tax the consideration as capital gains; the assessee contended that no cost of acquisition could be ascertained, hence the computation provisions failed.
Issue. Whether capital gains arises where the asset has no ascertainable cost of acquisition — i.e., whether the charging provision can be invoked independently of a workable computation provision.
HELD. The charging section and the computation provisions form an integrated code; if the computation provisions cannot apply (because the cost is incapable of ascertainment), the charge itself fails. Self-generated goodwill is not taxable as capital gains.
“The charging section and the computation provisions together constitute an integrated code. When there is a case to which the computation provisions cannot apply at all, it is evident that such a case was not intended to fall within the charging section.”
Relevance. Anchor for the 'charge fails when computation fails' doctrine — useful in valuation impasses, self-generated assets, and computational ambiguity (though now largely overtaken by section 55(2)(a)(i) deeming cost as nil).
▸ Mathuram Agrawal v. State of Madhya Pradesh (1999) 8 SCC 667 ; (2000) 1 SCR 1 (Supreme Court)
Facts. A municipal levy was challenged on the ground that the charging provision did not clearly specify the rate, the persons charged, and the measure of tax.
Issue. Whether a tax can be imposed in the absence of a clear, unambiguous charging provision identifying the subject, measure, rate, and incidence.
HELD. Article 265 demands that tax be levied only by clear authority of law. The four components — taxable event, person, rate, and measure — must be clearly discernible from the charging provision; ambiguity is fatal to the levy.
“The intention of the Legislature in a taxation statute is to be gathered from the language of the provisions, particularly when the language is plain and unambiguous. In a taxing Act it is not possible to assume any intention or governing purpose other than what is given expression to.”
Relevance. Foundational authority on the rigour required of charging sections — underpins arguments that ambiguous deeming fictions, surcharge formulas, and rate prescriptions must be strictly construed.
CBDT CIRCULARS — ECOSYSTEM
▸ CBDT Circular No. 14(XL-35) of 1955 dated 11 April 1955
Subject. Duty of officers to assist assessees in claiming and securing relief
Substance. Foundational circular directing that the AO should not exploit assessee ignorance to deny legitimate reliefs; officer is required to draw attention to refunds or reliefs to which the assessee is entitled. The circular has been judicially noted in several appellate decisions and remains operative for first-appellate practice.
Substance. Explained the FA 1987 / FA 1989 amendments unifying the previous year with the financial year preceding the AY, including transitional provisions for assessees with different accounting years. Useful in any controversy on the timing of accrual / chargeability for early post-1989 AYs.
▸ CBDT Circular No. 5 of 2014 dated 11 February 2014
Subject. Section 14A — dis-allowance even where no exempt income earned (since modulated)
Substance. Initially directed AOs to apply Rule 8D disallowance under section 14A even where no exempt income was earned in the year; subsequently modulated by Cheminvest (Del HC) and Maxopp (SC). FA 2022 amendment to section 14A re-asserted the position but remains under litigation.
WORKED EXAMPLES
Illustration — Illustration 1 — Unrealised rent recovered after eviction
Facts. E owned a let-out flat in Pune; tenant defaulted Rs 4 L over PYs 2020-21 to 2023-24. Court-decreed eviction + recovery; E receives Rs 4 L in PY 2024-25 (5 months after E sold the property).
Computation.
S. 25A(1) — Unrealised rent Rs 4 L received in PY 2024-25 → deemed HP income for PY 2024-25.
E is no longer owner (sold property) — s. 25A(1) still applies.
STATUTORY ARCHITECTURE — 18-ROW MAP
01. Section & marginal note
Section 25A — 'Special provision for arrears of rent and unrealised rent' — Chapter IV-B.
02. Sub-section structure
(1) Charge of arrears / unrealised rent in year of receipt; (2) 30% deduction.
03. Operative trigger
Receipt of arrears of rent OR unrealised rent (previously not taxed due to vacancy / non-payment) in a later PY.
04. Persons affected
Property owners (current or past); even if assessee is no longer owner in year of receipt.
05. Time anchor — PY / AY
PY of receipt — different from PY of original rental period.
06. Income anchor
HP head — even if assessee is not current owner.
07. Residential-status nexus
Standard.
08. Rate / charge mechanism
Slab rate; 30% deduction available.
09. TDS / TCS interaction
S. 194-I TDS on arrears payment by tenant.
10. Advance-tax obligation
On net arrears income in receipt year.
11. Presumptive provisions
Not applicable.
12. Exemption / deduction mechanism
30% under s. 25A(2).
13. Refund / credit
Standard.
14. Return / disclosure reporting
ITR Schedule HP — arrears row.
15. Penalty exposure
S. 270A under-reporting.
16. Prosecution exposure
S. 277 false statement.
17. Cross-statute interplay
Limitation Act, 1963 — arrears recovery time-bar; Civil Procedure Code.
18. Repeal & saving — 1961 → 2025
Preserved.
HISTORICAL CONTEXT
Section 25A was introduced (as part of the Income-tax Act, 1961) to address the asymmetry that would otherwise arise where rent unpaid by a tenant during a PY was nevertheless included in ALV under section 23(1)(a) (reasonable expected rent) — and then, when recovered in a later year, would have to be re-included. Pre-FA 2016, the framework was fragmented across section 25A (unrealised rent recovery) and section 25B (arrears of rent received subsequently). FA 2016 consolidated both into the present unified section 25A with effect from AY 2017-18.
The substantive principle: where arrears of rent OR unrealised rent are received in a later PY, they are charged in that later PY's HP income — even if the assessee is no longer the owner of the property in the year of receipt. A flat 30% deduction is allowed under section 25A(2) — equivalent to the section 24(a) standard deduction available on regular rental.
Practitioner relevance — section 25A captures recovery scenarios commonly arising in tenant-disputes, eviction proceedings, court-decreed arrears, settlement payments at exit. The 30% deduction prevents the cumulative-recovery from being taxed at the full slab rate without expense allowance. Carry-forward of past HP losses may set off against current-year s. 25A income.
The transition to the Income-tax Act, 2025 preserves section 25A architecture.
FINANCE ACT AMENDMENT TIMELINE
■ Pre-FA 2016 — Section 25A (unrealised) + Section 25B (arrears) + Section 25AA — fragmented.
■ FA 2016 — Consolidated into present Section 25A; effective AY 2017-18.
■ FA 2017-2025 — Minor refinements.
■ Income-tax Act, 2025 — Section 25A successor, operative 1-4-2026.
JUDICIAL EVOLUTION — VERIFIED LANDMARK AUTHORITIES
▸ Commissioner of Income-tax v. Vatika Township Pvt. Ltd. (2014) 367 ITR 466 ; (2015) 1 SCC 1 (Supreme Court — 5-Judge Constitution Bench)
Facts. The Department sought to apply a surcharge provision retrospectively to block-period assessments. The assessee contended that the amendment was substantive and could not have retrospective operation absent express legislative direction.
Issue. Whether amendments to taxing statutes operate prospectively unless the legislature has expressly or by necessary implication conferred retrospective effect.
HELD. The Constitution Bench reaffirmed the general rule against retrospectivity of taxing statutes. A taxing provision must be construed prospectively unless the language compels otherwise; mere insertion or substitution by amendment is not sufficient to deny vested rights.
“Of the various rules guiding how a legislation has to be interpreted, one established rule is that unless a contrary intention appears, a legislation is presumed not to be intended to have a retrospective operation.”
Relevance. Anchor authority for any argument that an amendment to a charging or computational provision must apply only from the AY notified — useful in transitional disputes around FA 2025 and the 1961 → 2025 changeover.
▸ Commissioner of Income-tax v. Excel Industries Ltd. (2013) 358 ITR 295 ; (2014) 2 SCC 1 (Supreme Court)
Facts. The assessee, an export-oriented unit, received DEPB licences and Advance Licences. The Department sought to tax the value of these incentives on accrual at the time of issue; the assessee contended that no income accrued until the licence was actually used or sold.
Issue. When does income accrue under the mercantile system — at the moment a right is created, or at the moment the right becomes enforceable as a debt?
HELD. Income accrues only when there is a corresponding liability of the other party. Mere creation of a contingent or unmatured right does not amount to accrual; the right must crystallise into a debt before tax incidence.
“Income accrues when there arises in favour of the assessee a debt — when there is a corresponding liability of the other party to pay the amount. It is not enough that the right has come into being; the right must ripen into a debt.”
Relevance. Anchor for accrual-vs-receipt timing disputes under section 5 / section 145 — relevant for retention monies, export incentives, contingent claim settlements, milestone-based contracts.
▸ K.P. Varghese v. Income-tax Officer, Ernakulam (1981) 131 ITR 597 ; (1981) 4 SCC 173 (Supreme Court — 3-Judge Bench)
Facts. Section 52(2) (since deleted) deemed sale consideration to be FMV where FMV exceeded the declared consideration by 15%. The Department applied it on a literal reading even when the assessee had not in fact received more than the declared price.
Issue. Whether a deeming provision in a charging schema can be construed literally where its plain reading produces a result manifestly contrary to legislative object.
HELD. The Court read down section 52(2) to apply only where the assessee had actually received consideration in excess of the declared sum. A literal construction yielding absurd or unjust results must yield to an object-based interpretation; the CBDT's contemporaneous Circular No. 96 was held binding on the Revenue.
“It is well settled that a literal construction of a statutory provision ought not to be adopted if it produces a manifestly unjust result… Where a literal construction creates an anomaly, the courts will adopt that construction which avoids the anomaly.”
Relevance. Anchor authority for purposive construction of deeming fictions across the 1961 Act — applies wherever a deeming clause (e.g., s. 50C, s. 56(2)(x), s. 2(22)(e)) yields a result contrary to legislative purpose.
▸ Commissioner of Income-tax v. B.C. Srinivasa Setty (1981) 128 ITR 294 ; (1981) 2 SCC 460 (Supreme Court)
Facts. The assessee transferred goodwill of a self-generated nature. The Department sought to tax the consideration as capital gains; the assessee contended that no cost of acquisition could be ascertained, hence the computation provisions failed.
Issue. Whether capital gains arises where the asset has no ascertainable cost of acquisition — i.e., whether the charging provision can be invoked independently of a workable computation provision.
HELD. The charging section and the computation provisions form an integrated code; if the computation provisions cannot apply (because the cost is incapable of ascertainment), the charge itself fails. Self-generated goodwill is not taxable as capital gains.
“The charging section and the computation provisions together constitute an integrated code. When there is a case to which the computation provisions cannot apply at all, it is evident that such a case was not intended to fall within the charging section.”
Relevance. Anchor for the 'charge fails when computation fails' doctrine — useful in valuation impasses, self-generated assets, and computational ambiguity (though now largely overtaken by section 55(2)(a)(i) deeming cost as nil).
▸ Mathuram Agrawal v. State of Madhya Pradesh (1999) 8 SCC 667 ; (2000) 1 SCR 1 (Supreme Court)
Facts. A municipal levy was challenged on the ground that the charging provision did not clearly specify the rate, the persons charged, and the measure of tax.
Issue. Whether a tax can be imposed in the absence of a clear, unambiguous charging provision identifying the subject, measure, rate, and incidence.
HELD. Article 265 demands that tax be levied only by clear authority of law. The four components — taxable event, person, rate, and measure — must be clearly discernible from the charging provision; ambiguity is fatal to the levy.
“The intention of the Legislature in a taxation statute is to be gathered from the language of the provisions, particularly when the language is plain and unambiguous. In a taxing Act it is not possible to assume any intention or governing purpose other than what is given expression to.”
Relevance. Foundational authority on the rigour required of charging sections — underpins arguments that ambiguous deeming fictions, surcharge formulas, and rate prescriptions must be strictly construed.
CBDT CIRCULARS — ECOSYSTEM
▸ CBDT Circular No. 14(XL-35) of 1955 dated 11 April 1955
Subject. Duty of officers to assist assessees in claiming and securing relief
Substance. Foundational circular directing that the AO should not exploit assessee ignorance to deny legitimate reliefs; officer is required to draw attention to refunds or reliefs to which the assessee is entitled. The circular has been judicially noted in several appellate decisions and remains operative for first-appellate practice.
▸ CBDT Circular No. 549 dated 31 October 1989
Subject. Explanatory notes — Finance Act 1989 amendments (incl. PY unification)
Substance. Explained the FA 1987 / FA 1989 amendments unifying the previous year with the financial year preceding the AY, including transitional provisions for assessees with different accounting years. Useful in any controversy on the timing of accrual / chargeability for early post-1989 AYs.
▸ CBDT Circular No. 5 of 2014 dated 11 February 2014
Subject. Section 14A — dis-allowance even where no exempt income earned (since modulated)
Substance. Initially directed AOs to apply Rule 8D disallowance under section 14A even where no exempt income was earned in the year; subsequently modulated by Cheminvest (Del HC) and Maxopp (SC). FA 2022 amendment to section 14A re-asserted the position but remains under litigation.
WORKED EXAMPLES
Illustration — Illustration 1 — Unrealised rent recovered after eviction
Facts. E owned a let-out flat in Pune; tenant defaulted Rs 4 L over PYs 2020-21 to 2023-24. Court-decreed eviction + recovery; E receives Rs 4 L in PY 2024-25 (5 months after E sold the property).
Computation.
S. 25A(1) — Unrealised rent Rs 4 L received in PY 2024-25 → deemed HP income for PY 2024-25.
E is no longer owner (sold property) — s. 25A(1) still applies.
S. 25A(2) — 30% × Rs 4 L = Rs 1.2 L deduction.
Net s. 25A income = Rs 4 L − Rs 1.2 L = Rs 2.8 L.
Added to E's HP head in PY 2024-25.
Result. Section 25A captures unrealised rent recovery; 30% deduction; ownership status irrelevant in receipt year.
Illustration — Illustration 2 — Arrears of rent received in lump sum
Facts. F's let-out property — tenant pays Rs 3 L lump-sum arrears in PY 2024-25 relating to past PYs (rent under-paid earlier).
Computation.
S. 25A(1) — Arrears Rs 3 L → deemed HP income for PY 2024-25.
S. 25A(2) — 30% × Rs 3 L = Rs 90,000 deduction.
Net s. 25A income = Rs 2.1 L.
Result. Arrears received in lump sum — captured in receipt year; deduction available.
Illustration — Illustration 3 — Combined arrears + unrealised rent
Facts. G receives Rs 6 L total — Rs 4 L unrealised rent + Rs 2 L arrears.
Computation.
S. 25A(1) — Total Rs 6 L deemed HP income.
S. 25A(2) — 30% × Rs 6 L = Rs 1.8 L deduction.
Net Rs 4.2 L taxable.
Result. Both arrears and unrealised rent are captured under unified s. 25A framework.
Illustration — Illustration 4 — Carry-forward HP loss set-off
Facts. H has carry-forward HP losses Rs 5 L from PY 2019-20. In PY 2024-25, H receives Rs 3 L under s. 25A.
Computation.
S. 25A(1) — Rs 3 L deemed HP income.
S. 25A(2) — 30% deduction Rs 90,000.
Net Rs 2.1 L → HP head income.
Carry-forward HP loss Rs 5 L (from earlier PYs) — set off against current HP income.
Rs 2.1 L fully absorbed; remaining Rs 2.9 L HP loss carried forward.
Result. Carry-forward HP losses can absorb s. 25A income; planning lever for clients with past HP losses.
Illustration — Illustration 5 — TDS on arrears payment
Facts. J's tenant (a corporate) pays Rs 5 L arrears to J in PY 2024-25 with TDS u/s 194-I @ 10% = Rs 50,000 deducted.
Computation.
Tenant withholds TDS u/s 194-I = Rs 50,000.
J receives net Rs 4.5 L.
S. 25A(1) — gross Rs 5 L deemed HP income.
S. 25A(2) — 30% × Rs 5 L = Rs 1.5 L deduction.
Net Rs 3.5 L taxable.
J's tax — slab rate; Rs 50,000 TDS credit.
Result. TDS u/s 194-I operates on arrears payments; gross amount captured; TDS credit available.
PRACTITIONER PLANNING NOTES
■ Document tenant disputes / eviction proceedings; preserve court orders / settlement deeds.
■ Section 25A operates on RECEIPT — not on accrual; receipt-year governs.
■ 30% deduction under s. 25A(2) — automatic.
■ Carry-forward HP losses can absorb s. 25A income.
■ TDS u/s 194-I — verify tenant compliance on arrears payments.
■ Section 25A applies even if assessee is no longer owner.
■ Multi-year arrears — single receipt year captures; consider section 89 spread-back (limited applicability).
■ Tax planning — defer recovery to lower-slab PY where feasible.
■ Documentation — eviction order / arrears agreement / bank receipt — 7 years.
■ FA 2016 consolidation — apply unified section 25A; not legacy 25A / 25B / 25AA.
■ Cross-border arrears — section 195 if paid to NR.
■ Letting / vacating timeline — preserve evidence.
■ Annual practitioner review.
■ ITR Schedule HP — arrears row.
■ Section 270A under-reporting — preserve evidence of receipt year.
LITIGATION DEFENCE
■ Mathuram Agrawal strict construction.
■ K.P. Varghese object-based interpretation.
■ Vatika Township prospective amendment (FA 2016 consolidation operative AY 2017-18 onwards).
■ Excel Industries accrual-vs-receipt timing — s. 25A is RECEIPT-based.
■ BC Srinivasa Setty — if computation impossible, charge may fail.
■ Receipt year defence — preserve bank receipt / cheque encashment date.
■ 30% deduction defence — automatic; AO cannot deny.
■ Carry-forward HP loss set-off — preserve loss-bringing schedules.
■ Ownership in receipt year — s. 25A(1) makes ownership irrelevant; rebut AO's contrary stance.
■ TDS reconciliation defence — produce Form 16AA / Form 26AS.
■ Spread-back arguments — limited; primary anchor is s. 25A receipt-year rule.
■ Beneficial circulars — UCO Bank anchor.
■ Calcutta Discount Article 226 jurisdiction.
■ Pre-FA 2016 transactions — argue legacy s. 25A / 25B framework.
■ Section 273B reasonable-cause defence for procedural lapses.
■ Limitation Act — argue against time-barred recovery characterisation.
PROCEDURE
Step 1. Identify arrears / unrealised rent receipt
Cheque date / bank deposit date.
Step 2. Verify nature — arrears or unrealised
Either captures under s. 25A.
Step 3. Compute gross amount
Including TDS withheld.
Step 4. Apply s. 25A(2) — 30% deduction
Automatic.
Step 5. Net s. 25A income
Gross − 30%.
Step 6. Add to HP head for receipt PY
Even if no longer owner.
Step 7. Section 71B set-off cap consideration
If aggregate HP loss for PY.
Step 8. Carry-forward HP loss set-off
Against current s. 25A income.
Step 9. TDS u/s 194-I reconciliation
Form 26AS / AIS.
Step 10. ITR Schedule HP — arrears row
Disclose receipt + deduction.
Step 11. Section 89 spread-back consideration
Limited applicability.
Step 12. Documentation
Eviction / arrears agreement / bank receipt.
Step 13. Advance tax on net s. 25A income
Quarterly.
Step 14. Self-assessment before filing
s. 140A.
Step 15. Working papers preserved
7 years.
PRACTITIONER CHECKLIST
☐ Arrears / unrealised rent receipt date verified.
☐ Nature classified (arrears or unrealised).
☐ Gross amount documented.
☐ 30% deduction applied.
☐ Net s. 25A income computed.
☐ Receipt-year (not accrual-year) charge.
☐ Section 71B cap considered.
☐ Carry-forward HP loss set-off.
☐ TDS u/s 194-I reconciled.
☐ ITR Schedule HP populated.
☐ Section 89 spread-back evaluated.
☐ Bank receipts retained.
☐ Eviction / arrears documentation retained.
☐ Advance tax paid.
☐ Self-assessment u/s 140A.
☐ FA 2016 unified framework applied.
☐ Cross-border consideration (s. 195).
☐ Working papers 7 years.
☐ Annual practitioner update.
CROSS-REFERENCES
▸ Section 22 — HP charge.
▸ Section 23 — Annual value.
▸ Section 24 — Deductions.
▸ Section 25 — NR interest disallowance.
▸ Section 25A — THIS SECTION.
▸ Section 26 — Co-ownership.
▸ Section 27 — Deemed owner.
▸ Section 71B — Set-off cap.
▸ Section 89 — Spread-back (limited).
▸ Section 139 — Return.
▸ Section 140A — Self-assessment.
▸ Section 194-I — TDS on rent.
▸ Section 270A — Penalty.
▸ Section 273B — Reasonable cause.
▸ Form 26AS / AIS / TIS — TDS reconciliation.
▸ Form 16AA — TDS certificate.
▸ ITR Schedule HP — arrears row.
▸ Limitation Act, 1963 — recovery time-bar.
▸ Civil Procedure Code.
▸ Income-tax Act, 2025 — Section 25A (successor), operative 1-4-2026.
▸ Income-tax Act, 2025 — Section 536 (saving).