Section 80JJAA is the employment-generation incentive — 30% deduction on ADDITIONAL employee cost for THREE consecutive AYs (including the year of first employment). The policy goal — incentivise manufacturing and professional employment of low-and-medium wage workers.
Conditions: (a) Indian company / business under s. 44AB tax audit; (b) Additional employees — employee count above PY 2015-16 baseline (FA 2016 framework); (c) Salary limit Rs 25,000 per month / Rs 3 L per annum (FA 2018 enhanced); (d) Employed 240 days minimum (150 days for apparel / footwear / leather); (e) EPF participation; (f) New employee from preceding year only (no recruitment / re-recruitment); (g) Section 44AB audit prerequisite.
Practitioner significance — substantial benefit for labour-intensive industries. 30% deduction on additional employee cost for 3 years — effectively 90% over the period (cumulative). Particularly valuable for manufacturing / apparel / IT-services / professional firms. Section 80AC + Section 80A apply. Section 115BAC new regime — 80JJAA available (specific carve-out for s. 80JJAA + s. 80CCD(2) + s. 80CCH preserved).
The transition to the Income-tax Act, 2025 preserves the Chapter VI-A framework. Section 536 saving for pending matters.
FINANCE ACT AMENDMENT TIMELINE
■ FA 1998 — Section 80JJAA introduced.
■ FA 2016 — Restructured with broader scope.
■ FA 2018 — Salary cap raised to Rs 25,000 per month.
■ FA 2018 — 150-day eligibility for apparel / footwear / leather.
■ FA 2020 — Section 115BAC carve-out preserving s. 80JJAA.
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.
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.
▸ 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.
▸ 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).
▸ 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.
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.
▸ CBDT Circular No. 6 of 2019 dated 20 March 2019
Subject. Withdrawal of low-tax-effect appeals — monetary thresholds
Substance. Revised monetary thresholds for departmental appeals — ITAT (Rs 50L), HC (Rs 1 Cr), SC (Rs 2 Cr); subsequently further revised. Operates as a non-statutory limitation on the Revenue's appellate engagement, binding under section 119.
WORKED EXAMPLES
Illustration — Illustration 1 — Manufacturing company
Facts. A Ltd (Indian co; tax audit) hires 50 new workmen; each Rs 20,000 / month; total additional cost Rs 1.2 cr.
Computation.
S. 80JJAA — 30% × Rs 1.2 cr = Rs 36 L deduction.
Operative for 3 consecutive AYs.
Cumulative — Rs 36 L × 3 = Rs 1.08 cr (90% of additional cost).
Result. Substantial relief for labour-intensive industries; 90% effective over 3 years.
STATUTORY ARCHITECTURE — 18-ROW MAP
01. Section & marginal note
Section 80JJAA — Employment Generation Deduction — Chapter VI-A.
02. Sub-section structure
Per operative text + provisos.
03. Operative trigger
Eligible investment / payment / contribution / qualifying activity.
04. Persons affected
Individuals / HUFs / specified entities per section.
05. Time anchor — PY / AY
Investment / payment must be within PY; s. 139 due-date filing.
06. Income anchor
Reduces GTI to arrive at total income; post all head-wise computation.
07. Residential-status nexus
Resident-only for most; some sections (e.g., 80G) extend to all.
08. Rate / charge mechanism
Direct reduction of taxable income.
09. TDS / TCS interaction
Standard.
10. Advance-tax obligation
On net post-deduction income.
11. Presumptive provisions
Section 44AD / 44ADA — restrictions on additional VI-A deductions.
12. Exemption / deduction mechanism
Section IS the deduction provision.
13. Refund / credit
Standard refund framework.
14. Return / disclosure reporting
ITR Schedule VIA + supporting evidence (Form 12BB / receipts).
15. Penalty exposure
Section 270A on incorrect / inflated claim.
16. Prosecution exposure
Section 277 false statement.
17. Cross-statute interplay
Section 80AC + s. 139(1) timing; section 115BAC new regime restrictions.
18. Repeal & saving — 1961 → 2025
Preserved; some sections sunset for new claims.
HISTORICAL CONTEXT
Section 80JJAA is the employment-generation incentive — 30% deduction on ADDITIONAL employee cost for THREE consecutive AYs (including the year of first employment). The policy goal — incentivise manufacturing and professional employment of low-and-medium wage workers.
Conditions: (a) Indian company / business under s. 44AB tax audit; (b) Additional employees — employee count above PY 2015-16 baseline (FA 2016 framework); (c) Salary limit Rs 25,000 per month / Rs 3 L per annum (FA 2018 enhanced); (d) Employed 240 days minimum (150 days for apparel / footwear / leather); (e) EPF participation; (f) New employee from preceding year only (no recruitment / re-recruitment); (g) Section 44AB audit prerequisite.
Practitioner significance — substantial benefit for labour-intensive industries. 30% deduction on additional employee cost for 3 years — effectively 90% over the period (cumulative). Particularly valuable for manufacturing / apparel / IT-services / professional firms. Section 80AC + Section 80A apply. Section 115BAC new regime — 80JJAA available (specific carve-out for s. 80JJAA + s. 80CCD(2) + s. 80CCH preserved).
The transition to the Income-tax Act, 2025 preserves the Chapter VI-A framework. Section 536 saving for pending matters.
FINANCE ACT AMENDMENT TIMELINE
■ FA 1998 — Section 80JJAA introduced.
■ FA 2016 — Restructured with broader scope.
■ FA 2018 — Salary cap raised to Rs 25,000 per month.
■ FA 2018 — 150-day eligibility for apparel / footwear / leather.
■ FA 2020 — Section 115BAC carve-out preserving s. 80JJAA.
■ FA 2024 / 2025 — Cosmetic refinements.
■ Income-tax Act, 2025 — Section 80JJAA 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.
▸ 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.
▸ 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.
▸ 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).
▸ 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.
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.
▸ CBDT Circular No. 6 of 2019 dated 20 March 2019
Subject. Withdrawal of low-tax-effect appeals — monetary thresholds
Substance. Revised monetary thresholds for departmental appeals — ITAT (Rs 50L), HC (Rs 1 Cr), SC (Rs 2 Cr); subsequently further revised. Operates as a non-statutory limitation on the Revenue's appellate engagement, binding under section 119.
WORKED EXAMPLES
Illustration — Illustration 1 — Manufacturing company
Facts. A Ltd (Indian co; tax audit) hires 50 new workmen; each Rs 20,000 / month; total additional cost Rs 1.2 cr.
Computation.
S. 80JJAA — 30% × Rs 1.2 cr = Rs 36 L deduction.
Operative for 3 consecutive AYs.
Cumulative — Rs 36 L × 3 = Rs 1.08 cr (90% of additional cost).
Result. Substantial relief for labour-intensive industries; 90% effective over 3 years.
Illustration — Illustration 2 — Apparel manufacturing (150 days)
Facts. B Ltd (apparel) hires seasonal workers for 180 days at Rs 18,000 / month.
Computation.
S. 80JJAA — Apparel-sector carve-out — 150 days minimum.
180 days ≥ 150 → eligible.
Salary Rs 18,000 < Rs 25,000 cap → eligible.
30% × additional cost = deduction.
Result. Apparel / footwear / leather 150-day carve-out enables seasonal employment relief.
Illustration — Illustration 3 — Salary cap breach
Facts. C Ltd hires new employee at Rs 30,000 / month.
Computation.
Salary Rs 30,000 > Rs 25,000 cap (Rs 3 L p.a.).
Not within s. 80JJAA scope.
No deduction.
Result. Salary cap restrictive; structural threshold.
Illustration — Illustration 4 — 240-day requirement
Facts. D Ltd hires employee on 1-November-2024; engaged through 31-March-2025 = 151 days.
Computation.
Standard 240-day requirement.
151 days < 240 → NOT employed for sufficient period.
S. 80JJAA NOT available for that employee.
Continuing employment into next PY — 240 days from initial date can be tested in subsequent year.
Result. 240-day rule strict; timing critical.
Illustration — Illustration 5 — New regime preservation
Facts. E Ltd opts into new regime under s. 115BAC; claims s. 80JJAA.
Computation.
S. 115BAC carve-out — preserves s. 80JJAA (along with s. 80CCD(2), s. 80CCH).
New regime + s. 80JJAA combinable.
Significant new-regime advantage for labour-intensive industries.
Result. Section 80JJAA preserved under new regime; rare carve-out.
PRACTITIONER PLANNING NOTES
■ Old vs new regime — most Chapter VI-A deductions UNAVAILABLE under new regime (s. 115BAC); annual selection critical.
■ Investment / payment evidence — receipts / certificates / loan statements / premium receipts — preserved 7 years.
■ Form 12BB — Investment declaration to employer; preserves TDS-side compliance.
■ Section 80AC — Timely return filing for sectional deduction preservation.
■ Section 80A — Aggregate Chapter VI-A deduction cannot exceed GTI.
■ Section 80AB — Computation framework; some deductions on net (not gross).
■ ITR Schedule VIA — Comprehensive disclosure essential.
■ Joint-investment / joint-loan apportionment between co-borrowers / co-investors.
■ Self-funding requirement — most deductions need own-source-funded investment.
■ Cross-statute interplay — PMS / NPS / EPF Acts; SEBI Regulations; trust law for s. 80G donee.
■ Annual practitioner review — track FA changes to thresholds and conditions.
■ Section 273B reasonable-cause defence for procedural lapses.
■ Senior citizen carve-outs — preserve age / status evidence.
■ Disability / specified illness — preserve certificates.
■ Documentation — original receipts / certificates / Form 16 — retained 7 years.
LITIGATION DEFENCE
■ Strict construction — Mathuram Agrawal anchor.
■ Object-based interpretation — K.P. Varghese; deductions are beneficial — ambiguity resolves in favour.
■ Prospective amendment — Vatika Township for FA changes.
■ BC Srinivasa Setty — computation issues.
■ Excel Industries — accrual / receipt timing of investment / payment.
■ Maxopp Investment — for s. 14A interaction.
■ Investment evidence defence — produce original receipts / certificates.
■ Loan source defence — preserve loan / repayment trail.
■ Section 80AC timing defence — file return within due date.
■ Joint investment / loan apportionment.
■ Reliance Petroproducts — bona-fide claim not concealment.
■ Calcutta Discount Article 226 — for jurisdictional errors.
■ Section 273B reasonable-cause defence.
■ Beneficial circulars — UCO Bank anchor.
■ Documentation defence — Form 16 / Form 12BB / receipts / certificates.
■ Section 270A bona-fide claim defence.
PROCEDURE
Step 1. Identify eligible investment / payment
Per section's qualifying categories.
Step 2. Verify investment / payment within PY
Section 80A(1) requirement.
Step 3. Compute deductible amount
Per section's cap / formula.
Step 4. Apply section-specific conditions
All conditions strictly satisfied.
Step 5. Verify section 80AC timing (where applicable)
Return within s. 139(1) due date.
Step 6. Apply section 80A overall ceiling
Deduction not exceed GTI.
Step 7. Old vs new regime selection
Most deductions only old regime.
Step 8. Form 12BB to employer
For TDS-side recognition.
Step 9. ITR Schedule VIA populated
Section-wise disclosure.
Step 10. Joint investment apportionment
Per contribution share.
Step 11. Cross-statute compliance
PMS / NPS / EPF / SEBI / Trust Act.
Step 12. Document receipts / certificates
Original retained 7 years.
Step 13. Section 270A defence preparation
Bona-fide claim.
Step 14. Section 273B reasonable cause
For procedural lapses.
Step 15. Annual review
Track FA changes.
PRACTITIONER CHECKLIST
☐ Eligible investment / payment identified.
☐ Within PY timing verified.
☐ Deductible amount per section cap.
☐ All conditions strictly satisfied.
☐ Section 80AC timing (return within due date).
☐ Section 80A overall GTI ceiling.
☐ Old vs new regime selection done.
☐ Form 12BB to employer.
☐ Section 115BAC new regime restrictions noted.
☐ ITR Schedule VIA populated.
☐ Joint investment / loan apportionment.
☐ Cross-statute compliance verified.
☐ Original receipts / certificates 7 years.
☐ Section 270A bona-fide claim.
☐ Section 273B defence prepared.
☐ Annual FA update.
☐ Senior citizen / disability evidence.
☐ Self-funding source preserved.
☐ Client briefing on regime selection.
CROSS-REFERENCES
▸ Section 4 — Charge.
▸ Section 14 — Heads.
▸ Section 80A — General rules.
▸ Section 80AB — Computation framework.
▸ Section 80AC — Return-filing timing.
▸ Section 115BAC — New regime.
▸ Section 139 — Return.
▸ Section 270A — Penalty.
▸ Section 273B — Reasonable cause.
▸ ITR Schedule VIA.
▸ Form 12BB — Investment declaration.
▸ Income-tax Act, 2025 — Successor, operative 1-4-2026.
▸ Income-tax Act, 2025 — Section 536 (saving).
▸ Section 44AB — Tax audit.
▸ EPF & Miscellaneous Provisions Act, 1952.
▸ Section 80AC — Timing.
▸ Section 80A — General rules.