The transition to the new Income-tax framework introduced by the Finance Act, 2026 has brought significant structural changes, including the renumbering and rationalisation of Tax Deducted at Source (TDS) provisions. While the core principles governing TDS remain largely unchanged, the reclassification of sections under the new Income-tax Act, 2025 has created confusion among taxpayers, deductors, and professionals.
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Shift from Old to New TDS Framework
Under the earlier Income-tax Act, 1961, TDS provisions were primarily governed under Chapter XVII-B, covering sections such as 192 (salary), 194C (contract payments), 194J (professional fees), among others. With the implementation of the new Act, these provisions have been reorganised into a new numbering system to simplify compliance and improve structural clarity.
The objective behind this restructuring is to create a more logical grouping of provisions, reduce redundancy, and align the law with modern compliance systems, including faceless and digital tax administration.
| Sl. No. | Old Section (Income-tax Act 1961) | Nature of Payment | New Section (IT Act 2025) | Nature Code | Standard Rate | Threshold Limit |
| 1 | 192 | Salary | 392 | S01 | Slab rate | Nil |
| 2 | 192A | EPF withdrawal | 392 | S04 | 10% | ₹50,000 |
| 3 | 192B | Perquisites / ESOP | 392 | S02 | Slab rate | Nil |
| 4 | 193 | Interest on securities | 393 | NS16 | 10% | ₹10,000 |
| 5 | 194 | Dividend | 393 | NS08 | 10% | ₹5,000 |
| 6 | 194A | Interest (other than securities) | 393 | NS07 | 10% | ₹40,000 / ₹50,000 |
| 7 | 194B | Lottery / game winnings | 393 | NS19 | 30% | ₹10,000 |
| 8 | 194BB | Horse race winnings | 393 | NS21 | 30% | ₹10,000 |
| 9 | 194C | Contract / Work | 393 | NS01 | 1% / 2% | ₹30,000 / ₹1,00,000 |
| 10 | 194D | Insurance commission | 393 | NS10 | 5% | ₹15,000 |
| 11 | 194DA | Life insurance pay-out | 393 | NS22 | 5% | ₹1,00,000 |
| 12 | 194E | Payment to non-resident sportsman | 393 | NS23 | 20% | Nil |
| 13 | 194EE | NSS withdrawal | 393 | NS24 | 10% | ₹2,500 |
| 14 | 194F | Mutual fund repurchase | 393 | NS25 | 20% | Nil |
| 15 | 194G | Lottery commission | 393 | NS26 | 5% | ₹15,000 |
| 16 | 194H | Commission / Brokerage | 393 | NS04 | 5% | ₹15,000 |
| 17 | 194I | Rent | 393 | NS05 / NS06 | 10% / 2% | ₹2,40,000 |
| 18 | 194IA | Purchase of immovable property | 393 | NS27 | 1% | ₹50,00,000 |
| 19 | 194IB | Rent by Individual / HUF | 393 | NS28 | 5% | ₹50,000 per month |
| 20 | 194IC | Joint development agreement | 393 | NS29 | 10% | Nil |
| 21 | 194J | Professional / Technical fees | 393 | NS02 / NS03 | 10% | ₹30,000 |
| 22 | 194K | Income from mutual fund units | 393 | NS30 | 10% | ₹5,000 |
| 23 | 194LA | Land acquisition compensation | 393 | NS17 | 10% | ₹2,50,000 |
| 24 | 194LB | Infrastructure debt fund | 393 | NS31 | 5% | Nil |
| 25 | 194LC | Foreign currency borrowing | 393 | NS32 | 5% | Nil |
| 26 | 194M | Payment by Individual / HUF (contract / professional) | 393 | NS33 | 5% | ₹50,00,000 |
| 27 | 194N | Cash withdrawal | 393 | NS20 | 2% / 5% | ₹1 crore |
| 28 | 194O | E-commerce participant | 393 | NS13 | 1% | ₹5,00,000 |
| 29 | 194Q | Purchase of goods | 393 | NS12 | 0.1% | ₹50,00,000 |
| 30 | 194R | Benefits / Perquisites | 393 | NS14 | 10% | ₹20,000 |
| 31 | 194S | Virtual digital asset | 393 | NS15 | 1% | ₹50,000 / ₹10,000 |
| 32 | 195 | Payment to non-resident | 393 | NS18 | As per Act | Nil |
| 33 | 196A | Income of non-resident units | 393 | NS34 | 20% | Nil |
| 34 | 196B | Offshore fund income | 393 | NS35 | 10% | Nil |
| 35 | 196C | Foreign company income | 393 | NS36 | 10% | Nil |
| 36 | 196D | Foreign institutional investor | 393 | NS37 | 20% | Nil |
Key Features of the New TDS Regime
One of the major highlights of the new system is the consolidation of similar provisions. Payments of a similar nature are now grouped together under broader categories, reducing fragmentation. Additionally, descriptive section headings have been introduced to improve readability and ease of interpretation.
The government has also aimed to align TDS provisions with evolving business practices, including digital transactions, cross-border payments, and automated compliance systems.
Practical Implications for Taxpayers and Deductors
Despite being largely a renumbering exercise, the transition has practical implications. Deductors must ensure that they use the correct section codes while filing TDS returns, making payments, and issuing TDS certificates. Incorrect mapping between old and new sections may lead to compliance errors, notices, or mismatches in tax credit.
Professionals have also highlighted that ERP systems, accounting software, and return filing utilities need to be updated to reflect the revised section codes. Any delay in such updates may lead to operational disruptions.
Continued Applicability of Existing Procedures
It is important to note that while section numbers have changed, the underlying compliance framework—such as deduction timelines, deposit rules, and return filing requirements—continues to remain substantially the same unless specifically amended.
Taxpayers are therefore advised not to assume a change in liability merely due to renumbering, and instead focus on understanding the corresponding provisions under the new law.
Need for Clear Mapping and Awareness
Given the scale of transition, a clear mapping between old and new TDS sections is critical. Such mapping helps in ensuring continuity, especially in cases involving ongoing contracts, long-term payments, or assessments spanning multiple financial years.
Tax authorities are expected to issue detailed guidance and updated utilities to facilitate a smooth transition. However, professionals have stressed the need for greater awareness and training to avoid inadvertent non-compliance.
Conclusion
The restructuring of TDS provisions under the Income-tax Act, 2025 represents a step towards simplification and modernisation of tax laws. However, the success of this transition depends on how effectively taxpayers and professionals adapt to the new framework.
Until systems stabilise and familiarity increases, careful attention to section mapping, compliance procedures, and official notifications will remain essential to avoid errors and litigation.
Read More: S. 80C Deductions Explained: How Taxpayers Can Maximise Rs. 1.5 Lakh Benefit Under Old Tax Regime?

