Income-tax Act 2025: Old TDS Sections vs Section 392 and 393

From 1 April 2026, India's TDS framework is reported under the Income-tax Act, 2025. The underlying withholding policy is largely familiar, but the section numbering and filing references have changed significantly.

This is one of the most practical changes for accountants, payroll teams and TDS return preparers in Tax Year 2026-27.

What happened to Sections 192 to 194T?

Under the Income-tax Act, 1961, TDS provisions were spread across many sections such as 192, 194C, 194H, 194I, 194J, 194Q and 194T.

Under the Income-tax Act, 2025:

• Section 392 deals with TDS on salary; and
• Section 393 consolidates TDS on other specified payments into structured tables.

TCS is separately consolidated under the new-law framework.

Which Act applies around March and April 2026?

For non-salary TDS categories, the practical transition generally depends on the event that triggers TDS—usually the earlier of credit or payment.

If that triggering event occurs on or before 31 March 2026, the Income-tax Act, 1961 applies.

If it occurs on or after 1 April 2026, the Income-tax Act, 2025 applies.

Example: March provision paid in April

Suppose professional fees are credited in the books on 31 March 2026 but paid in April 2026.

Because the earlier event occurred in March, the TDS obligation is governed by the Income-tax Act, 1961. The April payment does not shift that transaction into the new Act.

Example: April contractor bill

If a contractor payment is first credited or paid in April 2026, the new-law TDS reference under Section 393 should be used.

Continuing to quote an old section such as 194C for a transaction governed by the new Act can create validation or processing issues in TDS filing.

What about salary?

Salary TDS is governed by its own timing rule and is now placed under Section 392 of the new Act. Payroll teams should therefore update both statutory mapping and reporting codes for salary paid from 1 April 2026 onwards.

Have rates and thresholds changed?

The Government has clarified that the consolidation itself is not intended as a policy change and that rates and monetary thresholds are largely retained. The exact table item and current Finance Act should still be checked for the particular payment category.

What should businesses update?

• ERP and accounting TDS masters;
• vendor deduction codes;
• payroll configuration;
• TDS return mapping;
• year-end provision templates;
• internal SOPs; and
• staff training material.

Keep FY 2025-26 and Tax Year 2026-27 clearly separated

This transition is especially important because tax audit and return work for FY 2025-26 continues under the old Act even while current-year transactions from April 2026 are governed by the new Act.

Do not change section numbers based only on the filing date. Identify which law governs the underlying transaction first.