Tax Law and International Tax Law

The Income-tax Act, 2025 introduces significant amendments to India's transfer pricing regime, fundamentally restructuring how associated enterprise relationships are determined and expanding the scope of international transactions subject to arm's length pricing requirements.

India's new Income Tax Act will fundamentally transform how income is assessed starting from Financial Year 2026-27, replacing the decades-old Income Tax Act of 1961. Understanding the transitional provisions and how proceedings will be handled across the old and new regimes is crucial for taxpayers and professionals navigating this historic legislative change.

The Supreme Court dismissed a public interest litigation challenging the constitutionality of digital search and seizure powers under Section 132 of the Income Tax Act, 1961 and the corresponding Section 247 of the Income Tax Act, 2025 on March 9, 2026. Chief Justice Surya Kant’s bench refused to entertain arguments that warrantless access to cloud servers, emails, and encrypted devices violates Article 21 privacy rights, holding that existing judicial review mechanisms adequately safeguard taxpayers while enabling tax evasion combat.