Income Tax Act 2025 forms vs Income Tax Act 1961 forms: practical mapping guide for professionals

Income Tax Act 2025 forms vs Income Tax Act 1961 forms: practical mapping guide for professionals

Residential status under new income tax law in India is one thing. From 1 April 2026, tax forms themselves are changing as well under the new Income Tax Act, 2025. For tax professionals, finance teams and businesses, a key day to day challenge will be understanding how familiar forms under the Income Tax Act, 1961 map to their equivalents under the new law.

This article explains the new Income Tax Act, 2025 form structure, how forms are organised on the e-Filing portal, and gives a practical mapping of some important ITA 1961 forms to their new ITA 2025 counterparts.

How forms are organised under the Income Tax Act 2025

With the notification of the Income Tax Act, 2025, forms have been renumbered and restructured. On the e-Filing portal, forms are now grouped by the applicable statute so that taxpayers can clearly see which law they are filing under.

The e-Filing portal shows three broad tabs:

1. Forms as per Income Tax Act 2025

These are forms available for filing under the new Income Tax Act, 2025. Over time, this will become the main set of compliance forms for income tax.

2. Forms as per Income Tax Act 1961

These are forms that continue to be available under the earlier Income Tax Act, 1961 during the transition period or for past assessment years.

3. Forms as per Other Acts

These are forms that are prescribed under other legislations but are filed through the income tax e-Filing portal. For example, certain equalisation levy, TDS or reporting forms under special laws.

The first step for any user on the portal is to select the correct tab based on the applicable Act and the relevant assessment year.

Why a form mapping is necessary

For more than six decades, taxpayers and professionals have used the old Income Tax Act, 1961 form numbers in their daily language. Email instructions, checklists and ERP workflows all refer to forms like 10F, 15CA, 15CB, 26QB and so on.

When those forms are renumbered under the Income Tax Act, 2025, confusion can arise unless there is a clear mapping. In practice, professionals need to know:

  • What is the new form number under ITA 2025 for a familiar ITA 1961 form
  • Whether the underlying purpose and legal provision remain the same
  • How to locate and file the correct form on the e-Filing portal
  • How to update internal templates, SOPs and checklists

A structured form mapping allows you to confidently transition without missing compliance.

Sample mapping: important forms under ITA 1961 and their ITA 2025 equivalents

The CBDT has provided a mapping of new Income Tax Act, 2025 forms to the corresponding forms under the Income Tax Act, 1961. A few illustrative examples are:

1. Stock exchange client code modification report

  • New form (ITA 2025): Form 1
  • Old form (ITA 1961): Form 3BB
  • Description: Monthly statement to be furnished by a stock exchange in respect of transactions in which client codes have been modified after registering in the system for the month of …

2. Application for zero coupon bond notification

  • New form (ITA 2025): Form 2
  • Old form (ITA 1961): Form 5B
  • Description: Application for notification of a zero coupon bond under section 2(112) of the Act

3. Application for approval of research associations and similar entities

  • New form (ITA 2025): Form 17
  • Old form (ITA 1961): Form 3CF
  • Description: Application for approval of a company under section 45(3)(b) and of a research association, university, college or other institution under section 45(4)(b) of the Income Tax Act, 2025

4. Applications for affordable housing and semiconductor projects

  • New form (ITA 2025): Form 18
  • Old form (ITA 1961): Form 3CN
  • Description: Application for notification of affordable housing project as specified business under section 46 of the Act
  • New form (ITA 2025): Form 19
  • Old form (ITA 1961): Form 3CS
  • Description: Application for notification of a semiconductor wafer fabrication manufacturing unit as specified business under section 46 of the Act

5. Agricultural extension project approval

  • New form (ITA 2025): Form 20
  • Old form (ITA 1961): Form 3C-O
  • Description: Application for approval of agricultural extension project under section 47(1)(a) of the Act

6. International tax and treaty related forms

  • Form 41 (ITA 2025) corresponds to Form 10F under ITA 1961
  • Form 42 (ITA 2025) corresponds to Form 10FA (application for certificate of residence under treaty)
  • Form 55 (ITA 2025) corresponds to Form 34F (application to invoke mutual agreement procedure)

7. Advance Pricing Agreement forms

  • Form 50 (ITA 2025) corresponds to Form 3CEC (pre-filing consultation)
  • Form 51 (ITA 2025) corresponds to Forms 3CED and 3CEDA (APA application)
  • Form 52 (ITA 2025) corresponds to Form 3CEF (annual compliance report)
  • Form 54 (ITA 2025) is a new form for renewal of an Advance Pricing Agreement

8. Tonnage tax and shipping

  • Form 80 (ITA 2025) corresponds to Form 65 (application for exercising or renewing option for tonnage tax scheme)

9. Charitable and non profit registrations

  • Form 104 (ITA 2025) corresponds to Form 10A (provisional registration or approval)
  • Form 105 (ITA 2025) corresponds to Form 10AB (final registration of non profit organisation and approval for deduction)
  • Form 106 (ITA 2025) corresponds to Form 10AC (order for provisional registration or approval, including rejection of application)

10. Donations and deduction under section 354

  • Form 113 (ITA 2025) corresponds to Form 10BD (statement to be filed by donee)
  • Form 114 (ITA 2025) corresponds to Form 10BE (certificate of donation)

11. Declarations for non deduction and non collection of tax

  • Form 121 (ITA 2025) corresponds to Forms 15G and 15H (declaration for receipt of certain incomes without deduction of tax)
  • Form 127 (ITA 2025) corresponds to Form 27C (declaration for obtaining goods without collection of tax)

12. Challan cum statements for TDS

  • Form 141 (ITA 2025) corresponds to Forms 26QB, 26QC, 26QD and 26QE (challan cum statement of tax deduction on specified payments under section 393(1))

13. Payments to non residents

  • Form 145 (ITA 2025) corresponds to Form 15CA (information for payments to non residents)
  • Form 146 (ITA 2025) corresponds to Form 15CB (certificate of an accountant for such payments)

These are only a few entries from a much longer mapping. The full mapping table should be referred to for detailed compliance.

Related: Overview of the new Income Tax Act, 2025 and transition from the Income Tax Act, 1961 (link: /blog/income-tax-act-2025-transition-guide)

New forms introduced under the Income Tax Act 2025

In addition to renumbering existing forms, ITA 2025 also introduces some new forms that did not have a direct counterpart under ITA 1961. For example:

  • Form 54: Application for renewal of an Advance Pricing Agreement
  • Form 188: Application for approval for superannuation fund or gratuity fund

There are also specific forms for:

  • Sovereign wealth funds and pension funds seeking notification under Schedule V
  • Mutual funds seeking approval under Schedule XV
  • Units in International Financial Services Centres engaged in ship leasing, aircraft leasing or other specified activities, filing statement cum declarations

Professionals need to identify these genuinely new compliance requirements and not assume that every ITA 2025 form has an ITA 1961 equivalent.

Practical compliance checklist for the new form regime

To manage the transition smoothly, tax teams and advisors can follow a simple checklist:

1. List all income tax forms you currently use under ITA 1961 for your business or clients.

2. Use the CBDT mapping table to identify the corresponding form numbers under ITA 2025.

3. Update internal SOPs, checklists, ERP workflows and template letters with the new form numbers.

4. Train finance and compliance teams on the new e-Filing portal layout and the three tabs.

5. For any new forms without ITA 1961 equivalents, review the underlying provisions and decide whether they apply to your fact pattern.

6. For cross border and international tax forms (APA, MAP, treaty residence, SWF, pension funds), coordinate with specialised advisors well in advance of filing deadlines.

7. Keep a copy of the official mapping guide handy and bookmark the relevant pages in the Income Tax Department portal.

Related: New income tax act for small businesses in India overview (link: /blog/new-income-tax-act-small-businesses-overview)

Official references and further reading

Always rely on official sources when dealing with form changes and new legislation. Useful references include:

  • Income Tax Department e-Filing portal
  • Bare text of the Income Tax Act, 2025 and rules as notified
  • CBDT circulars and notifications on transition from the Income Tax Act, 1961 to the Income Tax Act, 2025
  • Official mapping guide between ITA 1961 and ITA 2025 forms

A structured approach to the new form regime will reduce last minute confusion, avoid incorrect filings, and help you remain compliant as India moves from the Income Tax Act, 1961 to the Income Tax Act, 2025.

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