The Biggest TDS Structural Shift in 60 Years
The New Income Tax Act, 2025 replaces the Income Tax Act, 1961 with a simplified legal framework that reorganizes and renumbers several provisions. One of the biggest areas of interest for taxpayers, businesses, finance professionals, and tax practitioners is the restructuring of Tax Deducted at Source, TDS section changes. The Income Tax Act 2025 restructure TDS sections as an initiative aims to simplify compliance by consolidating multiple provisions into a streamlined framework. While the TDS mechanism remains largely unchanged, the section numbers governing various TDS provisions have been reassigned, making it essential to understand how the old sections map to the new ones.
Whether you deduct TDS on salaries, contractor payments, professional fees, rent, interest, dividends, or the purchase of immovable property, referring to the correct section under the New Income Tax Act, 2025 is critical for maintaining compliance, filing accurate returns, and avoiding reporting errors.
By the time it was replaced, the TDS section list read like an alphabet soup: 192, 192A, 193, 194, 194A, 194B, 194BA, 194BB, 194C, 194D, 194DA, 194E, 194EE, 194G, 194H, 194I, 194IA, 194IB, 194IC, 194J, 194K, 194LA, 194M, 194N, 194-O, 194P, 194Q, 194R, 194S, 194T, 195 — each with its own rate, threshold, exception, amendment history, and circular trail.
The new Income Tax Act, 2025, effective from 1 April 2026, collapses all of this into three parent sections.
This guide compares old vs new TDS sections to help businesses quickly identify the revised provisions.
Part 1: The New TDS Section Structure
What Are the New TDS Sections Under Income Tax Act 2025? (Old 192–194T vs New Section 392, 393, 394)
Old: 40+ scattered TDS sections. New: 3 parent TDS sections.
| Category | Old Act (1961) | New Act (2025) |
|---|---|---|
| Salary TDS + PF Withdrawal | Sec 192, 192A | Section 392 |
| All Other TDS (Residents, Non-Residents & Special Cases) | Sec 193 to 194T, 195 | Section 393 |
| Tax Collection at Source (TCS) | Sec 206C | Section 394 |
Within Section 393, payments are split into three sub-tables:
- Table 1 (Sec 393(1)) — Payments to residents (interest, rent, commission, contractors, professionals, dividends, etc.)
- Table 2 (Sec 393(2)) — Payments to non-residents and foreign companies
- Table 3 (Sec 393(3)) — Special category payments (winnings, lottery, partners of firms)
Each entry in the table has a serial number and a corresponding 4-digit payment code (1001 to 1067). This code now replaces old section references in TDS returns, challans, and TRACES filings.
Part 2: What are The New TDS Sections VS. Old TDS Sections
The following table summarizes all TDS section changes introduced under the New Income Tax Act 2025 and TDS section mapping that provides a side-by-side comparison of every old section with its corresponding provision under the New Income Tax Act, 2025.
| Old Section (1961) | What It Covered | New Section (2025) | Payment Code |
|---|---|---|---|
| 192 | Salary | Sec 392(1) | 1001, 1002, 1003 |
| 192A | PF premature withdrawal | Sec 392 | 1004 |
| 193 | Interest on securities | Sec 393(1) Sl. 5(i) | 1013 |
| 194 | Dividend | Sec 393(1) Sl. 7 | 1018 |
| 194A | Interest (Bank/PO/others) | Sec 393(1) Sl. 5(ii) | 1014 |
| 194B | Lottery winnings | Sec 393(3) Sl. 1 | — |
| 194BA | Online game winnings | Sec 393(3) Sl. 2 | — |
| 194BB | Horse race winnings | Sec 393(3) Sl. 3 | — |
| 194C | Contractor payments | Sec 393(1) Sl. 6(i) | 1017 |
| 194D | Insurance commission | Sec 393(1) Sl. 1(i) | — |
| 194DA | Life insurance maturity | Sec 393(1) Sl. 8(i) | — |
| 194E | Non-resident sportsmen/entertainers | Sec 393(2) | — |
| 194EE | NSS withdrawal | Sec 393(1) | — |
| 194G | Commission on lottery tickets | Sec 393(3) Sl. 4 | — |
| 194H | Commission/brokerage | Sec 393(1) Sl. 1(ii) | — |
| 194I(a) | Rent — Plant & Machinery | Sec 393(1) Sl. 2(ii) | — |
| 194I(b) | Rent — Land, Building & Furniture | Sec 393(1) Sl. 2(ii) | — |
| 194IA | Property purchase (buyer) | Sec 393(1) Sl. 3(i) | — |
| 194IB | Rent — Individual/HUF (non-audit) | Sec 393(1) Sl. 2(i) | — |
| 194IC | JDA payments | Sec 393(1) Sl. 3(ii) | — |
| 194J | Professional / Technical Fees | Sec 393(1) Sl. 6(iii) | 1020, 1021 |
| 194K | Mutual fund income | Sec 393(1) | — |
| 194M | Contractor/Professional payments by Individual/HUF | Merged into Sec 393(1) Sl. 6(ii) | — |
| 194N | Cash withdrawals | Sec 393(1) | — |
| 194-O | E-commerce transactions | Sec 393(1) | — |
| 194Q | Purchase of goods | Sec 393(1) | — |
| 194R | Business perquisites/benefits | Sec 393(1) | — |
| 194S | VDA (Crypto/Digital Assets) | Sec 393(1) | — |
| 194T | Payments to firm partners | Sec 393(3) Sl. 7 | — |
| 195 | Payments to non-residents | Sec 393(2) | — |
Also, read – TDS rate chart FY 2026-27 in detail here
Part 3: All the TDS Forms Have Changed
This is where most businesses will feel the effect of TDS section changes day-to-day. Every major TDS form has been renamed and redesigned.
What are All the New TDS Return Forms (Quarterly Filings)
| Purpose | Old Form | New Form | Key Change |
|---|---|---|---|
| Quarterly TDS — Salary | Form 24Q | Form 138 | Major structural redesign |
| Quarterly TDS — Non-salary | Form 26Q | Form 140 | Major structural redesign |
| Quarterly TDS — Non-residents | Form 27Q | Form 144 | Major structural redesign |
| Quarterly TCS Return | Form 27EQ | Form 143 | Major structural redesign |
| Property / Rent / JDA / Professional / VDA (One-off Transactions) | Form 26QB, Form 26QC, Form 26QD, Form 26QE (4 separate forms) | Form 141 (Single Consolidated Form) | 4 forms merged into 1 |
The consolidation of 26QB, 26QC, 26QD, and 26QE into a single Form 141 is a significant simplification. Earlier, a taxpayer buying a property AND paying professional fees had to use two different forms. Now it is all one form with separate schedules.
New TDS Certificates under Income Tax Act 2025
| Certificate For | Old Form | New Form | Change |
|---|---|---|---|
| Salary TDS Certificate (Annual) | Form 16 | Form 130 | More detailed structure, 3 parts, now includes pensioners |
| Non-Salary TDS Certificate | Form 16A | Form 131 | Redesigned |
| TDS Certificate for Form 141 Transactions | Form 16B / 16C / 16D | Form 132 | Multiple forms replaced by one |
| Annual Tax Credit Statement | Form 26AS | Form 168 | Integrated with AIS, more detailed |
| Employee Investment Declaration | Form 12BB | Form 124 | Renumbered |
What this means for salaried employees: The Form 16 your employer gives you every June will now be called Form 130. Same purpose, new name, more detailed format. If your employer issues a document labelled “Form 16” for Tax Year 2026-27, that is technically non-compliant — the correct form is now Form 130.
What are The New Self-Declaration Forms Under Income Tax 2025 (15G and 15H)
| Purpose | Old Form | New Form | Change |
|---|---|---|---|
| Declaration for Nil TDS (Individuals Below 60) | Form 15G | Form 121 | Both merged into a single form |
| Declaration for Nil TDS (Senior Citizens) | Form 15H | Form 121 | Both merged into a single form |
| Application for Lower/Nil Deduction | Form 13 | Form 128 | Renumbered |
| Foreign Remittance Declaration | Form 15CA | Form 145 | Renumbered |
| CA Certificate for Foreign Remittance | Form 15CB | Form 146 | Renumbered |
The merger of Form 15G and Form 15H into a single Form 121 is an important simplification. Earlier, the age-based distinction meant that someone turning 60 mid-year had to manage both forms. Now a single form applies to everyone regardless of age. Additionally, payers must allot a 26-character Unique Identification Number to every Form 121 received — ensuring better tracking during assessments.
The old Form 15G and Form 15H are not valid for Tax Year 2026-27.
Part 4: Substantive (Non-Rate) Changes to TDS Provisions
Beyond section renaming and form renumbering, several actual compliance rules have changed.
1. Manpower Supply Services — Ambiguity Resolved
This was a long-running dispute in practice. Under the old Section 194C, TDS applied to “work” contracts. But whether deploying contract workers or providing labour supply services counted as “work” — or as a “service” under Section 194J — was genuinely unclear.
The new Act explicitly includes manpower supply as “work” under Section 393. This removes the ambiguity completely.
From 1 April 2026, TDS on manpower supply invoices must be deducted — at 1% for Individual/HUF contractors, 2% for others. Businesses that had been avoiding TDS on such invoices using the ambiguity defence must now deduct from the first payment of FY 2026-27.
2. Section 194M is Merged into the Main Contractor/Professional Clause
Under the old Act, Section 194M was introduced specifically to cover contractor and professional payments by individuals and HUFs not required to audit their accounts — who were otherwise outside the scope of 194C and 194J.
Under the new Act, this is seamlessly folded into Section 393(1) Sl. No. 6(ii). There is no need for a separate section. The obligation now flows naturally from the same table that applies to specified persons.
3. MACT Interest — Now Fully Exempt from TDS
Interest awarded by the Motor Accident Claims Tribunal (MACT) to a natural person is now fully exempt from tax under the Income Tax Act, 2025.
This means no TDS applies on such interest payments at all. Earlier, this interest was treated as taxable and TDS was deducted by insurance companies or courts before releasing compensation amounts. Many accident victims were unaware they could claim refunds. That problem ends from 1 April 2026.
4. CBDT Guidelines Now Binding on All Deductors
Under the new Act, CBDT (Central Board of Direct Taxes) circulars and guidelines are explicitly made binding on deductors — not just persuasive. This closes a long-standing gap where some large deductors would dispute the applicability of circulars in litigation.
5. NRI Property Purchase — PAN-Based TDS, No TAN Required
When a resident buys immovable property from a non-resident, the buyer is required to deduct TDS. Under the old system, this often required the buyer to obtain a Tax Deduction Account Number (TAN), which was cumbersome for one-off transactions.
Under the new Act, the buyer simply uses their PAN instead of TAN for such transactions — significantly reducing compliance friction in NRI property sales.
6. Form 141 — One Form Instead of Four
Earlier, TDS payments for the following required separate forms:
- Property purchase → Form 26QB
- Rent payment → Form 26QC
- JDA (Joint Development Agreement) → Form 26QD
- Professional fees → Form 26QE
From 1 April 2026, all four are handled through a single Form 141 with separate schedules. One form, one submission, one tracking number.
Part 5: The 4-Digit Payment Code System
Under the old TDS framework, filings referenced section numbers directly (e.g., Section 194C for contractors). Under the new framework, TDS challans and TRACES filings use numeric codes from 1001 to 1067, each corresponding to a specific row in the Section 393 table.
For example:
- What was Section 192 (salary) is now code 1001 (regular salary), 1002 (government employee salary), 1003 (salary advance)
- What was Section 194C (contractor) is now code 1017
- What was Section 194J (professional) is now 1020 (technical) or 1021 (professional)
This matters practically: If your accounting software, ERP, or TDS filing tool still uses the old section names in its dropdown menus, filings for payments made from 1 April 2026 onwards will trigger validation errors on the TRACES portal. A correction statement would then need to be filed.
Part 6: The TDS Compliance Checklist (What You Need to Do Now)
To comply with the latest TDS section changes, businesses should complete the following checklist.
For employers and payroll teams:
- Update payroll software to reference Section 392 instead of Section 192
- Collect fresh investment declarations from employees under the new Act’s section references
- Issue Form 130 (not Form 16) for Tax Year 2026-27 salary TDS certificates, by 15 June 2027
For accounts and finance teams:
- Update TDS filing software with new payment codes (1001–1067)
- Stop using old section references (194C, 194J, 194I, etc.) for any payment from 1 April 2026
- Use Form 141 for property, rent, JDA, professional, and VDA transactions (instead of 26QB/C/D/E)
For CAs and tax professionals:
- Q4 FY 2025-26 returns must be filed using old forms and old section references
- From Q1 FY 2026-27, file under the new system with new forms and new codes
- Ensure clients are advised that Form 15G and Form 15H are no longer valid — use Form 121 instead
For individuals:
- If you pay rent above ₹50,000/month, update your TDS challan process to use new section
- If you submit Form 15G or 15H at your bank, submit Form 121 from now on
- When you receive your annual TDS certificate, it should say Form 130 (salary) or Form 131 (other income)
Summary Table of TDS Section Changes: Old TDS Forms vs New TDS Forms at a Glance
Businesses should update their systems for the [SECONDARY] new TDS sections from April 2026 to avoid filing errors.
| Old Form | New Form | What It Is |
|---|---|---|
| Form 16 | Form 130 | Salary TDS certificate |
| Form 16A | Form 131 | Non-salary TDS certificate |
| Form 16B / 16C / 16D | Form 132 | TDS certificate for one-off transactions |
| Form 24Q | Form 138 | Quarterly TDS return (salary) |
| Form 26Q | Form 140 | Quarterly TDS return (non-salary) |
| Form 26QB / 26QC / 26QD / 26QE | Form 141 | TDS for property, rent, JDA, professional, VDA transactions |
| Form 27Q | Form 144 | Quarterly TDS return (non-residents) |
| Form 27EQ | Form 143 | Quarterly TCS return |
| Form 26AS | Form 168 | Annual tax credit / information statement |
| Form 15G + Form 15H | Form 121 | Nil TDS declaration (all ages, merged) |
| Form 13 | Form 128 | Application for lower/nil deduction certificate |
| Form 15CA | Form 145 | Foreign remittance declaration |
| Form 15CB | Form 146 | CA certificate for foreign remittance |
| Form 12BB | Form 124 | Investment/deduction declaration by employee |
These changes are among the biggest TDS & TCS Updates 2026 that taxpayers and deductors need to prepare for.
FAQs
No. Existing PAN and TAN remain fully valid.
No. The same quarterly due dates (31 July, 31 October, 31 January, 31 May) continue.
For FY 2025-26, yes. For FY 2026-27 onwards, your bank should be issuing Form 121.
For Tax Year 2026-27 salary income (April 2026 onwards), the correct certificate is Form 130. An employer issuing Form 16 for this period would be technically non-compliant. This can cause mismatches when you file your income tax return.
No. Income and transactions up to 31 March 2026 remain governed by the old Act. Any assessment, appeal, or proceeding related to periods before 1 April 2026 continues under the 1961 Act.
Escalate to your tax consultant or CA. Payroll configuration must be updated before the June 2027 deadline for issuing TY 2026-27 salary certificates. Most major payroll software providers have already released updates.
The Bottom Line
The new Income Tax Act 2025 is a structural overhaul dressed up as a simplification exercise — and in many ways, it genuinely is simpler. But “simpler” does not mean “requires no action.” For every business, employer, and CA in India, there is a concrete transition to-do list.
The section numbers are gone. The old forms are gone. The old payment codes are gone. The new system is more logical and more automation-ready. But you have to make the switch — and make it accurately. Understanding these TDS section changes will help businesses update their payroll, ERP, and tax compliance processes before the new law becomes effective.