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Business · effective 1 April 2026

Section 40(a)(ia) under the
Income-tax Act, 2025

30% disallowance for failure to deduct/pay TDS on payments to residents

Income-tax Act, 1961
40(a)(ia)
Income-tax Act, 2025
35(b)(i)
ConfirmedTaken from the ICAI Direct Taxes Committee concordance and independently checked against the bare statutory text of the Income-tax Act, 2025.

Topic

30% disallowance for failure to deduct/pay TDS on payments to residentsBusiness provisions under the Income-tax Act, 2025 (Act 30 of 2025).

What carried over

The substance of this provision was not changed by the re-write. What moved is the citation.

Substance preserved: 30% of the sum disallowed where TDS under Chapter XIX-B was not deducted, or deducted but not paid by the s.263(1) return due date; allowed back in the year of payment (s.35(b)(i)(A)); and the payee-has-filed relief (old second proviso to 40(a)(ia), keyed to old s.201) survives at s.35(b)(i)(B) cross-referring to s.398(2). The non-resident counterpart, old 40(a)(i), is s.35(b)(ii) and remains a 100% disallowance. Old 40A is s.36.

Source

Verified against bare text of s.35(b)(i) in ICAI publication. ICAI concordance row '35 | Amounts not deductible in certain circumstances | 40'.

Open the source document →

CBDT publishes its own correspondence utility on incometaxindia.gov.in and that is the authority. Spot-check anything high-stakes there before you rely on it.

Still cite section 40(a)(ia) for
Income earned up to 31 March 2026 — that is FY 2025-26, Assessment Year 2026-27, governed by the Income-tax Act, 1961 even though you file it during 2026.
Cite 35(b)(i) for
Income earned from 1 April 2026 — Tax Year 2026-27 onwards, governed by the Income-tax Act, 2025. Tax deducted on payments made on or after 1 April 2026 must be reported under the new section 393 table references and new challan/return codes. Quoting a legacy section such as 194C or 194J triggers validation failure.
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This is a navigational aid for the 1961 → 2025 transition, not tax advice. It helps you find the right place in the new Act when you already know the old section. Confirm every citation against the bare Act and against CBDT's own correspondence utility before relying on it in a return, certificate, notice reply or opinion. The source text used here is the Act as passed, so any rate or threshold amended by the Finance Act, 2026 is not reflected; section numbers are unaffected.

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