Chapter XI of the Income-tax Act, 2025 runs from section 178 to section 184 and covers general anti-avoidance rule. Its 7 sections replace 8 sections of the Income-tax Act, 1961. This guide gives the complete section-by-section mapping between the two Acts.
What Chapter XI covers
Chapter XI is the General Anti-Avoidance Rule, carried over as a self-contained block from sections 95 to 102 of the 1961 Act.
Chapter XI contains 7 sections (sections 178 to 184). Between them they carry forward the substance of 8 sections of the Income-tax Act, 1961.
The Income-tax Act, 2025 received Presidential assent on 21 August 2025 and takes effect from 1 April 2026. The Income-tax Act, 1961 continues to govern every tax year up to 31 March 2026, and all assessments, appeals, penalties and prosecutions relating to those years are completed under the old Act by virtue of the repeal and savings provision in section 536. The mapping on this page is drawn from the section-wise concordance published with the Act, including the corrigenda notified in the Gazette on 3 September 2025.
What changed in Chapter XI
- Section 178 is the applicability provision (old section 95) and section 179 defines an impermissible avoidance arrangement (old section 96).
- Section 183 merges sections 100 and 101 — the application of the chapter and the framing of guidelines.
- Section 184 carries the GAAR definitions from section 102.
- The structure is unchanged: the chapter still operates as an override, and the consequences in section 181 (old section 98) remain wide.
Chapter XI: complete section mapping (2025 → 1961)
Every section of Chapter XI is listed below with the section or sections of the Income-tax Act, 1961 that it corresponds to. Where a section is marked as read with a Schedule, the operative detail sits in that Schedule rather than in the section itself.
| New section (2025) | Provision | Corresponding 1961 section(s) |
|---|---|---|
| 178 | Applicability of General Anti-Avoidance Rule | 95 |
| 179 | Impermissible avoidance arrangement | 96 |
| 180 | Arrangement to lack commercial substance | 97 |
| 181 | Consequences of impermissible avoidance arrangement | 98 |
| 182 | Treatment of connected person and accommodating party | 99 |
| 183 | Application of this Chapter | 100, 101 |
| 184 | Interpretation | 102 |
How to use this mapping
- Working on a year up to 2025-26? Use the 1961 section in the right-hand column. The old Act governs those years under section 536.
- Working on tax year 2026-27 onwards? Use the new section number in the left-hand column, and read the section text rather than assuming the old provision was copied verbatim.
- Drafting a reply or an appeal? Cite the section that applies to the year in dispute, not the section in force when you are writing.
- Updating templates and software? Sections that merged — shown where one new section maps to several old ones — need the most attention, because a single new provision now carries what were separate conditions.
This page is a structural mapping guide, not tax advice. A corresponding section is not always an identical section — several provisions were merged, split or re-worded when they were carried over. Always read the actual text of the new section before relying on it, and check for later amendments, rules and CBDT notifications.