Chapter VI of the Income-tax Act, 2025 runs from section 101 to section 107 and covers aggregation of income. Its 7 sections replace 7 sections of the Income-tax Act, 1961. This guide gives the complete section-by-section mapping between the two Acts.
What Chapter VI covers
Chapter VI aggregates income and deals with the unexplained-money family — cash credits, investments, assets and expenditure that a taxpayer cannot explain. It is short, but it carries a punitive charge.
Chapter VI contains 7 sections (sections 101 to 107). Between them they carry forward the substance of 7 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 VI
- Each unexplained item now has its own section: 102 unexplained credits (old 68), 103 unexplained investment (69, 69B), 104 unexplained asset (69A, 69B), 105 unexplained expenditure (69C) and 106 hundi borrowings (69D).
- Section 107 is a new charging provision for this chapter, with no direct 1961 equivalent — the special rate that section 115BBE carried is dealt with through section 195 in Chapter XIII.
- Section 101 carries old section 66, the aggregation rule for total income.
Chapter VI: complete section mapping (2025 → 1961)
Every section of Chapter VI 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) |
|---|---|---|
| 101 | Total income | 66 |
| 102 | Unexplained credits | 68 |
| 103 | Unexplained investment | 69, 69B |
| 104 | Unexplained asset | 69A, 69B |
| 105 | Unexplained expenditure | 69C |
| 106 | Amount borrowed or repaid through negotiable instrument, hundi, etc | 69D |
| 107 | Charge of tax | — (new provision) |
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.
