Tax Reform or Compliance Squeeze? Reading the Income Tax Bill 2025

Income Tax Bill 2025 revamps India’s tax system with compliance push, new regimes, and higher revenue targets.

Inside the Income Tax Bill 2025: structural reforms, compliance push, corporate shifts, and the fiscal gamble shaping India’s direct tax future.

(Photo: Kamran Akther/The Quint)

On 11 August, amid a stormy monsoon session and the detention of Opposition MPs protesting outside against allegations of 'vote chori', the Lok Sabha passed the new Income Tax Bill, 2025 and the Taxation Laws (Amendment) Bill, 2025 as Money Bills, bypassing debate in the Rajya Sabha.

Days earlier, the government had withdrawn its older version of the Bill. The overhaul envisages structural simplification, tighter compliance, expanded digital taxation, and streamlined dispute resolution, alongside targeted incentives such as tax benefits under the new Unified Pension Scheme.

Yet, beyond these stated aims, the legislation marks a decisive shift in India’s direct tax architecture, blending an optional personal tax regime, revamped corporate incentives, expanded reporting mandates, fortified anti-avoidance measures, and enhanced administrative authority.

Revenue Targets and Compliance Gamble

At its core, it reflects the classic tenets of base broadening and compliance intensification, a pivot aimed at boosting government revenue.

That fiscal ambition is quantifiable.

The 2025-26 Union Budget projects total receipts other than borrowings at Rs 34.96 lakh crore, with net tax revenue pegged at Rs 28.37 lakh crore. The Bill’s sweeping base-broadening provisions, from crypto disclosures to high-value transaction reporting, are designed to plug leakage and hit these targets.

Nevertheless, the success of this revenue arithmetic hinges on taxpayer behaviour and administrative precision.

If compliance slippage outpaces the intended yield, the reform could undershoot projections, undermining fiscal consolidation goals even as it imposes new compliance costs.

The Bill’s architects frame the new, ostensibly simplified personal income tax regime and optional concessional corporate tax structures as supply-side catalysts, recalibrating incentives and invigorating manufacturing.

This is a calculated “rate-structure shock”, assuming taxpayers will willingly shift to the new regime for lower headline rates.

Yet, this overlooks entrenched behavioural patterns and the advantages of existing deductions, especially for a middle class whose savings and investments are tied to them.

Corporate Winners and Losers

For corporations, concessional rates may favour large players able to restructure finances, leaving smaller enterprises without such capacity at a disadvantage. This “supply-side signalling” could create a bifurcated landscape, where efficiency gains and investment stimuli are unevenly distributed.

The reform’s market impact so far reflects this nuance: real estate indices such as Nifty Realty jumped roughly 3.3 percent on expectations of higher disposable incomes and affordable housing incentives, while infrastructure stocks dipped on the back of modest capital expenditure proposals.

This is not India’s first tryst with structural direct tax reform. The Direct Taxes Code (DTC) Bill of 2010, which sought to replace the Income tax Act, stalled amid political hesitation and implementation concerns.

Internationally, similar transparency and base-broadening regimes, from the Organisation for Economic Cooperation and Development (OECD)'s Common Reporting Standard to Foreign Account Tax Compliance Act in the US, have often been paired with judicial oversight to safeguard taxpayer rights. The absence of such institutional guardrails heightens privacy concerns, particularly given the scale of data capture contemplated.

Disclosure Drive or Surveillance State?

Financial Transactions, compulsory cryptocurrency reporting, and international group reporting mark a shift in the taxpayer-authority relationship.

By converting opaque household and retail financial activities into structured data streams for the tax department’s “data-matching engine,” the Bill aims to shrink the “tax gap”, the difference between owed and collected taxes.

Economically, this move could curb informality, widen the tax base, and foster voluntary compliance.

But the expanded reporting burden will hit small businesses and individuals lacking resources to meet the new standards, risking a chilling effect on small-scale economic activity.

Federal Tensions in Fiscal Design

Federalism adds another layer of complexity. Scholars warn that the Bill could narrow the divisible tax pool under Article 270, constraining state revenues and fiscal autonomy. In a federal setup where states shoulder the lion’s share of social sector spending, reduced fiscal space could translate into harder trade-offs in welfare and infrastructure, politically sensitive terrain in an already strained intergovernmental fiscal compact.

Provisions on “unexplained credits/investments/assets/expenditure” allow tax authorities to treat any unexplained financial credit or investment as taxable income.

While targeting unaccounted wealth, this discretionary tool creates “audit shock risk,” especially for middle and lower middle class households relying on informal transfers, gifts, or cash dealings that may lack documentation. With household savings falling (18.1 percent of GDP in FY24, a three-year decline) and debt rising (41.9 percent of GDP at end-2024), retroactive tax demands could trigger distress sales or increased borrowing, deepening credit stress.

Implementation: Codification vs Capacity

Infrastructure readiness is a make-or-break factor. The Bill consolidates over 800 sections into 536 across 23 chapters a rare legislative streamlining, but such codification is only half the battle.

Without proportionate upgrades to the CBDT’s digital systems, analytics platforms, and taxpayer grievance mechanisms, implementation could stall. The sheer volume of new data inflows, particularly from crypto and high-value SFT reporting, demands not just better servers but also trained personnel capable of rapid, accurate processing.

Timeline clarity is equally crucial. Several provisions, including changes to capital gains and faceless procedures, are expected to take effect only from FY27.

Transition rules will determine how smoothly taxpayers and corporates adapt, especially around carry-forward of losses and treatment of assets acquired under the old regime. Absent clear guidance could deter investment and complicate compliance planning.

Digital Traceability and Compliance Tightening

Restrictions on cash repayments and mandated electronic payments promote traceability but impose “digital onboarding costs” on small players, pushing them into formal channels with potential fees and operational adjustments. The denial of loss set-offs against undisclosed income and limits on carry-forward for late filers further tighten the net, reducing avenues for appeal and potentially inflating liabilities.

Several macroeconomic safeguards remain absent. The lack of clear de minimis thresholds or safe harbours for unexplained credit rules is a major gap. Without explicit limits or documentary standards, routine family support, small one-off receipts, or minor crypto gains could face disproportionate scrutiny.

A phased rollout with robust administrative capacity building, judicial oversight, and state-centered coordination could mitigate these risks, yet none are firmly embedded in the current framework.

The Reform’s Fork in the Road

If the reform’s architects can align fiscal ambition with economic and social safeguards, the bill could become a model of modern, data-driven taxation. If not, its legacy may be defined by the vulnerabilities it exposes.

The coming months will test whether technical precision and political sensitivity can turn this moment into a turning point for equitable growth, or a cautionary tale of reform without resilience.

The Income Tax Bill, 2025, continues to exempt genuine agricultural income from taxation, reaffirming support for real farmers and rural producers. However, it tightens the rules to plug misuse. Mandatory reporting thresholds apply to agricultural income exceeding Rs 10 lakh per annum.

Agri-related businesses, such as poultry, fish farming, food processing, and large agribusiness entities, are now subject to progressive taxation (typically 10-15 percent) and must maintain thorough documentation.

Additionally, the Bill clarifies and simplifies the definition of agricultural income by tabulating provisions formerly buried in dense legal text, making distinctions clearer for taxpayers and auditors alike.

This set of reforms seems calibrated to preserve rural protections for small, genuine farmers, while subjecting large-scale agri-activity and non-farm income linked to land to greater transparency and taxation. This approach improves fairness but raises compliance demands on larger rural operators and agribusinesses.

Tax-to-GDP Ambitions

India's tax-to-GDP ratio has seen a notable uptick, from around 11.2 percent in FY23 to 11.6 percent in FY24, and is estimated at 11.7 percent for FY25. The Reserve Bank of India forecasts this climb to stretch further: gross tax revenue is projected to reach 12.0 percent of GDP in FY26, driven by strong direct tax buoyancy.

Direct taxes (income and corporate) are expected to contribute around 7.1 percent of GDP (up from 6.8 percent), while indirect taxes remain at about 4.9 percent, totaling a projected over 11.7 percent tax-to-GDP ratio. Contextually, a 15 percent tax-to-GDP ratio is often cited as the benchmark for sufficient revenue mobilisation to support developmental goals such as infrastructure, social welfare, and poverty reduction, with India still short of that in the near term.

If the current reforms, base broadening, better compliance via IT and reporting, and plug-in of high-value activities, achieve expected traction, India could realistically approach or exceed 12-13 percent of GDP in tax collection over the medium term.

Even so, achieving over 15 percent would likely require broader inclusion under GST or higher compliance in informal sectors, behavioural shifts toward formalisation, stronger enforcement, and perhaps new tax instruments.

(Deepanshu Mohan is a Professor and Dean, OP Jindal Global University. He is a Visiting Professor and Fellow at LSE, and University of Oxford. Ankur Singh is a Research Analyst with Centre for New Economics Studies (CNES), O.P. Jindal Global University. This is an opinion piece and the views expressed above are the author’s own. The Quint neither endorses nor is responsible for the same.)