Head: A shorter tax statute is not always a simpler tax law

India’s Income Tax Act, 2025 has been celebrated as one of the most significant legislative simplification exercises since the enactment of the Income-tax Act, 1961. The statute has been compressed from 819 sections to 536, hundreds of provisos and explanations have disappeared, tables and formulae have replaced lengthy prose, and the confusing distinction between “previous year” and “assessment year” has been replaced by a uniform “tax year”.

By every quantitative measure, the reform appears impressive. Yet a fundamental question remains: Does a shorter statute necessarily create a simpler tax system?

The answer may be more nuanced than the numbers suggest.

The 1961 Act undoubtedly required reform. Decades of amendments had created a dense network of cross-references, exceptions and explanatory provisions that often made navigation difficult even for experienced professionals. A rewrite was necessary and long overdue. However, legislative brevity and functional simplicity are not always synonymous. In several areas, the law has become shorter, but the manner in which taxpayers, professionals and tax administrators interact with it may have become more complex.

The clearest illustration lies in the restructuring of the Tax Deduction at Source (TDS) regime. For decades, taxpayers and professionals communicated through familiar section numbers such as Sections 194A, 194C, 194I and 194J dealing respectively with interest, contractual payments, rent and professional fees. These provisions became part of the shared language of tax compliance.

The new 2025 Act consolidates many such provisions into a single section supported by tables containing numerous rows and serial numbers. While the underlying obligations remain largely unchanged, identifying them often requires navigating such subsections, tables, rows and serial numbers. A taxpayer who was once........

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