The Central Board of Direct Taxes (CBDT) has issued a comprehensive set of Frequently Asked Questions (FAQs) addressing taxpayer concerns regarding the upcoming implementation of the Income Tax Act, 2025. Set to take effect from April 1, 2026, the new legislation has prompted questions about the validity of existing tax identifiers and filing procedures. A key clarification from the CBDT is that taxpayers will not need to reapply for PANs.
Existing PANs and TANs Remain Valid
According to the CBDT's clarifications, all existing Permanent Account Numbers (PANs) and Tax Deduction and Collection Account Numbers (TANs) issued under the Income Tax Act, 1961, will continue to be valid under the new Income Tax Act, 2025. This means a seamless transition for millions of taxpayers, as no fresh applications will be required for their current PANs or TANs.
Furthermore, the department clarified that PAN allotment applications pending as of March 31, 2026, will remain valid. Applicants whose requests are currently being processed will not be required to submit a fresh application under the new Act.
New Forms for Fresh Applications
While existing PANs remain valid, individuals applying for a new Permanent Account Number on or after April 1, 2026, will be required to use new forms prescribed under the Income Tax Rules, 2026. These newly introduced application forms—Forms 93, 94, 95, 96, 134, and 135—are specifically for fresh applications filed after the new Act comes into force.
The department has also introduced a replacement for the existing Form 60, which is currently used by individuals without a PAN for specified financial transactions. Under the Income Tax Act, 2025, such persons will instead furnish Form 97 for transactions specified under Rule 159(2) of the Income Tax Rules, 2026. Businesses and institutions receiving these declarations will also see a procedural change: instead of filing Form 61, they will now be required to submit a half-yearly statement in Form 98 to the Income Tax Department.
Return Filing Framework Largely Unchanged
The FAQs also confirm that the new law does not significantly alter the fundamental framework for filing income tax returns. The provisions related to return filing have been consolidated under Section 263 of the Income Tax Act, 2025, covering original, belated, revised, and updated returns within a single provision. Importantly, the categories of taxpayers required to file returns remain broadly consistent with those under the Income Tax Act, 1961. The CBDT has also addressed potential confusion, assuring taxpayers that they will not be required to file two income tax returns during the transition.
Financial Year 2025-26 Governed by Old Act
A crucial clarification for the transition year is that income earned during Financial Year 2025-26 will continue to be governed entirely by the Income Tax Act, 1961. This applies even if the return for that period is filed after the new Act becomes effective on April 1, 2026. Accordingly, taxpayers filing returns for Assessment Year 2026-27 will continue to use the ITR forms notified under the Income Tax Act, 1961, which will be made available on the e-filing portal well before the due date.
The CBDT's FAQs aim to ensure a seamless transition to the Income Tax Act, 2025, by maintaining the validity of existing PANs, ensuring continuity for pending applications, and largely preserving familiar return filing procedures during the shift to the new tax regime.