AAR - Transitional 2025
Facts
Multiple taxpayers sought clarification on transition between IT Act 1961 and 2025.
Issue
Which Act governs investments made in FY 2025-26 but claimed in FY 2026-27?
Held
Section 536 savings clause preserves 1961 Act treatment for investments made before April 1, 2026. New Section 123 (formerly 80C) applies prospectively.
Ratio
Savings clause is statutorily controlled - investments are governed by the Act in force at the time of investment, not at the time of claim.
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