Section 263 has moved to section 377 under the Income-tax Act, 2025, but the real story is not the renumbering. It is the cleaner limitation machinery, tighter transition rules, and the continuing risk from weak assessment records.
CBDT Circular 4/2026 and the Finance Act, 2026 have changed the DIN debate. A missing audit trail can still be fatal, but a mere quoting defect is now harder to weaponise.
Block assessment is back in India’s search-tax architecture, promising faster anti-evasion action but reopening a harder question: can speed, abatement and compressed procedure coexist with taxpayer safeguards?
Faceless appeal has survived India’s new tax statute, but not through a neat legislative reset. The real story lies in the savings clause, NFAC continuity and the growing centralisation of tax appellate process.
India's tax rewrite does not wipe away the 1961 Act's afterlife. Section 536 preserves pending appeals, refunds, losses, search cases and old liabilities, while quietly narrowing several transition arguments.