At the stroke of midnight on 31 March, India’s tax law, including the M&A and succession regime, will awake to a new Income-tax Act, 2025. New sections. New numbering. New language
The same structural problems.
The Income Tax Act, 2025, effective 1 April 2026, is a semantic redraft, not a strategic reform. The law has been rewritten. The policy has not been rethought.
Fast-track demergers without tax neutrality. A demerger definition too narrow for holding structures and SPVs. Phantom income on deferred and contingent consideration. A valuation trap between signing and closing. A definition of ‘relative’ that contradicts itself within the same statute. No framework for family arrangements. Unresolved grandfathering on cost splits. And loss carry-forward provisions that exclude entire sectors while penalising genuine group restructurings.
Multiple structural gaps. Zero fixes. The attached carousel walks through each one.