Aditya Bhattachrya Highlights Structural Continuity and Enhanced Scrutiny of Rental Income Under Proposed Income-tax Bill, 2026
In a recent media interaction, Aditya Bhattacharya, provided key insights to Moneycontrol, into how the proposed Income-tax Bill, 2026 (ITA 2025 framework) restructures provisions relating to income from house property while retaining their substantive foundation.
Aditya noted, “The core framework governing income from house property, currently under Sections 22 to 24 of the Income-tax Act, 1961, has been substantively carried forward in the corresponding chapter of the proposed Income-tax Bill, 2026.”
He clarified that while the legislative architecture has been reorganized, the underlying principles remain largely intact. For instance:
- The provision concerning ‘Determination of the Annual Value of Property’, presently contained in Section 23 of the Income-tax Act, 1961, will now be addressed under Section 21 of the ITA 2025.
- Similarly, deductions relating to income from house property, currently governed by Section 24, will now fall under Section 22 of the ITA 2025.
This structural renumbering reflects an effort to streamline and modernize the statute without materially altering the foundational computation mechanism for rental income.
However, he emphasized that procedural and compliance aspects are witnessing a significant shift. The provisions concerning ‘Return of Income’, which will now fall under Section 263 of the ITA 2025 (replacing Sections 139 and 285BA of the ITA 1961), introduce enhanced reporting obligations, stronger data integration, and expanded information-reporting mechanisms.
Commenting on the broader policy intent, Aditya observed:
“Overall, rental income is expected to be under closer scrutiny. The proposed law marks a clear shift towards stricter taxation and higher scrutiny of rental income, while retaining familiar classification principles. Rental income is no longer viewed as a passive stream but as a regular, traceable source of income, backed by improved data matching.”
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