How to Verify a Tax Answer Against Primary Sources

Published guides to the Income-tax Act, 2025 currently give conflicting new section numbers for the same 1961 Act provisions. The reliable method is to verify against CBDT’s official concordance table and the bare Act, in that order, before a citation reaches a client deliverable.

The problem, stated plainly

A renumbering of roughly 800 provisions generated enormous demand for mapping material. That material was produced quickly, and errors propagate as they are copied.

The result is that well-trafficked published guides currently give different new section numbers for the same old provision. Withholding is the clearest example, and a useful one because the wrong version is so widely repeated. Numerous sources state that all TDS and TCS provisions were “consolidated into Section 393.” That is close enough to sound right, and wrong in a way that matters.

The actual structure is three sections. Section 392 covers TDS on salary. Section 393 covers TDS on all non-salary payments, arranged across six tables. Section 394 covers TCS. A practitioner working from the single-section version would cite Section 393 for a salary deduction and again for a TCS collection, and would be wrong on both — while sounding perfectly confident, because the source did.

This is not primarily anyone’s fault. It is a predictable consequence of a large legislative change. But it has a direct consequence for practice: a section number obtained from a search result is not a safe basis for an opinion, a filing, or a notice response.

Why this is getting harder, not easier

Two things have changed about how tax research is done.

Search results increasingly surface summarised answers rather than sources, removing the step where a practitioner would previously have seen where an answer came from and formed a view about its reliability.

General-purpose AI assistants generate fluent, confident answers on Indian tax questions by drawing on open-web content — including the very secondary sources that disagree with each other. Fluency is not accuracy, and a well-written wrong section number is more dangerous than an obviously uncertain one, because it does not prompt verification.

A working verification method

One: identify the provision, not the number. Start from what the provision does, since function is stable across a renumbering while the number is not.

Two: use CBDT’s concordance table. CBDT publishes an official old-to-new mapping on incometax.gov.in. This is the authoritative source and should anchor any firm-wide reference.

Three: confirm against the bare Act. The statute as enacted, read with amendments, is the primary authority.

Four: check the rule, form or notification. Section-level provisions are frequently operationalised through rules and forms. The Income-tax Rules, 2026 replaced the 1962 Rules and forms changed alongside them — so a correct section citation with an outdated form reference is still an error.

Five: check for amendment since enactment. A provision correct at enactment may have been amended by a subsequent Finance Act.

Six: record what you verified and when. A citation note recording the source consulted and the date makes the position auditable and re-verification straightforward.

What to require of any research tool

Whether the tool is a database, a search engine or an AI assistant, the test is the same: can you get from the answer to the primary source in one step, and does the source say what the answer says it says?

An answer citing a section without linking the provision cannot be checked without redoing the work. An answer linking to commentary rather than to the Act has moved the problem rather than solved it.

Related reading

• the old-to-new section mapping — Income-tax Act 2025 Section Mapping: Old vs New Reference
• what changed in the 2025 Act — Income-tax Act, 2025 vs the 1961 Act: What Actually Changed
• where general-purpose AI goes wrong — AI for Indian Tax Research: Common Failure Modes

Sources

• CBDT section concordance table — incometax.gov.in