The Statutory Brief

IT Act 1961 → 2025 / Sections 61–67A, 69B–69D, 86

Unexplained income

Sections 61–67A, 69B–69D, 86 → Sections 97–310

Revocable transfers, liability for clubbed income, AOP member's share, unexplained investment/expenditure, hundi

Sections 61–67A, 69B–69D, 86 of the old Income-tax Act, 1961 · new sections 97–310 under the Income-tax Act, 2025

New reference Sections 97–107, 309, 310

Income-tax Act, 1961Sections 61–67A, 69B–69D, 86

  • 61–63: revocable transfer of assets taxed in the transferor's hands
  • 65: person whose income is clubbed pays tax on demand
  • 67A, 86: computation and taxation of an AOP/BOI member's share
  • 69B, 69C, 69D: unexplained investment, expenditure and hundi transactions

Applies to FY 2025-26 (AY 2026-27) and earlier years.

Income-tax Act, 2025Sections 97–107, 309, 310

  • 97, 98: revocable transfers and definitions
  • 100: liability for income included in another person's income
  • 309, 310: AOP/BOI member's share
  • 103–106: unexplained investment, expenditure and hundi; taxed at 30% under section 195 (FA 2026; was 60%)

Applies from tax year 2026-27 (from 1 April 2026).

Section-by-section mapping (9 sections)

1961 ActSubject2025 Act
61Revocable transfer of assets97
62Transfer irrevocable for a specified period97
63"Transfer" and "revocable transfer" defined98
65Liability of person in respect of income included in the income of another person100
67AMember's share in AOP/BOI income309
86Share of member of AOP/BOI in its income310
69BAmount of investments, etc., not fully disclosed in books of account103, 104
69CUnexplained expenditure, etc105
69DHundi borrowings and repayments106

Source: CBDT mapping of sections, Income-tax Act 1961 to Income-tax Act 2025.

What changed

Renumbered, with one real change: Finance Act 2026 cut the special rate on unexplained income under section 195 from 60% to 30%, and omitted the separate 10% penalty (443). See the 115BBE page.

Practice notes

  • Clubbing of spouse/minor income (64) and cash credits (68, 69, 69A) have their own pages.
  • Hundi borrowing (69D) is now described as 'negotiable instrument, hundi, etc.' in section 106.

These are summaries, not the statutory text. Read the bare Act for both sections on the Income Tax Department's official site, which also has a side-by-side comparison utility.

Frequently asked

What is section 61 called in the new Income-tax Act, 2025?

Section 61 of the Income-tax Act, 1961 (Revocable transfer of assets) corresponds to section 97 of the Income-tax Act, 2025, which applies from 1 April 2026 (tax year 2026-27).

What is section 62 called in the new Income-tax Act, 2025?

Section 62 of the Income-tax Act, 1961 (Transfer irrevocable for a specified period) corresponds to section 97 of the Income-tax Act, 2025, which applies from 1 April 2026 (tax year 2026-27).

What is section 63 called in the new Income-tax Act, 2025?

Section 63 of the Income-tax Act, 1961 ("Transfer" and "revocable transfer" defined) corresponds to section 98 of the Income-tax Act, 2025, which applies from 1 April 2026 (tax year 2026-27).

What is section 65 called in the new Income-tax Act, 2025?

Section 65 of the Income-tax Act, 1961 (Liability of person in respect of income included in the income of another person) corresponds to section 100 of the Income-tax Act, 2025, which applies from 1 April 2026 (tax year 2026-27).

What is section 67A called in the new Income-tax Act, 2025?

Section 67A of the Income-tax Act, 1961 (Member's share in AOP/BOI income) corresponds to section 309 of the Income-tax Act, 2025, which applies from 1 April 2026 (tax year 2026-27).

What is section 86 called in the new Income-tax Act, 2025?

Section 86 of the Income-tax Act, 1961 (Share of member of AOP/BOI in its income) corresponds to section 310 of the Income-tax Act, 2025, which applies from 1 April 2026 (tax year 2026-27).

What changed in Sections 61–67A, 69B–69D, 86 under the new Income Tax Act?

Renumbered, with one real change: Finance Act 2026 cut the special rate on unexplained income under section 195 from 60% to 30%, and omitted the separate 10% penalty (443). See the 115BBE page.

Related sections

115BBE→195Tax rate on unexplained income (cash credits, investments, money, expenditure)64→99Clubbing of income of spouse, minor child and son's wife68→102Unexplained cash credits in the books of account