The Finance Bill, 2026, introduced with the Union Budget 2026-27, brings extensive direct tax amendments focused on procedural rationalisation, dispute reduction, and certainty, rather than changes in tax rates.
This article presents a clear, section-wise summary of all major direct tax amendments relevant for Chartered Accountants, tax professionals, CFOs, and advanced taxpayers.
What Finance Bill 2026 Is Primarily About
Finance Bill 2026 focuses on in the matter of direct taxes:
- No change in income-tax rates
- Rationalisation of penalty and prosecution provisions
- Streamlining assessment, reassessment, and revision procedures
- Enhancing rule-based and automated tax administration
- Introducing a one-time disclosure scheme for small taxpayers with foreign assets
1. Income-tax Rates for AY 2026-27: No Change
The Finance Bill does not amend income-tax rates applicable for AY 2026-27. Existing rates continue for:
- Individuals and HUFs (old regime and section 115BAC default regime)
- Domestic and foreign companies
- Firms and LLPs
- Co-operative societies
Key point: The continuity of rates reinforces tax policy stability, especially for long-term planning.
2. Default Tax Regime under Section 115BAC
- Section 115BAC(1A) continues as the default regime for individuals and HUFs
- Slab structure, surcharge thresholds, and marginal relief remain unchanged
- The 15% surcharge cap on dividend income and capital gains continues
The amendments primarily clarify procedural application, not substantive tax liability.
3. Rationalisation of Penalty and Prosecution Provisions
Finance Bill 2026 introduces substantial restructuring of penalty and prosecution provisions under the Income-tax Act.
Key aspects:
- Consolidation and substitution of multiple prosecution sections
- Clearer linkage between default, intent, and consequence
- Procedural safeguards before initiation of prosecution
- Alignment with a graded, proportionate enforcement framework
Impact: Expected reduction in unnecessary prosecution and long-drawn litigation.
4. Amendments Relating to Assessment and Reassessment
Several amendments aim to streamline assessment and reassessment:
- Introduction of revised procedural sequencing
- Clearer timelines for notices and orders
- Reduced scope for discretionary actions
- Emphasis on digitally driven and rule-based processes
These changes are designed to improve certainty and reduce repeated disputes.
5. Expanded Scope for Modified Returns and Corrections
Finance Bill 2026 expands flexibility for:
- Filing modified returns
- Making corrections aligned with APA and safe harbour outcomes
- Rectifying genuine errors without immediate penal consequences
This is especially relevant for:
- Corporate taxpayers
- Transfer pricing cases
- Entities with complex reporting structures
6. Foreign Assets of Small Taxpayers Disclosure Scheme, 2026
A new Foreign Assets Disclosure Scheme is introduced as a one-time measure.
Key features:
- Applicable to specified small taxpayers
- Declaration-based, time-bound framework
- Immunity from penalty and prosecution on declared assets
- Declaration does not reopen completed assessments
The scheme excludes serious cases involving prosecution or undisclosed income from criminal activity.
7. International Taxation: Safe Harbour and APA Measures
To improve certainty for global and export-oriented businesses, the Bill provides:
- Expansion of safe harbour rules for IT and IT-enabled services
- Increase in eligibility thresholds
- Automated, rule-based approval mechanism
- Fast-tracking of unilateral APA processes (with defined timelines)
- Extension of modified return benefits to associated entities
These changes aim to reduce transfer pricing disputes.
8. Targeted Measures for Global Digital & Service Providers
Finance Bill 2026 introduces targeted incentives, including:
- Tax holiday for foreign companies providing cloud services through India-based data centres (subject to conditions)
- Safe harbour margins for related data centre service entities
- Exemption of global income of non-resident experts under notified schemes
These provisions support India’s positioning as a global services and data hub.
9. MSME and Small Business-Relevant Direct Tax Measures
Key measures affecting MSMEs and exporters include:
- Removal of the ₹10 lakh value cap on courier exports
- Compliance simplification aligned with MSME financing ecosystems
- Reduced friction for small exporters and D2C businesses
10. Shift Towards Rule-Based, Trust-Centric Tax Administration
A consistent theme across Finance Bill 2026 is:
- Greater reliance on automated systems
- Reduced human discretion
- Predictable, rule-based outcomes
- Strengthening of trust-based tax governance
Who Should Closely Track Finance Bill 2026?
- Chartered Accountants and tax advisors
- CFOs and finance leaders
- MSMEs and exporters
- IT, SaaS, and digital service companies
- Taxpayers with cross-border exposure
Conclusion
Finance Bill 2026 is a process-driven reform Bill. It prioritises:
- Stability over rate tinkering
- Certainty over discretion
- Compliance ease over enforcement-heavy approaches
For professionals, the focus shifts from tax planning through rates to planning through process and documentation.
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