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ChanakyaTax & Law

Indian tax law, cited at the source.

Both Income-tax Acts served at their date — 1961 and 2025 side by side — the treaties article by article, the GST family, the tribunals in full text. The practitioner’s method rides inside the connector, and the citation comes back with the answer.

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The Writers' Buildings at Calcutta seen across the tank — photograph by Francis Frith, 19th century

Who Chanakya Tax & Law is for

For practitioners whose position has to hold at the section and at the year — from the computation to the tribunal. Each one puts the question in their own words; the answer comes back sourced.

At the computation desk

Chartered accountants. The liability computed from the text at the year — income tax, TDS, capital gains, the GST side — rates and thresholds read from the section, never from memory. “Capital gains on an unlisted-share transfer by a non-resident: rate, base, and the treaty cap?”

Finance directors. Withholding under section 195 with the treaty cap beside it, PE risk, transfer pricing — treaty and statute confronted, never assumed. “Does the India–Netherlands DTAA cap the withholding on these royalties?”

In the file, and before the tribunal

Tax counsel. The exact vintage and the procedure, from the section 148A notice to ITAT — each step answered inside its own clock. “This reassessment covers AY 2020-21 — give me the section as it stood that year.”

Advisers on the transition. The 1961 Act for the decades it governed, the 2025 Act from 1 April 2026 — renumbered and restructured; the date picks the text, and the answer names it. “Cite me the reassessment machinery — old Act and new, side by side.”

What the corpus covers

The two charging Acts, the treaties, the GST family and the tribunals — each read as it stood at the date of the taxable event. Where the two Acts diverge on substance, the divergence is stated, not smoothed; and a superseded circular says so, and binds nobody.

  • Income-tax Act 1961 883 sections — the Act the assessments of two generations stand on
  • Income-tax Act 2025 524 sections, in force 1 April 2026 — the date picks the Act
  • 99 tax treaties article by article — residence, PE, dividends, royalties, credit
  • The GST family CGST, IGST and their rules — and the annexed statutes, section by section
  • Notifications & circulars 5,212 CBDT and CBIC, with their life-chain
  • Judgments, full text 151,120 — ITAT, the High Courts and the Supreme Court, weighted
  • Doctrine at its weight circulars bind the administration, never the courts — labelled
  • The clocks reassessment, appeals, stay — computed as calendar dates

What you hand it

Six pieces of work, taken end to end — and under each of them the same record: the section at its date, the treaty article, the circular with its weight, the judgment in full text.

Compute, from the text

The liability from the section as it stood at the year — rates, thresholds, conditions read on the page. Where a figure depends on an election or a proviso, the dependency is stated, not silently resolved.

Answer the reassessment

The section 148A gate step by step — inquiry notice, reply, reasoned order — and the limitation arithmetic of section 149 computed as calendar dates, three years or ten by the amount escaping.

Carry the appeal

Grounds before the Commissioner (Appeals) and ITAT, the stay application, the precedent weighed by court — a Tribunal decision persuades, a High Court binds its state, the Supreme Court binds all.

Cross the border

Withholding under section 195 with the treaty cap beside it, PE qualification, the credit as the article writes it — and the TRC’s place stated, not assumed.

Work the transition

The 1961 and 2025 Acts side by side: the date of the taxable event picks the Act, the renumbering is crossed openly, and where the two texts diverge on substance the divergence is put on the table.

Mind the GST side

CGST and IGST read section by section with their rules — registration, input tax credit, place of supply — and the annexed statutes a tax matter touches: companies, evidence, procedure.

Strollers along the Esplanade at Calcutta, Government House beyond — wood engraving, 19th century

Two Acts, one date

India now lives with two Income-tax Acts: the 1961 Act for the decades it governed, the 2025 Act from 1 April 2026 — renumbered, restructured, applied by the date of the taxable event. Citing the wrong Act’s section number is the new classic error. The rule of the house: the date picks the Act, the answer names it — and where the two texts diverge on substance, the divergence is stated, not smoothed.

The whole file, read

Assessment order, 148A notice, the computation and the papers behind it — read whole, and the facts that decide the outcome drawn out of them.

A practitioner’s reasoning

The facts qualified, the section read at its year, the circular weighed as doctrine, the treaty confronted with the statute — and the judgments, in full text, brought to bear on the point actually in issue.

Arguments, and pieces

Reply to the notice, grounds of appeal, stay application, the computation annexed — drafted and argued. Each piece leaves as a draft; the signature stays with the professional.

ITA 1961, s. 149(1) ITA 2025 — renumbered DTAA India–Netherlands, art. 12

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Questions, as they arrive

Four matters, put the way they are put in practice. The answer comes back with its citations — the section at its year, the article, the circular, the judgment.

Counsel, on a reopening. “The Department wants to reopen AY 2021-22 — years after the assessment. Can they?”

A CA, on a non-resident’s gain. “Capital gains on an unlisted-share transfer by a non-resident: rate, base, treaty cap?”

A CFO, on royalties. “Does the India–Netherlands DTAA cap the withholding on these royalties?”

An adviser, on the transition. “Cite me the reassessment machinery — old Act and new, side by side.”

Three steps, no more

A few minutes: the connector goes in, the question goes out dated, and the citation comes back to be checked at the official source.

  1. Connect

    One click from the connect page, or the address pasted by hand — Claude on the web, on the desktop and on mobile; ChatGPT through the same address. The connector is open: no account is needed today.

  2. Ask, dated

    Put the question and give the assessment year or the date of the taxable event. The version served is the one that date commands — and the answer states which Act, and which version, it read.

  3. Verify the citation

    The answer cites the section at its year, the treaty article, the circular with its number and date, the judgment — verifiable line by line at the official source.

They appear in your tool list once the connector is confirmed. The full walk-through: step-by-step setup.

Four questions, before you connect

Where do the texts come from?

From the official record: India Code and the Gazette for the Acts and rules; the CBDT’s and CBIC’s published notifications, circulars and instructions; the treaty texts as published; the courts’ and tribunals’ own records for the judgments, held in full text. Every answer returns the exact citation, for checking at the source.

How are the two Income-tax Acts handled?

As two records, not one. The 1961 Act governs the decades it covered; the 2025 Act takes over from 1 April 2026, renumbered and restructured. The date of the taxable event picks the Act, the answer names which one it read — and for transition work the two texts are served side by side, divergences stated.

How do I connect?

From the connect page: one click, or the connector’s address pasted into Claude (web, desktop or mobile) or into ChatGPT. The connector is open — no account is needed today. The detailed walk-through is on the setup page.

Is this legal advice?

No: a documentary research aid, sourced to the section and to the article. The professional checks the citation, weighs the situation and decides. The full frame is in the terms.

All frequently asked questions

Put it on a real assessment

Open the counsel’s ledger on a file you already know — the section at its year, the treaty cap, the deadline. The first answer comes back with its citations.

Open connector · no account needed today · works in Claude and ChatGPT.