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ITA 1961 → ITA 2025Assessment

Section 142(2A) Section 158

Special Audit

RetainedHigh - Extremely burdensome and expensive for the assessee.

Quick Answer

Section 142(2A) of the Income Tax Act, 1961 (Special Audit) corresponds to Section 158 of the Income-tax Act, 2025, effective 1st April 2026. Status: Retained.

What changed for Section 142(2A)

Under the Income Tax Act, 1961, Section 142(2A) governs special audit. Empowers the AO to order a 'Special Audit' by a nominated Chartered Accountant if the accounts are highly complex or to protect the interest of the revenue.

From 1st April 2026, the same subject sits at Section 158 of the Income-tax Act, 2025 — retained and renumbered as Section 158 of the Income-tax Act, 2025. Retained. Mostly invoked in heavy search & seizure cases or massive corporate frauds.

For Section 142(2A), the practical impact is rated High. Extremely burdensome and expensive for the assessee.

Old Law (ITA 1961)Ch: XIV

Sec 142(2A)

Provision Summary

Empowers the AO to order a 'Special Audit' by a nominated Chartered Accountant if the accounts are highly complex or to protect the interest of the revenue.

New Law (ITA 2025)Ch: XV

Sec 158

Provision Summary

Retained. Mostly invoked in heavy search & seizure cases or massive corporate frauds.

Key Changes & Highlights

  • Volume of digital transactions and volume of data explicitly added as a valid ground to invoke a Special Audit.

Related Sections

Frequently Asked Questions

What is Section 142(2A) of the Income Tax Act, 1961 about?

Section 142(2A) of the Income Tax Act, 1961 covers special audit. Empowers the AO to order a 'Special Audit' by a nominated Chartered Accountant if the accounts are highly complex or to protect the interest of the revenue.

Which section replaces Section 142(2A) in the Income-tax Act, 2025?

Section 142(2A) of the Income Tax Act, 1961 maps to Section 158 of the Income-tax Act, 2025, effective 1st April 2026 (status: Retained). Retained. Mostly invoked in heavy search & seizure cases or massive corporate frauds.

What is the impact of the change to Section 142(2A) under the new tax code?

The transition impact for Section 142(2A) is rated High. Extremely burdensome and expensive for the assessee.

What should I watch out for when Section 142(2A) moves to the 2025 code?

Volume of digital transactions and volume of data explicitly added as a valid ground to invoke a Special Audit. These points are specific to Section 142(2A) (Special Audit).

Disclaimer: This mapping of Section 142(2A) (Special Audit) to Section 158 of the Income-tax Act, 2025 is for educational and reference purposes only, based on publicly available drafts and circulars. As Section 142(2A) is currently marked Retained, always confirm its treatment with a qualified Chartered Accountant before filing or making compliance decisions.

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