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Microlesson · 5-min read

Sources of Income Tax Law — Act, Rules, Notifications and Circulars

## "Income Tax Law" is Wider Than "Income Tax Act"

Students often use these terms interchangeably, but they are not the same.

Income Tax LawIncome Tax Act
Wider scopeNarrower scope
Includes the Act + Rules + Annual Finance Acts + Notifications + Circulars + Judicial DecisionsOnly the Income-tax Act, 1961 itself

So whenever we say "Income Tax Law", we mean the entire body of rules that together govern income tax — the Act is just one (the most important) component.

## The Four Components of Income Tax Law

### 1. Income-tax Act, 1961 — "Kya karna hai?"

  • The parent statute passed by Parliament.
  • It tells you what to do — e.g., file a return, pay tax, deduct TDS.
  • Each section creates a substantive right or obligation.

### 2. Income-tax Rules, 1962 — "Kaise karna hai?"

  • Subordinate legislation framed by the Central Board of Direct Taxes (CBDT) under powers delegated by the Act.
  • They tell you how to do what the Act requires — e.g., which form to use for filing, how to compute a particular figure, procedural mechanics.
  • They came into effect from 1.4.1962 — hence "Income-tax Rules, 1962".

> Example link: The Act (section) says "file your return by 31st July". The Rule says "file it in ITR Form X, electronically, with such-and-such annexures."

### 3. Notifications — Government Speaks

  • Issued by the Central Government (or CBDT where authorised).
  • Purpose: to give effect to provisions of the Act — e.g., notifying a cost inflation index, notifying a new tax-saving scheme, amending Rules.
  • The CBDT is also empowered to make and amend Rules through notifications.

### 4. Circulars — CBDT Speaks

  • Issued by the Central Board of Direct Taxes (CBDT) from time to time.
  • Purpose: to clarify doubts, deal with specific problems, and explain the scope/meaning of provisions of the Act.
  • They are issued for guidance of officers and/or assessees.

### Important Distinction — Notifications vs Circulars

NotificationsCirculars
Issued by Central GovernmentIssued by CBDT
Give effect to / operationalise provisionsClarify / interpret provisions
Have force of law (often amend Rules)Binding on officers, not binding on assessees if against them

## Hierarchy (Top-Down)

```

Constitution of India

Income-tax Act, 1961 (Parliament)

Income-tax Rules, 1962 (CBDT, delegated)

Notifications (Central Govt / CBDT)

Circulars (CBDT — clarificatory)

```

A Rule cannot override the Act. A Circular cannot override a Rule or the Act. Judicial decisions of the Supreme Court / High Courts also form part of the "law" and bind lower authorities.

Worked example

### Example 1

Example — Act vs Rules: Section 139 of the Act says individuals must file a return of income. Rule 12 of the Income-tax Rules, 1962 prescribes which ITR form (ITR-1, ITR-2, etc.) the individual must use. The Act answers "what"; the Rules answer "how".

### Example 2

Example — Circular: Suppose a new section is inserted by the Finance Act on taxation of crypto-assets. Assessees are confused about how to compute cost of acquisition. The CBDT issues a Circular clarifying the method. This Circular binds the Assessing Officer but if it is favourable to the assessee, the assessee can rely on it.

### Example 3

Example — Notification: Every year, the Central Government issues a Notification prescribing the Cost Inflation Index (CII) for that financial year — this gives effect to section 48 of the Act.

⚠️ Common exam mistakes

  • Equating "Income Tax Law" with the "Income Tax Act" alone — the Law also includes Rules, Notifications, Circulars and judicial decisions.
  • Confusing Notifications (issued by Central Government) with Circulars (issued by CBDT).
  • Assuming Circulars are binding on assessees — they bind departmental officers; assessees may follow a circular favourable to them but can challenge one that is adverse.
  • Forgetting that the Income-tax Rules came into effect on 1.4.1962, hence the name "Rules, 1962".
  • Thinking the CBDT can make Rules without delegation — its power to frame Rules comes from the Act itself.
Reference: — Income-tax Act, 1961 and Income-tax Rules, 1962
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