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Case lawIncome-tax Act 2025Chapter VIII › Section 142
Chapter VIIIwas s.80

Section 142 of the Income-tax Act, 2025

Section 142 — Deductions in respect of profits and gains from housing projects. Successor to s.80 of the 1961 Act.

Where this section sits

Section 142 is in Chapter VIII — Deductions to Be Made in Computing Total Income, which runs from section 122 to section 154.

← Section 141  ·  Section 143 →

What this section does

The section preserves, under the 2025 Act, a deduction that arises under a repealed statute. It applies for a tax year where clause (a) is satisfied — the assessee's gross total income includes profits and gains derived from the business of developing and building housing projects or rental housing projects referred to in section 80-iba of the Income-tax Act, 1961 — and clause (b) is satisfied, that the assessee is eligible to claim a deduction from those profits for that tax year under that section, as if that Act had not been repealed.

Where both hold, a deduction from those profits and gains is allowed in computing total income, on two conditions. Condition (i) is that the amount of the deduction is calculated as per the provisions of section 80-iba of the 1961 Act. Condition (ii) is that the deduction under the 2025 Act is allowed only for such tax years as would have been allowed under section 80-iba of the 1961 Act, as if that Act had not been repealed.

Why it is there

Housing project deductions run over several years from approval, so the repeal of the 1961 Act would otherwise cut off a developer part way through an entitlement already earned. The section carries it across without re-enacting it: eligibility, quantum and duration are all measured by the old section, and the 2025 Act supplies only the authority to allow the deduction.

Who it applies to

What this means in practice

Nothing about the deduction is settled by this section. Whether the assessee qualifies, how much is allowed and for how many more years are all answered by section 80-iba of the 1961 Act, applied as if that Act had not been repealed — so its conditions, limits and approval dates govern, and none are reproduced here. This is a continuation, not a fresh benefit: only an assessee already eligible under section 80-iba for the year in question can claim, and the claim stops in the year it would have stopped under the old law.

An example

Illustrative only, and invented for this page. The figures are chosen to show the rule biting, not taken from any real matter.

A firm developing a housing project was eligible to claim the deduction under section 80-iba of the 1961 Act, with the entitlement running to a tax year falling after the repeal. For that later year its gross total income includes Rs. 3 crore of profits from the project. Clauses (a) and (b) are satisfied, so it gets a deduction in computing total income, but the amount is worked out under section 80-iba of the 1961 Act rather than under any rule in the 2025 Act, and once the last year that section would have allowed has passed, nothing further is available.

Where you meet this section

In the deductions claimed in the return by a housing project developer, and in a scrutiny query asking on what authority an 80-iba claim continues after the repeal of the 1961 Act — the substantiation still has to be built on the old section's conditions.

The words themselves

the amount of deduction is calculated as per the provisions of section 80-IBA of the Income-tax Act, 1961 (43 of 1961)
Section 142(i), Income-tax Act, 2025.
the deduction under this Act shall be allowed only for such tax years, as would have been allowed under section 80-IBA of the Income-tax Act, 1961 (43 of 1961), as if the said Act had not been repealed
Section 142(ii), Income-tax Act, 2025.

What people get wrong

What this replaced

The correspondence is the Income Tax Department’s own, from its comparison utility for the 1961 and 2025 Acts. A renumbering is the easy half; whether the words changed is the half that decides cases.

See the full 1961 to 2025 concordance.

Rules that serve this section

Rules of the Income-tax Rules, 2026 that work section 142. Where the rule’s own heading names the section we say so; the rest are marked on reading the rule, which is our derivation and not the department’s. A rule that serves the section silently and that we have missed will not appear here.

All of them are in the Rules 2026 index.

Circulars of the Board on this section

A circular binds the department, not you and not a court. Every one below was written under the 1961 Act; it reaches this section because the department’s own concordance carries the provision it names to this one.

See every circular and notification on this section, or the circulars index.

Notifications that reach this section

A notification is made under a power the Act gives and, within that power, is law. These too were made under the 1961 Act and are placed here by the department’s concordance.

See every circular and notification on this section, or the notifications index.

Case law carried across

Read this before you rely on it. Every decision below was decided under the Income-tax Act, 1961. It appears here because it is tagged to a 1961 provision that the department’s own mapping carries to section 142. That is an inference we have drawn, not a holding on the new section: where the words changed in the move, the reasoning may not survive. Treat this as the place to start looking, not as authority on the 2025 Act.

Explainers

What this page does not tell you. It does not reproduce the section. Everything above was written from the section’s own text as the Income Tax Department publishes it — the text is here, and nothing here is advice on your facts. Where a figure matters, read the sub-section it comes from.