RESOURCES · RESEARCH
Practice, examined.
Published for scrutiny.
Working papers on Indian tax law — written from daily practice, argued at academic depth, and published where anyone can test the reasoning.
WORKING PAPER · SSRN
Parliament's Closed List: The Unfinished Reform of Presumptive Taxation
Section 62(4) of the Income-tax Act, 2025 carried forward — almost unchanged — the closed list of "specified professions" that quietly decides who may use presumptive taxation and who must maintain full books and face a tax audit. The recodification was the moment to fix it. It didn't.
What the paper finds
- Five structural drafting defects: undefined enumerated heads, a split definition across Act and rules, inclusion without stated principle, heads of unequal determinacy, and no mechanism of evolution.
- For many taxpayers, whether they carry on a "specified profession" is settled only during assessment — part of the tax base is effectively delegated to the assessing officer.
What it proposes
- Replace the frozen list with a principled, self-updating test: income earned from personal professional skill qualifies.
- Define the principle, not the list — so the creator economy, new regulated professions and formerly notified professions stop falling through the gaps.
SSRN ABSTRACT 6809989POSTED 2 JUNE 202623 PAGESORCID 0009-0004-1824-4318
In progress
Further work on the presumptive-taxation regime under the 2025 Act is under preparation. New papers appear here first, alongside their SSRN postings.
Writing for journalists or researching the 2025 Act? An 800–1,200-word op-ed, expert comment or a plain-language explainer is available on request.
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