Read together, they tell a story less about simplification and more about who the tax code is optimised for now. This was the legal firewall that made India’s digital payments free for merchants. UPI processed 24,161.69 crore transactions worth Rs 314.23 lakh crore in FY26 (roughly $3.56 trillion), up from Rs 84.16 lakh crore just four years earlier. It also strips away notification requirements for foreign companies using Indian-owned data centres and extends exemptions to foreign electronics and diamond-trade companies. The more useful debate is not whether India needs tax certainty for capital, but whether it can extend the same certainty to the people already inside its payments system.