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IT / TDS

Tax Guide

RENAMED

Section 92 — Transfer pricing — computation of income from international transactions at ALP

Key mapping

Section 92 of IT Act 1961 (income arising from international transaction between associated enterprises must be computed at arm's length price; applies to SDTs above ₹20 crore) maps to Section 161 of IT Act 2025. The arm's length principle and SDT threshold are retained. Verify on the income-tax portal before filing.

92→161 (IT Act 2025)

What this means

Section 92 of IT Act 1961 (income arising from international transaction between associated enterprises must be computed at arm's length price; applies to SDTs above ₹20 crore) maps to Section 161 of IT Act 2025. The arm's length principle and SDT threshold are retained. Verify on the income-tax portal before filing.

Change type — Section renumbered

The section number changed when the IT Act 1961 was reorganised into the IT Act 2025. The substance, rates, thresholds, and conditions are preserved. Any reference to the old section number in contracts, certificates, or returns before 1 April 2026 remains valid under the transitional provisions in §536.

Effective date

This change takes effect from 1 April 2026 (Tax Year 2026-27 onwards). For income earned before 1 April 2026, the old Section 92 continues to apply under the transitional provisions of Section 536 of the IT Act 2025. Returns for FY 2025-26 (AY 2026-27) are filed under the IT Act 1961 — old section numbers apply.

Frequently asked questions

Where did Section 92 go in the Income Tax Act 2025?▾
Section 92 of the IT Act 1961 maps to 161 in the IT Act 2025, effective 1 April 2026. Section 92 of IT Act 1961 (income arising from international transaction between associated enterprises must be computed at arm's length price; applies to SDTs above ₹20 crore) maps to Section 161 of IT Act 2025. The arm's length principle and SDT threshold are retained. Verify on the income-tax portal before filing.
Does Section 92 still apply for FY 2025-26 (AY 2026-27)?▾
Yes. For income earned in FY 2025-26 (April 2025 to March 2026), the IT Act 1961 continues to apply — including Section 92. The IT Act 2025 (and its new section numbering) applies from Tax Year 2026-27 (income earned on or after 1 April 2026). Verify on the income-tax portal before filing.
What is the new section number for 92 in the IT Act 2025?▾
The new corresponding provision is 161 under the Income Tax Act 2025. Change type: Section renumbered. The section number changed when the IT Act 1961 was reorganised into the IT Act 2025. The substance, rates, thresholds, and conditions are preserved. Any reference to the old section number in contracts, certificates, or returns before 1 April 2026 remains valid under the transitional provisions in §536. Verify on the income-tax portal before filing.

Use this in practice

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Related sections

Section 54H — Extension of time for acquiring new asset for reinvestm… →Section 92A — Meaning of associated enterprise (AE) for transfer pric… →Section 92B — Meaning of international transaction →Section 92C — Computation of arm's length price (ALP) — prescribed me… →

All section references are sourced from the Income Tax Act 2025 (official gazette, incometaxindia.gov.in) and cross-referenced against CBDT's comparative statement. Always verify on the official portal before filing. This page is for reference only and does not constitute legal or tax advice.