What this means
Section 92CB of IT Act 1961 (safe harbour rules: CBDT may prescribe circumstances where the declared ALP is accepted without scrutiny; applicable to IT/ITES, KPO, contract R&D, etc.) maps to Section 167 of IT Act 2025. The safe harbour framework for reducing transfer pricing litigation is 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 92CB 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.
Confidence: medium. This mapping is inferred from structural analysis — verify against the official IT Act 2025 text on incometaxindia.gov.in before relying on it.
Frequently asked questions
Where did Section 92CB go in the Income Tax Act 2025?▾
Section 92CB of the IT Act 1961 maps to 167 in the IT Act 2025, effective 1 April 2026. Section 92CB of IT Act 1961 (safe harbour rules: CBDT may prescribe circumstances where the declared ALP is accepted without scrutiny; applicable to IT/ITES, KPO, contract R&D, etc.) maps to Section 167 of IT Act 2025. The safe harbour framework for reducing transfer pricing litigation is retained. Verify on the income-tax portal before filing.
Does Section 92CB 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 92CB. 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 92CB in the IT Act 2025?▾
The new corresponding provision is 167 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.