What this means
Section 92CE of IT Act 1961 (secondary adjustment: where primary TP adjustment is made, excess cash with AE must be repatriated or imputed interest is levied at 1-year MCLR + 325 bps; repatriation within 90 days) maps to Section 170 of IT Act 2025. The secondary adjustment and imputed interest rules 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 92CE 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 92CE go in the Income Tax Act 2025?▾
Section 92CE of the IT Act 1961 maps to 170 in the IT Act 2025, effective 1 April 2026. Section 92CE of IT Act 1961 (secondary adjustment: where primary TP adjustment is made, excess cash with AE must be repatriated or imputed interest is levied at 1-year MCLR + 325 bps; repatriation within 90 days) maps to Section 170 of IT Act 2025. The secondary adjustment and imputed interest rules are retained. Verify on the income-tax portal before filing.
Does Section 92CE 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 92CE. 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 92CE in the IT Act 2025?▾
The new corresponding provision is 170 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.