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IT / TDS

Tax Guide

RENAMED

Section 92D — Transfer pricing documentation — maintenance of information

Key mapping

Section 92D of IT Act 1961 (persons entering into international transactions must maintain prescribed documents: master file, local file, Form 3CEB; documents to be retained for 8 years) maps to Section 171 of IT Act 2025. The master file, local file, and 8-year retention requirement are retained. Verify on the income-tax portal before filing.

92D→171 (IT Act 2025)

What this means

Section 92D of IT Act 1961 (persons entering into international transactions must maintain prescribed documents: master file, local file, Form 3CEB; documents to be retained for 8 years) maps to Section 171 of IT Act 2025. The master file, local file, and 8-year retention requirement 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 92D 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 92D go in the Income Tax Act 2025?▾
Section 92D of the IT Act 1961 maps to 171 in the IT Act 2025, effective 1 April 2026. Section 92D of IT Act 1961 (persons entering into international transactions must maintain prescribed documents: master file, local file, Form 3CEB; documents to be retained for 8 years) maps to Section 171 of IT Act 2025. The master file, local file, and 8-year retention requirement are retained. Verify on the income-tax portal before filing.
Does Section 92D 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 92D. 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 92D in the IT Act 2025?▾
The new corresponding provision is 171 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 92E — Accountant's report for international transactions (For… →

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.