← All section mappings
International · effective 1 April 2026

Section 92 to 92F under the
Income-tax Act, 2025

Transfer pricing — the whole block

Income-tax Act, 1961
92 to 92F
Income-tax Act, 2025
161 to 173
ConfirmedTaken from the ICAI Direct Taxes Committee concordance and independently checked against the bare statutory text of the Income-tax Act, 2025.

Topic

Transfer pricing — the whole block — International provisions under the Income-tax Act, 2025 (Act 30 of 2025).

What carried over

The substance of this provision was not changed by the re-write. What moved is the citation.

One-to-one, in order: 92 -> 161 (computation having regard to ALP), 92A -> 162 (associated enterprise), 92B -> 163 (international transaction), 92BA -> 164 (specified domestic transaction), 92C -> 165 (determination of ALP), 92CA -> 166 (reference to TPO), 92CB -> 167 (safe harbour), 92CC -> 168 (APA), 92CD -> 169 (effect of APA), 92CE -> 170 (secondary adjustment), 92D -> 171 (TP documentation), 92E -> 172 (accountant's report), 92F -> 173 (definitions). Chapter X continues: 93 -> 174, 94 -> 175, 94A -> 176, 94B (thin capitalisation) -> 177. GAAR (95-102) becomes Chapter XI, ss.178-184.

Source

ICAI concordance rows for Chapter X ('Special Provisions Relating to Avoidance of Tax'), ss.161-177.

Open the source document →

CBDT publishes its own correspondence utility on incometaxindia.gov.in and that is the authority. Spot-check anything high-stakes there before you rely on it.

Still cite section 92 to 92F for
Income earned up to 31 March 2026 — that is FY 2025-26, Assessment Year 2026-27, governed by the Income-tax Act, 1961 even though you file it during 2026.
Cite 161 to 173 for
Income earned from 1 April 2026 — Tax Year 2026-27 onwards, governed by the Income-tax Act, 2025. Tax deducted on payments made on or after 1 April 2026 must be reported under the new section 393 table references and new challan/return codes. Quoting a legacy section such as 194C or 194J triggers validation failure.
← Previous
91 · Unilateral relief — countries with which no agreement exists
Next →
92CA · Reference to Transfer Pricing Officer
Back to all 80 section mappings →

This is a navigational aid for the 1961 → 2025 transition, not tax advice. It helps you find the right place in the new Act when you already know the old section. Confirm every citation against the bare Act and against CBDT's own correspondence utility before relying on it in a return, certificate, notice reply or opinion. The source text used here is the Act as passed, so any rate or threshold amended by the Finance Act, 2026 is not reflected; section numbers are unaffected.

Re-citing every clause by hand?
Let LexVio Tax AI do the pass.

See Tax AI →