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International · effective 1 April 2026

Section 92CA under the
Income-tax Act, 2025

Reference to Transfer Pricing Officer

Income-tax Act, 1961
92CA
Income-tax Act, 2025
166
ConfirmedTaken from the ICAI Direct Taxes Committee concordance and independently checked against the bare statutory text of the Income-tax Act, 2025.

Topic

Reference to Transfer Pricing Officer — 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.

Listed separately because it is heavily cited in TP assessments. Drafting note recorded by ICAI: the definition of 'associated enterprise' is now given once for the whole chapter in s.162 and is deliberately NOT repeated in ss.170 and 177, unlike the old 92CE and 94B which each carried their own. Scheme-making power for faceless TPO references sits in s.532.

Source

ICAI concordance row '166 | Reference to Transfer Pricing Officer. | 92CA'.

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 92CA 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 166 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.
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92 to 92F · Transfer pricing — the whole block
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92D · Maintenance of transfer pricing documentation
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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.

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