Income-tax Act, 1961Section 92C
- ALP by most appropriate method (CUP, RPM, CPM, TNMM, PSM, other)
- Tolerance band for variation
- Reference to TPO under 92CA
Applies to FY 2025-26 (AY 2026-27) and earlier years.
IT Act 1961 → 2025 / Section 92C
Transfer pricingSection 92C → Section 165
Computation of arm's length price for international and specified domestic transactions
Section 92C of the old Income-tax Act, 1961 · new section 165 under the Income-tax Act, 2025
New reference Section 165 (92 → 161, 92CA → 166)
Income-tax Act, 2025Section 165 (92 → 161, 92CA → 166)
- ALP computation: section 165
- Charging rule for international transactions: section 161
- Reference to TPO: section 166
Applies from tax year 2026-27 (from 1 April 2026).
What changed
Renumbered. The 3% tolerance cap remains in section 165(3). The Finance Act 2026 changed the TPO's deadline: by 31 January (if the limitation date is 31 March) or 31 October (if 31 December) — section 166(7).
Practice notes
- Accountant's report is section 172 (old 92E).
Frequently asked
Which section covers arm's length price in the new Income Tax Act 2025?
Section 165 (old 92C); TPO reference is section 166.
What is section 92C called in the new Income-tax Act, 2025?
Section 92C of the Income-tax Act, 1961 corresponds to Section 165 (92 → 161, 92CA → 166) of the Income-tax Act, 2025, which applies from 1 April 2026 (tax year 2026-27).
What changed in section 92C under the new Income Tax Act?
Renumbered. The 3% tolerance cap remains in section 165(3). The Finance Act 2026 changed the TPO's deadline: by 31 January (if the limitation date is 31 March) or 31 October (if 31 December) — section 166(7).
Is section 92C still applicable for FY 2025-26?
Yes. Income of FY 2025-26 (AY 2026-27) and earlier years is governed by section 92C of the 1961 Act. Section 165 (92 → 161, 92CA → 166) of the 2025 Act applies from tax year 2026-27.