IT Act 1961 → 2025 / Sections 92A–102
Transfer pricingAssociated enterprise, international transaction, APA, secondary adjustment, GAAR
Sections 92A–102 of the old Income-tax Act, 1961 · new sections 162–184 under the Income-tax Act, 2025
New reference Sections 162 to 184 (transfer pricing, anti-avoidance, GAAR)
Applies to FY 2025-26 (AY 2026-27) and earlier years.
Applies from tax year 2026-27 (from 1 April 2026).
| 1961 Act | Subject | 2025 Act |
|---|---|---|
| 92A | Meaning of associated enterprise | 162 |
| 92B | Meaning of international transaction | 163 |
| 92BA | Meaning of specified domestic transaction | 164 |
| 92CB | Power of Board to make safe harbour rules | 167 |
| 92CC | Advance pricing agreement | 168 |
| 92CD | Effect to advance pricing agreement | 169 |
| 92CE | Secondary adjustment in certain cases | 170 |
| 92D | Maintenance, keeping and furnishing of information and document by certain persons | 171 |
| 92F | Definitions (transfer pricing) | 173 |
| 93 | Avoidance of income-tax by transactions resulting in transfer of income to non-residents | 174 |
| 94 | Avoidance of tax by certain transactions in securities | 175 |
| 94A | Transactions with persons in notified jurisdictional areas | 176 |
| 95 | Applicability of General Anti-Avoidance Rule | 178 |
| 96 | Impermissible avoidance arrangement | 179 |
| 97 | Arrangement to lack commercial substance | 180 |
| 98 | Consequences of impermissible avoidance arrangement | 181 |
| 99 | Treatment of connected person and accommodating party | 182 |
| 100 | Application of GAAR chapter | 183 |
| 101 | Framing of guidelines | 183 |
| 102 | Definitions (GAAR) | 184 |
Source: CBDT mapping of sections, Income-tax Act 1961 to Income-tax Act 2025.
Renumbered. Arm's length computation (92C) and TPO reference (92CA) are on the section 92C page; accountant's report (92E) is section 172. Finance Act 2026 also amended section 162(2)(c), the TPO deadline in 166(7) (31 January / 31 October) and the modified return after an APA (169(1)).
Section 92A of the Income-tax Act, 1961 (Meaning of associated enterprise) corresponds to section 162 of the Income-tax Act, 2025, which applies from 1 April 2026 (tax year 2026-27).
Section 92B of the Income-tax Act, 1961 (Meaning of international transaction) corresponds to section 163 of the Income-tax Act, 2025, which applies from 1 April 2026 (tax year 2026-27).
Section 92BA of the Income-tax Act, 1961 (Meaning of specified domestic transaction) corresponds to section 164 of the Income-tax Act, 2025, which applies from 1 April 2026 (tax year 2026-27).
Section 92CB of the Income-tax Act, 1961 (Power of Board to make safe harbour rules) corresponds to section 167 of the Income-tax Act, 2025, which applies from 1 April 2026 (tax year 2026-27).
Section 92CC of the Income-tax Act, 1961 (Advance pricing agreement) corresponds to section 168 of the Income-tax Act, 2025, which applies from 1 April 2026 (tax year 2026-27).
Section 92CD of the Income-tax Act, 1961 (Effect to advance pricing agreement) corresponds to section 169 of the Income-tax Act, 2025, which applies from 1 April 2026 (tax year 2026-27).
Renumbered. Arm's length computation (92C) and TPO reference (92CA) are on the section 92C page; accountant's report (92E) is section 172. Finance Act 2026 also amended section 162(2)(c), the TPO deadline in 166(7) (31 January / 31 October) and the modified return after an APA (169(1)).