Section 92 → Section 180
Computation of income from international transaction having regard to arm's length price
Quick Answer
Section 92 of the Income Tax Act, 1961 (Computation of income from international transaction having regard to arm's length price) corresponds to Section 180 of the Direct Tax Code 2025 (Income-tax Act, 2025), effective 1st April 2026. Status: Retained.
Sec 92
Provision Summary
The charging section for Transfer Pricing. Mandates that any income arising from an international transaction must be computed using Arm's Length Price (ALP).
Sec 180
Provision Summary
Retained verbatim. The cornerstone of anti-profit shifting laws.
Key Changes & Highlights
- Explicitly states that if ALP calculation reduces the total taxable income in India, the provision will not apply.
Related Sections
Frequently Asked Questions
What does Section 92 of the Income Tax Act 1961 deal with?
Section 92 (Computation of income from international transaction having regard to arm's length price) The charging section for Transfer Pricing. Mandates that any income arising from an international transaction must be computed using Arm's Length Price (ALP).
What is the new section number for Section 92 under the Direct Tax Code 2025?
Section 92 of the ITA 1961 maps to Section 180 of the Direct Tax Code 2025 (Income-tax Act, 2025), effective from 1st April 2026.
What is the status of Section 92 under the new tax code?
Section 92 is marked as "Retained" with status "Active". Impact: Critical - Governs all Multi-National Corporations (MNCs) operating in India.
What are the key changes to Section 92 under DTC 2025?
Explicitly states that if ALP calculation reduces the total taxable income in India, the provision will not apply.
Disclaimer: This page is for educational and reference purposes only. Section mappings are based on publicly available drafts and circulars. Always consult a qualified Chartered Accountant before filing or making compliance decisions under the Direct Tax Code 2025.
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