Section 92A → Section 181
Meaning of associated enterprise
Quick Answer
Section 92A of the Income Tax Act, 1961 (Meaning of associated enterprise) corresponds to Section 181 of the Direct Tax Code 2025 (Income-tax Act, 2025), effective 1st April 2026. Status: Retained.
Sec 92A
Provision Summary
Defines what constitutes an 'Associated Enterprise' based on shareholding (≥26%), control over board, or heavy financial dependency.
Sec 181
Provision Summary
Definition widened. Shadow directors and algorithmic control over supply chains now explicitly trigger the Associated Enterprise status.
Key Changes & Highlights
- Focus shifted from mere equity holding to 'de-facto' economic control.
Frequently Asked Questions
What does Section 92A of the Income Tax Act 1961 deal with?
Section 92A (Meaning of associated enterprise) Defines what constitutes an 'Associated Enterprise' based on shareholding (≥26%), control over board, or heavy financial dependency.
What is the new section number for Section 92A under the Direct Tax Code 2025?
Section 92A of the ITA 1961 maps to Section 181 of the Direct Tax Code 2025 (Income-tax Act, 2025), effective from 1st April 2026.
What is the status of Section 92A under the new tax code?
Section 92A is marked as "Retained" with status "Modified". Impact: High - Determines which entities get dragged into Transfer Pricing audits.
What are the key changes to Section 92A under DTC 2025?
Focus shifted from mere equity holding to 'de-facto' economic control.
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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