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ITA 1961 → DTC 2025Transfer Pricing

Section 92B Section 182

Meaning of international transaction

RetainedHigh - Establishes the boundary of what requires an ALP report.

Quick Answer

Section 92B of the Income Tax Act, 1961 (Meaning of international transaction) corresponds to Section 182 of the Direct Tax Code 2025 (Income-tax Act, 2025), effective 1st April 2026. Status: Retained.

Old Law (ITA 1961)Ch: X

Sec 92B

Provision Summary

Defines transactions between two or more associated enterprises, where at least one is a non-resident.

New Law (DTC 2025)Ch: XII

Sec 182

Provision Summary

Expanded. Intangible property transfers (like sharing customer data or algorithms) are strictly classified as international transactions.

Key Changes & Highlights

  • Deemed international transactions tightened using the substance-over-form doctrine.

Related Sections

Frequently Asked Questions

What does Section 92B of the Income Tax Act 1961 deal with?

Section 92B (Meaning of international transaction) Defines transactions between two or more associated enterprises, where at least one is a non-resident.

What is the new section number for Section 92B under the Direct Tax Code 2025?

Section 92B of the ITA 1961 maps to Section 182 of the Direct Tax Code 2025 (Income-tax Act, 2025), effective from 1st April 2026.

What is the status of Section 92B under the new tax code?

Section 92B is marked as "Retained" with status "Active". Impact: High - Establishes the boundary of what requires an ALP report.

What are the key changes to Section 92B under DTC 2025?

Deemed international transactions tightened using the substance-over-form doctrine.

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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