Section 92C → Section 183
Computation of arm's length price
Quick Answer
Section 92C of the Income Tax Act, 1961 (Computation of arm's length price) corresponds to Section 183 of the Direct Tax Code 2025 (Income-tax Act, 2025), effective 1st April 2026. Status: Retained.
Sec 92C
Provision Summary
Lists the valid methods to calculate ALP: Comparable Uncontrolled Price (CUP), Resale Price, Cost Plus, Profit Split, and Transactional Net Margin (TNMM).
Sec 183
Provision Summary
Retained. The 'Most Appropriate Method' remains the guiding principle.
Key Changes & Highlights
- Tolerance band algorithms updated to handle hyper-volatile industries like tech startups.
Related Sections
Frequently Asked Questions
What does Section 92C of the Income Tax Act 1961 deal with?
Section 92C (Computation of arm's length price) Lists the valid methods to calculate ALP: Comparable Uncontrolled Price (CUP), Resale Price, Cost Plus, Profit Split, and Transactional Net Margin (TNMM).
What is the new section number for Section 92C under the Direct Tax Code 2025?
Section 92C of the ITA 1961 maps to Section 183 of the Direct Tax Code 2025 (Income-tax Act, 2025), effective from 1st April 2026.
What is the status of Section 92C under the new tax code?
Section 92C is marked as "Retained" with status "Active". Impact: Very High - The operational core of all Transfer Pricing studies.
What are the key changes to Section 92C under DTC 2025?
Tolerance band algorithms updated to handle hyper-volatile industries like tech startups.
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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