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ITA 1961 → DTC 2025Transfer Pricing

Section 92C Section 183

Computation of arm's length price

RetainedVery High - The operational core of all Transfer Pricing studies.

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.

Old Law (ITA 1961)Ch: X

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).

New Law (DTC 2025)Ch: XII

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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