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ITA 1961 → DTC 2025Transfer Pricing

Section 92CA Section 184

Reference to Transfer Pricing Officer (TPO)

RetainedHigh - Initiates the dreaded dedicated TP scrutiny.

Quick Answer

Section 92CA of the Income Tax Act, 1961 (Reference to Transfer Pricing Officer (TPO)) corresponds to Section 184 of the Direct Tax Code 2025 (Income-tax Act, 2025), effective 1st April 2026. Status: Retained.

Old Law (ITA 1961)Ch: X

Sec 92CA

Provision Summary

Allows the Assessing Officer to refer the computation of ALP to a specialized Transfer Pricing Officer.

New Law (DTC 2025)Ch: XII

Sec 184

Provision Summary

Retained. Risk-assessment algorithms now auto-flag cases for compulsory TPO reference without human intervention.

Key Changes & Highlights

  • TPO proceedings are now entirely faceless.

Related Sections

Frequently Asked Questions

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

Section 92CA (Reference to Transfer Pricing Officer (TPO)) Allows the Assessing Officer to refer the computation of ALP to a specialized Transfer Pricing Officer.

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

Section 92CA of the ITA 1961 maps to Section 184 of the Direct Tax Code 2025 (Income-tax Act, 2025), effective from 1st April 2026.

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

Section 92CA is marked as "Retained" with status "Active". Impact: High - Initiates the dreaded dedicated TP scrutiny.

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

TPO proceedings are now entirely faceless.

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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