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ITA 1961 → DTC 2025Transfer Pricing

Section 92D Section 188

Maintenance and keeping of information and document by persons entering into an international transaction

RetainedHigh - Forms the core of the TP compliance burden.

Quick Answer

Section 92D of the Income Tax Act, 1961 (Maintenance and keeping of information and document by persons entering into an international transaction) corresponds to Section 188 of the Direct Tax Code 2025 (Income-tax Act, 2025), effective 1st April 2026. Status: Retained.

Old Law (ITA 1961)Ch: X

Sec 92D

Provision Summary

Mandates maintaining specific TP documents (Master File, Local File) and submitting Country-by-Country Reporting (CbCR).

New Law (DTC 2025)Ch: XII

Sec 188

Provision Summary

Retained. CbCR data is now shared instantly with treaty partner countries via automated OECD exchange networks.

Key Changes & Highlights

  • Document retention period tightly defined.

Related Sections

Frequently Asked Questions

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

Section 92D (Maintenance and keeping of information and document by persons entering into an international transaction) Mandates maintaining specific TP documents (Master File, Local File) and submitting Country-by-Country Reporting (CbCR).

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

Section 92D of the ITA 1961 maps to Section 188 of the Direct Tax Code 2025 (Income-tax Act, 2025), effective from 1st April 2026.

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

Section 92D is marked as "Retained" with status "Active". Impact: High - Forms the core of the TP compliance burden.

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

Document retention period tightly defined.

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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