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ITA 1961 → ITA 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 Income-tax Act, 2025, effective 1st April 2026. Status: Retained.

What changed for Section 92B

In the 1961 statute, Section 92B deals with meaning of international transaction. Defines transactions between two or more associated enterprises, where at least one is a non-resident.

The new code maps this to Section 182: the provision is retained and renumbered as Section 182 of the Income-tax Act, 2025, applying from 1st April 2026. Expanded. Intangible property transfers (like sharing customer data or algorithms) are strictly classified as international transactions.

On the ground, changes to Section 92B carry a High impact. Establishes the boundary of what requires an ALP report.

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 (ITA 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 of the Income Tax Act, 1961 covers meaning of international transaction. Defines transactions between two or more associated enterprises, where at least one is a non-resident.

Where does Section 92B of the ITA 1961 go under the Income-tax Act, 2025?

Section 92B of the Income Tax Act, 1961 maps to Section 182 of the Income-tax Act, 2025, effective 1st April 2026 (status: Retained). Expanded. Intangible property transfers (like sharing customer data or algorithms) are strictly classified as international transactions.

Why does the change to Section 92B matter for taxpayers?

The transition impact for Section 92B is rated High. Establishes the boundary of what requires an ALP report.

What are the key changes to Section 92B under the Income-tax Act, 2025?

Deemed international transactions tightened using the substance-over-form doctrine. These points are specific to Section 92B (Meaning of international transaction).

Disclaimer: This mapping of Section 92B (Meaning of international transaction) to Section 182 of the Income-tax Act, 2025 is for educational and reference purposes only, based on publicly available drafts and circulars. As Section 92B is currently marked Retained, always confirm its treatment with a qualified Chartered Accountant before filing or making compliance decisions.

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