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 Income-tax Act, 2025, effective 1st April 2026. Status: Retained.
What changed for Section 92C
Section 92C of the 1961 Act sets out the rules on 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).
From 1st April 2026, the same subject sits at Section 183 of the Income-tax Act, 2025 — retained and renumbered as Section 183 of the Income-tax Act, 2025. Retained. The 'Most Appropriate Method' remains the guiding principle.
For Section 92C, the practical impact is rated Very High. The operational core of all Transfer Pricing studies.
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 is Section 92C of the Income Tax Act, 1961 about?
Section 92C of the Income Tax Act, 1961 covers 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).
Which section replaces Section 92C in the Income-tax Act, 2025?
Section 92C of the Income Tax Act, 1961 maps to Section 183 of the Income-tax Act, 2025, effective 1st April 2026 (status: Retained). Retained. The 'Most Appropriate Method' remains the guiding principle.
What is the impact of the change to Section 92C under the new tax code?
The transition impact for Section 92C is rated Very High. The operational core of all Transfer Pricing studies.
What should I watch out for when Section 92C moves to the 2025 code?
Tolerance band algorithms updated to handle hyper-volatile industries like tech startups. These points are specific to Section 92C (Computation of arm's length price).
Disclaimer: This mapping of Section 92C (Computation of arm's length price) to Section 183 of the Income-tax Act, 2025 is for educational and reference purposes only, based on publicly available drafts and circulars. As Section 92C is currently marked Retained, always confirm its treatment with a qualified Chartered Accountant before filing or making compliance decisions.
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