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ITA 1961 → DTC 2025Transfer Pricing

Section 92CB Section 185

Power of Board to make safe harbour rules

RetainedMedium - Provides massive relief and certainty to mid-sized IT exporters.

Quick Answer

Section 92CB of the Income Tax Act, 1961 (Power of Board to make safe harbour rules) corresponds to Section 185 of the Direct Tax Code 2025 (Income-tax Act, 2025), effective 1st April 2026. Status: Retained.

Old Law (ITA 1961)Ch: X

Sec 92CB

Provision Summary

Allows CBDT to declare safe harbour rules (acceptable profit margins) to avoid lengthy TP litigation.

New Law (DTC 2025)Ch: XII

Sec 185

Provision Summary

Retained. Focus is on expanding safe harbours for IT/ITES and routine BPO services to reduce compliance burden.

Key Changes & Highlights

  • Rules updated dynamically based on real-time global economic data.

Frequently Asked Questions

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

Section 92CB (Power of Board to make safe harbour rules) Allows CBDT to declare safe harbour rules (acceptable profit margins) to avoid lengthy TP litigation.

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

Section 92CB of the ITA 1961 maps to Section 185 of the Direct Tax Code 2025 (Income-tax Act, 2025), effective from 1st April 2026.

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

Section 92CB is marked as "Retained" with status "Active". Impact: Medium - Provides massive relief and certainty to mid-sized IT exporters.

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

Rules updated dynamically based on real-time global economic data.

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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