Section 92CC → Section 186
Advance Pricing Agreement (APA)
Quick Answer
Section 92CC of the Income Tax Act, 1961 (Advance Pricing Agreement (APA)) corresponds to Section 186 of the Income-tax Act, 2025, effective 1st April 2026. Status: Retained.
What changed for Section 92CC
Section 92CC of the 1961 Act sets out the rules on advance pricing agreement (APA). Allows taxpayers to negotiate and fix their transfer pricing methodology with the CBDT for up to 5 future years (and 4 rollback years).
The new code maps this to Section 186: the provision is retained and renumbered as Section 186 of the Income-tax Act, 2025, applying from 1st April 2026. Retained and heavily promoted. APA negotiation teams expanded to clear backlogs faster.
On the ground, changes to Section 92CC carry a Critical impact. Gives large MNCs absolute tax certainty in India.
Sec 92CC
Provision Summary
Allows taxpayers to negotiate and fix their transfer pricing methodology with the CBDT for up to 5 future years (and 4 rollback years).
Sec 186
Provision Summary
Retained and heavily promoted. APA negotiation teams expanded to clear backlogs faster.
Key Changes & Highlights
- Bilateral APAs highly prioritized to prevent international tax disputes.
Related Sections
Frequently Asked Questions
What does Section 92CC of the Income Tax Act 1961 deal with?
Section 92CC of the Income Tax Act, 1961 covers advance pricing agreement (APA). Allows taxpayers to negotiate and fix their transfer pricing methodology with the CBDT for up to 5 future years (and 4 rollback years).
Where does Section 92CC of the ITA 1961 go under the Income-tax Act, 2025?
Section 92CC of the Income Tax Act, 1961 maps to Section 186 of the Income-tax Act, 2025, effective 1st April 2026 (status: Retained). Retained and heavily promoted. APA negotiation teams expanded to clear backlogs faster.
Why does the change to Section 92CC matter for taxpayers?
The transition impact for Section 92CC is rated Critical. Gives large MNCs absolute tax certainty in India.
What are the key changes to Section 92CC under the Income-tax Act, 2025?
Bilateral APAs highly prioritized to prevent international tax disputes. These points are specific to Section 92CC (Advance Pricing Agreement (APA)).
Disclaimer: This mapping of Section 92CC (Advance Pricing Agreement (APA)) to Section 186 of the Income-tax Act, 2025 is for educational and reference purposes only, based on publicly available drafts and circulars. As Section 92CC is currently marked Retained, always confirm its treatment with a qualified Chartered Accountant before filing or making compliance decisions.
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