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 Direct Tax Code 2025 (Income-tax Act, 2025), effective 1st April 2026. Status: Retained.
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 (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).
What is the new section number for Section 92CC under the Direct Tax Code 2025?
Section 92CC of the ITA 1961 maps to Section 186 of the Direct Tax Code 2025 (Income-tax Act, 2025), effective from 1st April 2026.
What is the status of Section 92CC under the new tax code?
Section 92CC is marked as "Retained" with status "Active". Impact: Critical - Gives large MNCs absolute tax certainty in India.
What are the key changes to Section 92CC under DTC 2025?
Bilateral APAs highly prioritized to prevent international tax disputes.
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.
Need professional help on Section 92CC?
Compare trusted providers — both offer DTC 2025-ready CA services.
*Affiliate links — we may earn a small commission at no extra cost to you. Disclosure.
Want to calculate tax on this section?