Section 92CE → Section 187
Secondary adjustment in certain cases
Quick Answer
Section 92CE of the Income Tax Act, 1961 (Secondary adjustment in certain cases) corresponds to Section 187 of the Direct Tax Code 2025 (Income-tax Act, 2025), effective 1st April 2026. Status: Retained.
Sec 92CE
Provision Summary
If ALP adjustment exceeds Rs. 1 Crore, the excess money must actually be repatriated to India within 90 days. If not, interest is charged as if it was a loan.
Sec 187
Provision Summary
Retained verbatim. Ensures that paper adjustments actually result in real cash entering the Indian economy.
Key Changes & Highlights
- No change. Acts as a strict enforcement tool.
Frequently Asked Questions
What does Section 92CE of the Income Tax Act 1961 deal with?
Section 92CE (Secondary adjustment in certain cases) If ALP adjustment exceeds Rs. 1 Crore, the excess money must actually be repatriated to India within 90 days. If not, interest is charged as if it was a loan.
What is the new section number for Section 92CE under the Direct Tax Code 2025?
Section 92CE of the ITA 1961 maps to Section 187 of the Direct Tax Code 2025 (Income-tax Act, 2025), effective from 1st April 2026.
What is the status of Section 92CE under the new tax code?
Section 92CE is marked as "Retained" with status "Active". Impact: High - Forces MNCs to physically move cash to India after an audit addition.
What are the key changes to Section 92CE under DTC 2025?
No change. Acts as a strict enforcement tool.
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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