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ITA 1961 → DTC 2025Transfer Pricing

Section 92F Section 190

Definitions of certain terms relevant to computation of arm's length price

RetainedMedium - Keeps the TP laws updated with modern tech business models.

Quick Answer

Section 92F of the Income Tax Act, 1961 (Definitions of certain terms relevant to computation of arm's length price) corresponds to Section 190 of the Direct Tax Code 2025 (Income-tax Act, 2025), effective 1st April 2026. Status: Retained.

Old Law (ITA 1961)Ch: X

Sec 92F

Provision Summary

Defines key terms for TP such as 'accountant', 'arm's length price', 'enterprise', and 'specified date'.

New Law (DTC 2025)Ch: XII

Sec 190

Provision Summary

Retained. The definition of 'enterprise' is broadened to include entities providing exclusively digital or data-driven services.

Key Changes & Highlights

  • Data servers and algorithms explicitly recognized under the definition of enterprise assets.

Related Sections

Frequently Asked Questions

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

Section 92F (Definitions of certain terms relevant to computation of arm's length price) Defines key terms for TP such as 'accountant', 'arm's length price', 'enterprise', and 'specified date'.

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

Section 92F of the ITA 1961 maps to Section 190 of the Direct Tax Code 2025 (Income-tax Act, 2025), effective from 1st April 2026.

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

Section 92F is marked as "Retained" with status "Active". Impact: Medium - Keeps the TP laws updated with modern tech business models.

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

Data servers and algorithms explicitly recognized under the definition of enterprise assets.

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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