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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 Income-tax Act, 2025, effective 1st April 2026. Status: Retained.

What changed for Section 92F

Under the Income Tax Act, 1961, Section 92F governs 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'.

Under the Income-tax Act, 2025 (effective 1st April 2026), Section 92F is retained and renumbered as Section 190 of the Income-tax Act, 2025. Retained. The definition of 'enterprise' is broadened to include entities providing exclusively digital or data-driven services.

The transition impact on Section 92F is assessed as Medium. Keeps the TP laws updated with modern tech business models.

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 (ITA 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

Which subject does Section 92F of the 1961 Act cover?

Section 92F of the Income Tax Act, 1961 covers 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 Income-tax Act, 2025?

Section 92F of the Income Tax Act, 1961 maps to Section 190 of the Income-tax Act, 2025, effective 1st April 2026 (status: Retained). Retained. The definition of 'enterprise' is broadened to include entities providing exclusively digital or data-driven services.

How does the Income-tax Act, 2025 affect Section 92F in practice?

The transition impact for Section 92F is rated Medium. Keeps the TP laws updated with modern tech business models.

What is new about Section 92F under the Income-tax Act, 2025?

Data servers and algorithms explicitly recognized under the definition of enterprise assets. These points are specific to Section 92F (Definitions of certain terms relevant to computation of arm's length price).

Disclaimer: This mapping of Section 92F (Definitions of certain terms relevant to computation of arm's length price) to Section 190 of the Income-tax Act, 2025 is for educational and reference purposes only, based on publicly available drafts and circulars. As Section 92F is currently marked Retained, always confirm its treatment with a qualified Chartered Accountant before filing or making compliance decisions.

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