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ITA 1961 → DTC 2025Anti-Avoidance

Section 94A Section 192

Special measures in respect of transactions with persons located in notified jurisdictional area

RetainedHigh - Severely restricts businesses from routing funds through non-compliant island nations.

Quick Answer

Section 94A of the Income Tax Act, 1961 (Special measures in respect of transactions with persons located in notified jurisdictional area) corresponds to Section 192 of the Direct Tax Code 2025 (Income-tax Act, 2025), effective 1st April 2026. Status: Retained.

Old Law (ITA 1961)Ch: X

Sec 94A

Provision Summary

If an assessee enters into a transaction with a person in a notified non-cooperative country (tax haven), TP rules automatically apply, and a flat 30% TDS is mandated.

New Law (DTC 2025)Ch: XII

Sec 192

Provision Summary

Retained. Acts as India's primary defense against black-listed tax havens.

Key Changes & Highlights

  • TDS rates and disallowances become highly punitive for transactions passing through these jurisdictions.

Related Sections

Frequently Asked Questions

What does Section 94A of the Income Tax Act 1961 deal with?

Section 94A (Special measures in respect of transactions with persons located in notified jurisdictional area) If an assessee enters into a transaction with a person in a notified non-cooperative country (tax haven), TP rules automatically apply, and a flat 30% TDS is mandated.

What is the new section number for Section 94A under the Direct Tax Code 2025?

Section 94A of the ITA 1961 maps to Section 192 of the Direct Tax Code 2025 (Income-tax Act, 2025), effective from 1st April 2026.

What is the status of Section 94A under the new tax code?

Section 94A is marked as "Retained" with status "Active". Impact: High - Severely restricts businesses from routing funds through non-compliant island nations.

What are the key changes to Section 94A under DTC 2025?

TDS rates and disallowances become highly punitive for transactions passing through these jurisdictions.

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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