The Income-tax Act 2025: what changes for your transfer pricing practice
From tax year 2026-27, India's transfer pricing regime moves from the 1961 Act to the Income-tax Act 2025. Sections are renumbered, forms are renamed — Form 3CEB becomes Form 48 — and every template, checklist, and internal tool in your firm goes stale at once. Here is the quick-reference mapping.
| Topic | 1961 Act (until FY 2025-26) | 2025 Act (from FY 2026-27) |
|---|---|---|
| Governing Act | Income-tax Act, 1961 | Income-tax Act, 2025 (from tax year 2026-27) |
| TP chapter | Chapter X, Sections 92–92F | Sections 161–174 |
| Accountant's report | Section 92E / Form 3CEB | Section 172 / Form 48 |
| ALP computation | Section 92C, Rules 10A–10E | Section 165 + new rules |
| Documentation | Section 92D / Rule 10D | Section 171 + new rules |
| Safe harbour | Rule 10TA–10TE (₹300 Cr caps) | Draft: consolidated IT services @ 15.5%, ₹2,000 Cr cap |
| Penalties | 271AA / 271BA / 271G | Renumbered under the 2025 Act — verify final mapping |
What you should do this season
- • FY 2025-26 filings (due Oct–Nov 2026) still use the 1961-Act forms — Form 3CEB, 3CEAA, 3CEAD as usual.
- • Engagement letters spanning FY 2026-27 should reference both regimes to avoid re-papering.
- • Safe harbour advice given now should flag the draft 2025-Act rules (consolidated IT-services category at 15.5%, ₹2,000 crore cap) — clients above today's ₹300 crore cap may become eligible.
- • Templates and internal checklists need a dual-regime version — or a tool that switches labels by financial year automatically.
TP Report is regime-aware out of the box.
Pick the financial year and every generated document, deadline, and form label switches between the 1961 Act and the 2025 Act automatically. No stale templates, no missed renumbering.
Start your free trialDisclaimer: section and form mappings under the Income-tax Act 2025 reflect the Act as enacted and draft rules in circulation; final CBDT notifications may differ. Verify against the notified rules before filing. This guide is editorial, not legal advice.