Chapter X of the Income-tax Act, 2025 runs from section 161 to section 177 and covers special provisions relating to avoidance of tax. Its 17 sections replace 17 sections of the Income-tax Act, 1961. This guide gives the complete section-by-section mapping between the two Acts.
What Chapter X covers
Chapter X is the transfer pricing and anti-avoidance chapter — arm's length pricing, associated enterprises, APAs, safe harbours, secondary adjustments, thin capitalisation and documentation.
Chapter X contains 17 sections (sections 161 to 177). Between them they carry forward the substance of 17 sections of the Income-tax Act, 1961.
The Income-tax Act, 2025 received Presidential assent on 21 August 2025 and takes effect from 1 April 2026. The Income-tax Act, 1961 continues to govern every tax year up to 31 March 2026, and all assessments, appeals, penalties and prosecutions relating to those years are completed under the old Act by virtue of the repeal and savings provision in section 536. The mapping on this page is drawn from the section-wise concordance published with the Act, including the corrigenda notified in the Gazette on 3 September 2025.
What changed in Chapter X
- The numbering is a clean shift: 92 becomes 161, 92A becomes 162, 92B becomes 163, 92C becomes 165, 92CA becomes 166 and 92CE becomes 170.
- Section 171 carries section 92D (maintenance of information and documents) and section 172 carries section 92E (the accountant's report), which is why the penalty sections in Chapter XXI refer to section 171 and section 172.
- Section 177 carries section 94B, the interest deduction limitation for cross-border borrowings from associated enterprises.
- Section 176 carries section 94A, the notified jurisdictional area provisions.
Chapter X: complete section mapping (2025 → 1961)
Every section of Chapter X is listed below with the section or sections of the Income-tax Act, 1961 that it corresponds to. Where a section is marked as read with a Schedule, the operative detail sits in that Schedule rather than in the section itself.
| New section (2025) | Provision | Corresponding 1961 section(s) |
|---|---|---|
| 161 | Computation of income from international transaction and Specified domestic Transaction having regard to arm’s length price | 92 |
| 162 | Meaning of associated enterprise | 92A |
| 163 | Meaning of international transaction | 92B |
| 164 | Meaning of specified domestic transaction | 92BA |
| 165 | Determination of arm’s length price | 92C |
| 166 | Reference to Transfer Pricing Officer | 92CA |
| 167 | Power of Board to make safe harbour rules | 92CB |
| 168 | Advance pricing agreement | 92CC |
| 169 | Effect to advance pricing agreement | 92CD |
| 170 | Secondary adjustment in certain cases | 92CE |
| 171 | Maintenance, keeping and furnishing of information and document by certain persons | 92D |
| 172 | Report from an accountant to be furnished by persons entering into international transaction or specified domestic transaction | 92E |
| 173 | Definitions of certain terms relevant to determination of arm’s length price, etc | 92F |
| 174 | Avoidance of income-tax by transactions resulting in transfer of income to non-residents | 93 |
| 175 | Avoidance of tax by certain transactions in securities | 94 |
| 176 | Special measures in respect of transactions with persons located in notified jurisdictional area | 94A |
| 177 | Limitation on interest deduction in certain cases | 94B |
How to use this mapping
- Working on a year up to 2025-26? Use the 1961 section in the right-hand column. The old Act governs those years under section 536.
- Working on tax year 2026-27 onwards? Use the new section number in the left-hand column, and read the section text rather than assuming the old provision was copied verbatim.
- Drafting a reply or an appeal? Cite the section that applies to the year in dispute, not the section in force when you are writing.
- Updating templates and software? Sections that merged — shown where one new section maps to several old ones — need the most attention, because a single new provision now carries what were separate conditions.
This page is a structural mapping guide, not tax advice. A corresponding section is not always an identical section — several provisions were merged, split or re-worded when they were carried over. Always read the actual text of the new section before relying on it, and check for later amendments, rules and CBDT notifications.