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ARTICLE · 09 JULY 2025

Transfer Pricing 2025

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The Income Tax Act, 1961 ("IT Act") contains a specific chapter, namely Chapter X, which deals with special anti-avoidance rules in the form of transfer pricing regulations as applicable to com¬panies entering into related-party transactions.

IndiaTax
Deepak Chopra
Deepak Chopra
Harpreet Singh Ajmani
Harpreet Singh Ajmani
Rohan Khare
Rohan Khare
Priyam Bhatnagar
Priyam Bhatnagar
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1. Rules Governing Transfer Pricing

1.1 Statutes and Regulations

The Income Tax Act, 1961 ("IT Act") contains a specific chapter, namely Chapter X, which deals with special anti-avoidance rules in the form of transfer pricing regulations as applicable to companies entering into related-party transactions. Sections 92 to 92F of the IT Act, which forms part of "Chapter X – Special provisions relating to avoidance of tax", deals with transfer pricing regulations mandating the determination of arm's length price of related-party transactions entered into by the taxpayer. These regulations are required to be read with Rules 10A to 10THD of the Income Tax Rules, 1962("IT Rules"). These regulations are also governed through the issuance of circulars as well as notifications by the Central Board of Direct Taxes (CBDT) from time to time.

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