New Provision
Section 167, IT Act 2025
Replaces (IT Act 1961)
247 92CB
Chapter
Chapter X — Special Provisions
Effective From
1 April 2026
Statutory Text — Section 167
(1) The determination of— (a) income referred to in section 9(2); or (b) arm’s length price under section 165 or 166, shall be subject to safe harbour rules. (2) For the purposes of sub-section (1), the Board may make rules for safe harbour. (3) For the purposes of this section, “safe harbour” means circumstances in which the income-tax authorities shall accept,––
(a) the transfer price; or (b) the income, deemed to accrue or arise under section 9(2), declared by the assessee.
Shahi & Co. — Our Understanding
This section is part of Chapter X of the Income Tax Act, 2025, effective from 1 April 2026. It carries forward the corresponding provision from the Income Tax Act, 1961 with simplified language and restructured drafting.
Practical Note: For specific guidance on how this provision applies to your situation, consult a qualified Chartered Accountant. The Income Tax Act, 2025 retains the substance of the old law while making it more accessible.
Shahi & Co., Chartered Accountants
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Disclaimer: This is a reproduction of Section 167 of the Income Tax Act, 2025 (No. 30 of 2025) as published in the Official Gazette of India (CG-DL-E-22082025-265620) for informational and reference purposes only. Shahi & Co., Chartered Accountants makes no warranty as to completeness or accuracy. For the official authenticated text refer to
egazette.gov.in or
incometaxindia.gov.in. This does not constitute legal or tax advice.