Draft Rule 124 of the Income-tax Rules, 2026 sets out the procedure, timelines, and forms for furnishing country-by-country reports under section 511, triggered by a ₹6,400 crore consolidated revenue threshold.
Rule 122 of the Draft Income-tax Rules, 2026 requires the foreign associated enterprise to initiate an APA process before India begins bilateral or multilateral negotiations, ensuring coordinated and mutually acceptable transfer pricing agreements.
Draft Rule 123 of the Income-tax Rules, 2026 requires constituent entities of large international groups to maintain and furnish extensive documentation when revenue and transaction thresholds are exceeded.
Rule 121 of the Draft Income-tax Rules, 2026 lays down a structured mutual agreement procedure with defined timelines and safeguards, ensuring transparent resolution of cross-border tax disputes without reducing declared income in India.
Rule 118 introduces a structured computation mechanism to reduce tax payable when past income from APA or secondary adjustments is included in book profits, ensuring no excess tax burden while adjusting tax credit accordingly.
Rules 119 and 120 clarify renewal of agreements via fresh Form 54 application and confirm Chapter X applies until execution, with treaty-based negotiation for bilateral deals.
Rule 114 of the Draft Income-tax Rules, 2026 requires the Transfer Pricing Officer to conduct annual compliance audits of APAs, ensuring adherence to agreed terms and critical assumptions.
Rule 117 requires filing of modified returns, payment of additional tax, and withdrawal of pending appeals to give effect to rollback provisions, failing which the agreement may be cancelled.
The Supreme Court refused to interfere with the High Court’s order setting aside penalty under Section 271D due to absence of recorded satisfaction under Section 269SS. The SLP was dismissed on grounds of delay and merits.
Rules 112 and 113 of the Draft Income-tax Rules, 2026 allow amendment of APA applications before finalisation and mandate timely filing of annual compliance reports to ensure continued adherence.
