Rule 124 of the Draft Income-tax Rules, 2026 lays down the procedural framework for furnishing reports by international groups under section 511, primarily governing country-by-country reporting (CbCR) obligations. The designated income-tax authority for this purpose is the Joint Director notified by the Director General of Income-tax (Systems). The notification under section 511(1) must be made in Form No. 58 at least two months prior to the due date for furnishing the report. Every parent entity or alternate reporting entity resident in India is required to submit the report for each reporting accounting year in Form No. 59. Constituent entities covered under section 511(4) must file the report within twelve months from the end of the reporting accounting year. However, where the parent entity is located in a jurisdiction experiencing systemic failure and such failure has been intimated, the report must be submitted within six months from the end of the month in which such intimation is received. Information regarding the designated constituent entity must be furnished in Form No. 60. The rule specifies that the reporting obligation applies where the total consolidated group revenue equals or exceeds ₹6,400 crore, and prescribes the telegraphic transfer buying rate for conversion where revenue is denominated in foreign currency. Any revision or correction to Form No. 59 must be intimated to the Director General of Income-tax (Systems), ensuring structured compliance and timely cross-border tax transparency.
Extract of Rule No. 124 of Draft Income-tax Rules, 2026
Rule 124
Furnishing of report in respect of an international group under section 511.
(1) The income-tax authority for the purposes of section 511 shall be the Joint Director as may be designated by the Director General of Income-tax (Systems).
(2) The notification under section 511(1) shall be made in Form No. 58 two months prior to the due date for furnishing of report as specified under section 511(2).
(3) Every parent entity or the alternate reporting entity, as the case may be, resident in India, shall, for every reporting accounting year, furnish the report referred to in section 511(2) in Form No. 59.
(4) The period for furnishing of the report under sub-section (4) of section 511(4) by the constituent entity referred to in that sub-section shall be twelve months from the end of the reporting accounting year.
(5) In case the parent entity of the constituent entity is resident of a country or territory, where, there has been a systemic failure of the country or territory and the said failure has been intimated to such constituent entity, the period for submission of the report shall be six months from the end of the month in which said systemic failure has been intimated.
(6) The information required to be conveyed under section 511(5) regarding the designated constituent entity shall be furnished in Form No. 60
(7) For the purposes of section 511(8), the total consolidated group revenue of the international group shall be six thousand four hundred crore rupees.
(8) Where the total consolidated group revenue of the international group, as reflected in the consolidated financial statement, is in foreign currency, the rate of exchange for the calculation of the value in rupees of such total consolidated group revenue shall be the telegraphic transfer buying rate of such currency on the last day of the accounting year preceding the accounting year.
(9) Any revision or correction in the report furnished in the Form No. 59 shall be made by furnishing an intimation to the Director General of Income-tax (Systems).
(10) For the purposes of this rule, —
(a) “telegraphic transfer buying rate” shall have the same meaning as assigned to in rule 207;
(b) the terms “accounting year”, “consolidated financial statement” and “international group” shall have the same meaning as assigned in section 511(10).
