Rule 200 of the Draft Income-tax Rules, 2026 lays down the procedure and fee structure for filing an application for advance ruling under section 383. An application may be made by a resident or non-resident applicant in Form No. 120, duly verified in the prescribed manner. The fee payable depends on the category of applicant and the amount of the transaction for which the ruling is sought. For non-resident applicants under section 380(a)(i) and specified resident applicants under section 380(a)(ii), the fee is ₹2 lakh where the transaction amount is below ₹100 crore, ₹5 lakh where it is between ₹100 crore and ₹300 crore, and ₹1 lakh where it exceeds ₹300 crore. For resident applicants under section 380(a)(iii), the fee is ₹5 lakh for transactions between ₹100 crore and ₹300 crore, and ₹10 lakh where it exceeds ₹300 crore. For any other applicant, the fee is ₹10,000 in all cases. The application, verification, annexures, and supporting documents must be signed or digitally signed and furnished through the registered email address as per rule 167, along with proof of payment of the prescribed fee.
Extract of Rule No. 200 of Draft Income-tax Rules, 2026
Rule 200
Application for obtaining an advance ruling under section 383 of the Act.
(1) An application for obtaining an advance ruling under section 383(1) of Chapter XVIII-D(2), shall be made by a resident or a non- resident applicant in Form No. 120 and verified in the manner indicated therein in accordance with this rule.
(2) The fees payable along with the application for advance ruling shall be in accordance with the following table:
| S. No. |
Specific Condition/ Category as per Chapter XVIII-D (2) | Amount of transaction of one or more transaction for which ruling is sought |
Fee |
| 1. | Seeking advance rulings in relation to the tax liability arising out of a transaction undertaken or proposed to be undertaken by a non-resident applicant under section 380(a)(i) or resident applicant under section 380(a)(ii). | Amount less than Rs. 100 crores. | Rs. 2 lakhs |
| Amount between Rs. 100 crore and Rs. 300 crores. | Rs. 5 lakhs | ||
| Amount more than Rs. 300 crores. | Rs. 1 lakhs | ||
| 2. | Seeking advance rulings in relation to the tax liability of a resident applicant, arising out of a transaction undertaken or proposed to be undertaken by a resident applicant under section 380(a)(iii) | Amount between Rs. 100 crore and Rs. 300 crores. | Rs. 5 lakhs |
| Amount more than Rs. 300 crores. | Rs. 10 lakhs | ||
| 3. | Any other applicant | In all cases | Rs. 10,000 |
(3) The application referred to in sub-rule (1), the verification appended thereto, the annexures to the said application and the statements and documents accompanying the annexures, shall be signed or digitally signed and furnished through registered email address by the person as provided in rule 167
(4) Every application in the Form as applicable shall be accompanied by the proof of payment of fees as specified in sub-rule (2).
