Rules 112 and 113 of the Draft Income-tax Rules, 2026 lay down provisions relating to amendment of Advance Pricing Agreement (APA) applications and post-agreement compliance obligations. Under Rule 112, an applicant may request, in writing, an amendment to the APA application at any stage prior to finalisation of the agreement’s terms. Such amendment may be permitted by the Principal Chief Commissioner of Income-tax (International Taxation) in case of unilateral agreements, or by the competent authority of India in case of bilateral or multilateral agreements, provided the amendment does not alter the original nature of the application. Rule 113 mandates that every assessee covered under an APA must furnish an Annual Compliance Report in Form No. 52 for each year covered by the agreement. This report must be submitted within thirty days of the due date for filing the income-tax return for the relevant year or within ninety days of entering into the agreement, whichever is later. The Principal Chief Commissioner is required to forward copies of the report to the competent authority of India, the jurisdictional Commissioner of Income-tax, and the Transfer Pricing Officer, thereby ensuring coordinated monitoring of compliance.
Extract of Rule No. 112 and 113 of Draft Income-tax Rules, 2026
Rule 112
Amendments to Application.
(1) An applicant may request in writing for an amendment to an application at any stage, before the finalisation of the terms of the agreement.
(2) The Principal Chief Commissioner of Income-tax (International Taxation) (for unilateral agreement) or the competent authority of India (for bilateral or multilateral agreement) may, allow the amendment to the application, if such an amendment does not have effect of altering the nature of the application as originally filed.
Rule 113
Furnishing of Annual Compliance Report.
(1) The assessee shall furnish an annual compliance report to the Principal Chief Commissioner of Income-tax (International Taxation) for each year covered in the agreement.
(2) The annual compliance report shall be in Form No. 52. (3) The assessee shall file the annual compliance report for each year covered in the agreement, within thirty days of the due date of filing the income-tax return for that year, or within ninety days of entering into an agreement, whichever is later and send it to Principal Chief Commissioner of Income-tax (International Taxation).
(4) The Principal Chief Commissioner of Income-tax (International Taxation) shall send one copy of annual compliance report to the competent authority of India, one copy to the Commissioner of Income-tax who has the jurisdiction over the income-tax assessment of the assessee and one copy to the Transfer Pricing Officer having the jurisdiction over the assessee.
