Income Tax Form No. 47 is prescribed as a certificate from an accountant in connection with the exercise of option for determination of arm’s length price (ALP) under section 166(9) of the Income-tax Act, 2025. The form serves as a confirmation by an accountant that the international transactions or specified domestic transactions satisfy the conditions prescribed under Rule 82(5) of the Income-tax Rules, 2026.
Form No. 47 accompanies Form No. 46, which is filed by an assessee to exercise the option for determination of arm’s length price for international or specified domestic transactions for multiple tax years through a single proceeding. The accountant’s certificate confirms compliance with the conditions required for exercising this option.
The timeline for furnishing Form No. 47 is linked to the filing of Form No. 46. Both forms must be submitted within the period beginning from the end of the third tax year and ending on 30 June immediately succeeding the third tax year. This ensures that the accountant’s certification is available at the time the option for ALP determination is exercised.
Form No. 47 can only be submitted online through the Income Tax e-Filing portal. It cannot be filed offline. The form does not require any supporting documents to be attached. Its purpose is limited to certification by an accountant confirming that the relevant transactions meet the prescribed conditions under Rule 82 for the option exercised by the assessee under section 166(9).
FAQs on Income Tax Form 47: Certificate of an accountant under section 166
Certificate of an accountant under section 166(9) of the Income-tax Act, 2025
| Name of form as per I.T. Rules, 1962 | NA | Name of form as per I.T. Rules, 2026 | 47 |
| Corresponding section of I.T. Act, 1961 | 92CA(3B) | Corresponding section of I.T. Act, 2025 | 166(9) |
| Corresponding Rule of I.T. Rules, 1962 | NA | Corresponding Rule of I.T. Rules, 2026 | 82 |
Q1: What is Form No. 47?
Ans: It is a certificate from an accountant that the international transactions or the specified domestic transactions fulfil the conditions prescribed in rule 82(5).
Q2: What is the time limit for filing Form No. 47?
Ans: Form No. 47 shall be furnished along with Form No. 46 i.e., within the period, beginning from the end of the third tax year and ending on the 30th day of June succeeding the third tax year.
Q3: Can Form No. 47 be filed offline?
Ans: No. Form No. 47 can only be submitted online through the Income Tax e-Filing portal.
Q 4: What documents are required to file with Form No. 47?
Ans: No documents are required to be filed with Form No. 47.
Comprehensive note on new Forms (Form No. 47)
Form No. 47
This is a certificate from an accountant, accompanying the Form No. 46, certifying the fulfilment of the conditions prescribed under the rule 82 for the option exercised by the assessee under section 166(9).

