The Income Tax Department has issued FAQs and guidance on Form 52, the Annual Compliance Report (ACR) for Advance Pricing Agreements (APA) under Section 169 of the Income-tax Act, 2025, replacing Form 3CEF. The form is mandatory for taxpayers with unilateral, bilateral, or multilateral APAs and must be filed annually within prescribed timelines through the e-filing portal. Form 52 ensures that taxpayers confirm compliance with APA terms, including transfer pricing methodology and arm’s length price (ALP) determination. It introduces structured, tabular reporting of adjustments based on profit level indicators (PLI), replacing earlier generic disclosures. The annexures capture detailed computations, critical assumptions (such as FAR, AEs, invoicing, and compliance conditions), and deviations, if any. The form enhances transparency, standardisation, and audit efficiency while reducing ambiguity. Non-filing or incorrect filing may lead to APA cancellation. Overall, Form 52 strengthens compliance monitoring and facilitates effective transfer pricing audits.
Income Tax Department
Ministry of Finance, Government of India
FAQs on Income Tax Form 52: Annual Compliance Report on Advance Pricing Agreement
Form 52 – Frequently Asked Questions
Form of application under section 169 of the Income-tax Act, 2025
| Name of form as per I.T. Rules, 1962 | Form 3CEF |
Name of form as per I.T. Rules, 2026 | 52 |
| Corresponding section of I.T. Act, 1961 | 92CD | Corresponding section of I.T. Act, 2025 | 169 |
| Corresponding Rule of I.T. Rules, 1962 | 10-O | Corresponding Rule of I.T. Rules, 2026 | 113 |
Q1. What is Form 52?
Ans: Form 52 is an Annual Compliance Report on Advance Pricing Agreement (APA) under the Indian Income-tax Act, 2025. It is used by taxpayers who have entered into an APA with the Central Board of Direct Taxes (CBDT). The form is used to confirm that the terms and conditions agreed upon in the Advance Pricing Agreement have been complied with during the relevant financial year.
Q2. Who should file Form 52?
Ans: Any taxpayer who has a Unilateral, Bilateral, or Multilateral APA with Indian tax authorities should file Form 52.
Q3. Is Form 52 mandatory?
Ans: Form 52 is mandatory for applicants who have entered into an APA agreement.
Q4. What is the time limit for filing Form 52?
Ans: A separate report in Form 52 must be filed for each year covered by the APA, within thirty days of the due date of filing the income tax return for that year, or within ninety days of entering into an Advanced Pricing Agreement, whichever is later, as set out in Rule 113 of the Income-tax Rules, 2026.
Q5. How many times can Form 52 be filed in a year?
Ans: Form 52 can be filed once a year.
Q6. What documents are required to file Form 52?
Ans: All documents as agreed upon in the signed Advanced Pricing Agreement to justify the transfer pricing methodology and computation of arm’s length price are required at the time of filing.
Q7. Can I edit Form 52 after submission?
Ans: No. Once Form 52 is submitted and acknowledgment is generated, it cannot be edited. Ensure all details are correct before submission.
Q8. Can Form 52 be filed offline?
Ans: No. Form 52 can only be submitted online through the Income Tax e-Filing portal.
Q9. Why is Form 52 important and what are the changes in the current Form compared to the old Form 3CEF?
Ans: The form 52 is used to confirm that the terms and conditions agreed upon in the Advance Pricing Agreement have been complied with by the taxpayer during the relevant financial year.
- The erstwhile Form 3CEF had a set of very general queries regarding compliance with the terms set forth in the Agreement by the Applicant. For example, agreed profit level indicator (PLI) vs actual achievement, business model agreed upon vs actual business model adopted. Further, any variance from the critical assumptions agreed upon in the APA was required to be indicated in general terms by the Applicant, which could create avoidable confusion regarding compliance at the time of audit.
- In order to ensure clarity in compliance, tabular computation of adjustment in case of variation for various profit level indicators utilised in APAs has been introduced. Cases where multiple transactions could be aggregated with one PLI have also been accounted for.
- Further, specific Critical Assumptions laid down in APAs with regard to FAR of the applicant, Associated Enterprises (AEs), Invoicing and Credit terms and other compliances mandated in the APA have also been explicitly outlined in the Annexure to the Form. This shall ensure clarity and ease in compliance requirements for the Applicant.
Guidance Note on Income Tax Form 52: Annual Compliance Report on Advance Pricing Agreement
| Name of form as per I.T. Rules, 1962 | Form 3CEF | Name of form as per I.T. Rules, 2026 | 52 |
| Corresponding section of I.T. Act, 1961 | 92CD | Corresponding section of I.T. Act, 2025 | 169 |
| Corresponding Rule of I.T. Rules, 1962 | 10-O | Corresponding Rule of I.T. Rules, 2026 | 113 |
Form FN052- Annual Compliance Report on Advance Pricing Agreement Purpose:
Form 52 is an Annual Compliance Report on Advance Pricing Agreement (APA) under the Indian Income-tax Act, 2025. It is used by taxpayers who have entered into an APA with the Central Board of Direct Taxes (CBDT). The form is used to confirm that the terms and conditions agreed upon in the Advance Pricing Agreement have been complied with during the relevant financial year. Form 52 is filed as per Rule 113 of the Income-tax Rules, 2026.
Who Should File:
Any taxpayer who has a Unilateral, Bilateral, or Multilateral APA with Indian tax authorities.
Frequency & Due Dates:
A separate report in Form 52 must be filed for each year covered by the APA, 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, as set out in Rule 113 of the Income-tax Rules, 2026.
Structure of Form 52:
> Part A: Particulars of the Person
> Part B: Other Details (including):
> Details of adjustment as per APA for each covered transaction (method of calculation of adjustment laid out in Annexure) along with amount of adjustment made in return of income
> Specific details regarding compliance to the terms and conditions laid out in the signed APAs, and furnishing of reasons in case of deviation from said terms and conditions (in a separate enclosure)
| Annexure | Particulars | |||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
| A-1
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1. Computation of adjustment where operating profit margin (OPM) in relation to the Operating Expense is Profit Level Indicator (PLI) | |||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
@ In case 2 or more transactions are aggregated, the total amount of adjustment as per N in the above table may be shown in any one of the aggregated transactions and for the 2. Computation of adjustment where operating profit margin (OPM) in relation to the Operating Revenue is Profit Level Indicator (PLI)
@ In case 2 or more transactions are aggregated, the total amount of adjustment as per N in the above table may be shown in any one of the aggregated transactions and for the 3. Computation of adjustment in other cases
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| A-2 |
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| A-3 | Whether the documentation as referred to in the APA has been maintained and furnished. | Yes/No | If no, details thereof |
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What are the documents required to file the Form 52?
All documents as agreed upon in the APA to justify the transfer pricing methodology and computation of arm’s length price are required at the time of filing.
What is the process flow of filing Form 52?
The process flow includes following steps:
1. The Applicant shall file Form 52 electronically to the Principal Chief Commissioner of Income-tax (International Taxation)
2. The PCCIT (IT) shall send one copy of annual compliance report to the competent authority in India, one copy to the Commissioner of Income-tax who has the jurisdiction over the income-tax assessment of the Taxpayer and one copy to the Transfer Pricing Officer (TPO) having the jurisdiction over the Taxpayer.
Outcome of Processed Form 52:
- Following the filing of the ACR, the jurisdictional TPO would carry out a compliance audit for each of the years under the APA term. The TPO would provide a report to the PCCIT (IT) (for unilateral APAs) or the competent authority in India (for bilateral and multilateral APAs).
- The APA can be cancelled for not filing the ACR in time and also for furnishing the same with material errors.
Brief note on broad or qualitative changes proposed:
- The erstwhile Form 3CEF had a set of very general queries regarding compliance with the terms set forth in the Agreement by the Applicant. For example, agreed profit level indicator (PLI) vs actual achievement, business model agreed upon vs actual business model adopted. Further, any variance from the critical assumptions agreed upon in the APA was required to be indicated in general terms by the Applicant, which could create avoidable confusion regarding compliance at the time of audit.
- In order to ensure clarity in compliance, tabular computation of adjustment in case of variation for various profit level indicators utilised in APAs has been introduced. Cases where multiple transactions could be aggregated with one PLI have also been accounted for.
- Further, specific Critical Assumptions laid down in APAs with regard to FAR of the applicant, Associated Enterprises (AEs), Invoicing and Credit terms and other compliances mandated in the APA have also been explicitly outlined in the Annexure to the Form. This shall ensure clarity in compliance requirements for the Applicant and ease in carrying out compliance audit by the jurisdictional TPO, reducing opportunities of variance in understanding for both sides.
Challenges and Solutions:
- The erstwhile version of the form presented the challenge of ensuring clear compliance to the terms and conditions set forth in the APA, in the absence of a mechanism inbuilt in the Form for calculation of adjustment (if any) in case of deviation from said terms and conditions.
- This problem has been solved by incorporating a tabular computation in the Form itself to enable the Applicant to explicitly outline the adjustment made, ensuring clarity for the Applicant as well as lowering compliance burden at the time of compliance audit.
- The incorporation of details of common Critical Assumptions in APAs, into the Form itself further lowers compliance burden for the Applicant at the time of audit. Page 6 of 7
Common Changes made across Forms:
1. To make Forms system-friendly and enable e-filing and uploading, certain anomalies found due to grouping of Name, Designation, Address, PAN and Aadhaar number have been separated into different boxes.
2. Assessment / Financial / Previous year or years have been replaced with Tax year or years, wherever appearing in the Form/Annexure.
3. Sections, Clauses and Schedules changes as per the Income-tax Act, 2025.
4. Currency symbol “Rs.” has been replaced with “₹”.
