Income Tax Form 53: Past Years’ Details for MAT Relief under Section 206(1)

The FAQs on Income Tax Form 53 explain its role in providing relief from additional Minimum Alternate Tax (MAT) arising due to transfer pricing adjustments relating to past years, particularly under Advance Pricing Agreements (APA) or secondary adjustments. Introduced under section 170 of the Income-tax Act, 2025 and Rule 118 of the Income-tax Rules, 2026, Form 53 allows taxpayers to recompute book profits and reduce MAT liability where past income is recognised in the current year. Filing is mandatory for eligible taxpayers and must be done electronically before the due date of return filing. The form requires details of past income and MAT computations, though no supporting documents are required. Relief is calculated using a prescribed formula, and MAT credit is adjusted accordingly. This mechanism addresses taxpayer hardship, ensures fair taxation, and aligns MAT liability with actual income timing, thereby improving accuracy and compliance in transfer pricing adjustments.

Income Tax Department
Ministry of Finance, Government of India

FAQs on Income Tax Form 53: Form for filing particulars of past years for calculating relief in tax payable under section 206(1)

Form of application under section 170 of the Income-tax Act, 2025

Q1: What is Form 53 ?

Ans: Taxpayers impacted due to secondary adjustments/APA related adjustments for past year(s), can make an application under Form 53 to recompute the book profits and, consequently, MAT liability. Form 53 is filed under Rule 118 of the Income-tax Rules, 2026, and is verified by the person authorised to verify the taxpayer’s return of income.

Q2: Who should file Form 53?

Ans: Any taxpayer who is subject to the minimum alternate tax (MAT) payable in a year in which transfer pricing (TP) adjustments are made for past years (i.e., additional income is included in the books of account) following the conclusion of an Advance Pricing Agreement (APA) or a secondary adjustment can file Form 53, subject to satisfying conditions.

Q3: Is Form 53 mandatory?

Ans: Form 53 is mandatory. It is required to be filed by Applicant, in a Financial Year (FY) when there is an increase in book profit of the FY due to the income of past year(s) included in the book profit on account of an Advance Pricing Agreement (APA) entered by the taxpayer or secondary adjustment required under the Act.

Q4: What is the time limit for filing Form 53?

Ans: The form must be furnished on or before the due date for furnishing the return of income as specified in Section 263 of the Income tax Act, 2025.

Q5: How many times can Form 53 be filed in a year?

Ans: Form 53 can be filed once in a year.

Q6: What documents are required to file Form 53?

Ans: No specific documents are required for filing Form 53.

Q7: Can I edit Form 53 after submission?

Ans: No. Once Form 53 is submitted and acknowledgment is generated, it cannot be edited. Ensure all details are correct before submission.

Q8: What if I do not have a PAN?

Ans: Form 53 cannot be submitted without a valid PAN.

Q9: Why is Form 53 important?

Ans: Taxpayers were facing hardships due to incremental minimum alternate tax (MAT) arising from incremental income required to be recorded pursuant to Advance Pricing Agreement (APA), or due to a secondary adjustment. Relief was granted vide the Finance Act, 2021, wherein impacted taxpayers could file a prescribed form to recompute the book profits and, consequently, MAT liability. The Central Board of Direct Taxes (CBDT) notified Rule 10RB( Now Rule 118) in the Income-tax Rules, 1962, governing the computation mechanism for aforementioned relief and prescribed Form No.3CEEA (Now Form 53), which is required to be filed by the taxpayer to claim such relief.

Guidance Note on Income Tax Form 53: Form for filing particulars of past years for calculating relief in tax payable under section 206(1)

Form 53- Form for filing particulars of past years for calculating relief in tax payable under section 206(1) of the Income-tax Act, 2025.

1. Purpose:

Taxpayers were facing hardships due to incremental minimum alternate tax (MAT) arising from incremental income required to be recorded pursuant to Advance Pricing Agreement (APA), or due to a secondary adjustment. In this regard, relief was granted vide the Finance Act, 2021, wherein, the taxpayer, impacted due to secondary adjustments/APA related adjustments for past year(s), can make an application under a prescribed form to recompute the book profits and, consequently, MAT liability. The Central Board of Direct Taxes (CBDT) notified Rule 10RB in the Income-tax Rules, 1962, governing the computation mechanism for aforementioned relief.

The notification prescribes Form No. 3 CEEA (now Form 53), which is required to be filed by the taxpayer to claim such relief. Form 53 is filed under Rule 118 of the Income-tax Rules, 2026. This Form must be verified by the person who is authorised to verify the taxpayer’s return of income.

Who Should File:

Any taxpayer who is subject to the minimum alternate tax (MAT) payable in a year in which transfer pricing (TP) adjustments are made for past years (i.e., additional income is included in the books of account) following the conclusion of an Advance Pricing Agreement (APA) or a secondary adjustment.

Further, to seek the MAT relief under sub-section 206(1) of the Income-tax Act, 2025 (the Act) it is provided that –

• To claim MAT relief, the taxpayer should not have utilised the MAT credit (under section 206 of the Act) previously allowed.
• No interest will be payable to the taxpayer on the refund arising because of the provisions of the regulation.

Frequency & Due Dates:

Required to be filed by Applicant, in a Financial Year (FY) when there is an increase in book profit of the FY due to the income of past year(s) included in the book profit on account of an Advance Pricing Agreement (APA) entered by the taxpayer or secondary adjustment required under the Act.

Structure of Form 53:

>Part A: Particulars of the Person

>Part B: Other Details:

• • • Residential Status
    • Relevant Tax Year
    • Details of past income, and calculations of Amounts A, B, C and D as per Rule 118

What are the documents required to file the Form 53?

No specific documents required

What is the process flow of filing Form 53?

The process flow includes following steps:

1. The Applicant shall file Form 53 electronically

2. The Form No. 53 requires the taxpayer to provide the details of past income and the MAT payable on such income, in the prescribed manner and format.

3. This Form must be verified by the person who is authorised to verify the taxpayer’s return of income.

4. The MAT relief available under Rule 118 of the Rules (by reduction of the MAT payable by the taxpayer for the FY), will be determined based on the following formula: [(A-B) – (D- C)], where the amounts A, B, C and D are defined in the same Rule.

5. Past income is defined as the amount of income of past year(s) included in the book profit of the FY on account of an APA entered into by the taxpayer or secondary adjustment required under the Act.

6. If there is no MAT relief available under Rule 118 of the Rules [i.e., the value of (A-B) – (D- C) is negative], the value of the formula will be considered as zero.

7. The MAT credit previously allowed to the taxpayer shall be reduced by the MAT relief available under Rule 118 of the Rules.

Outcome of Processed Form 53:

• On receipt of the Form 53, the person who is authorised to verify the taxpayer’s return of income, shall verify the amount claimed as relief in tax payable under section 206(1) of the Income-tax Act, 2025 and provide the same to the taxpayer.

Brief note on broad or qualitative changes proposed:

• No major changes have been incorporated into the Form. Qualitative changes have been made to bring the Form in line with the modified Rule 118 which has been changed for simplification and ease of computation.

Challenges and Solutions:

• No particular challenges faced. Qualitative changes have been made to bring the Form in line with the modified Rule 118 which has been changed for simplification and ease of computation.

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 “₹”.