Rule 10DA – Requirements for filing a Master File as per CBDT Notification (N.No. 3497(E))

The Central Board of Direct Taxes (CBDT), has released the final rules through a notification (N No. 3497(E) on preparation and filing of Master file by the Indian Entity of an International group. The brief of the rules as notified and the documentation/information requirements as needed for the filing are summarized herewith for your reference.

For a deeper discussion of how this would be relevant for your entity, please contact the undersigned.

Applicability of RULE 10DA

Preparation and filing of master file with the income tax department is mandatory for those Indian entities which are a part of the international group (whether a parent company is Indian resident or a foreign resident).

 Conditions Threshold limit in INR Crores
A Consolidated group revenue of the ‘International Group’ for the accounting year EXCEEDS 500
B Aggregate Value of International Transactions EXCEEDS 50
C International transaction pertaining to an intangible property EXCEEDS 10


Condition A is to be fulfilled first and then any of the one condition is to be fulfilled out of B & C for the applicability of master file requirement.

Ø  Requirements under the relevant form

  • If an international group has “one Indian entity” then the master file is to be filed in form 3CEAA which further consist of two parts.
    Part A and Part B
  • Part A is to be filed by every Indian entity which is a part of the International group regardless of the above three conditions;
  • Part B is to be  filed by those Indian entities which satisfies the conditions as tabulated above
  • If an international group has “more than one Indian entity” then the international group may designate an Indian entity which shall file the master file in
    Form 3CEAA (Part A or Part B or both as applicable) and the intimation of the same is to be filed by the designated Indian entity in form 3CEAB with the
    DGIT (Risk Assessments).
    A pictorial representation of the above rule and the requirements for filing the master file has been attached to herewith for reader’s reference

(Republished with Amendments)

Author Bio

Name: Himanshu
Qualification: CA in Practice
Company: AK Nair & Co./ NBC Consultants LLP
Location: New Delhi, New Delhi, IN
Member Since: 21 Feb 2018 | Total Posts: 4

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January 2021