Master File and CbCR Requirements in India (2026), Forms 56 to 60

Written by CA Nandini, Krystal7 Consultants. Last updated 27 September 2026.

Every Indian company in an international group, however small, files Part A of the master file. The form is Form 3CEAA for FY 2025-26 and Form 56 from tax year 2026-27. It is due with the return, 30 Nov in transfer pricing cases. Part B applies above Rs 500 crore of group revenue. The entity's international transactions must also exceed Rs 50 crore, or its intangible transactions Rs 10 crore. Above Rs 6,400 crore, the entity also files a CbCR intimation (Form 58).

This page is for foreign parents and the finance leads of their Indian subsidiaries. It maps the old forms to the new ones, sets out every threshold, due date and penalty, and works through two groups with rupee figures.

What are the master file and CbCR requirements in India?

India asks every constituent entity of a multinational group to file a master file, and asks large groups for a country by country report (CbCR). From 1 Apr 2026, section 171(4) of the Income Tax Act, 2025 governs the master file. Rule 123 of the Income Tax Rules, 2026 sets the detail. Section 511 and rule 124 govern CbCR.

The master file describes the whole group. It covers the legal structure, the main businesses, the intangibles, the group financing and the consolidated accounts. The CbC report gives numbers by country: revenue, profit before tax, tax paid, employees and assets. Both come from the OECD's BEPS Action 13 model, which many parents already follow at home.

The Indian subsidiary rarely writes these documents itself. The group tax team holds the data. The Indian entity still carries its own filing duties, and the penalties fall on the Indian entity if it misses them.

The table below shows who files what. The form names follow the CBDT guidance note on Forms 56 to 60 and the official old to new form list (Income Tax Department, 2026).

Obligation	Form from tax year 2026-27	Form for FY 2025-26	Who files	Trigger
Master file, basic details	Form 56 Part A	Form 3CEAA Part A	Every constituent entity of an international group	None. It applies whatever the group's size
Master file, full group information	Form 56 Part B	Form 3CEAA Part B	The same entity	Group revenue above Rs 500 crore, and Indian international transactions above Rs 50 crore or intangible transactions above Rs 10 crore
Designation for the master file	Form 57	Form 3CEAB	The Indian entity the group designates	Optional, where two or more Indian entities must file
CbCR intimation	Form 58	Form 3CEAC	Every constituent entity resident in India whose parent is not resident in India	Group revenue above Rs 6,400 crore in the preceding accounting year
CbC report	Form 59	Form 3CEAD	An Indian parent, an Indian alternate reporting entity, or an Indian entity where a local filing trigger applies	Same Rs 6,400 crore test
Designation for the CbC report	Form 60	Form 3CEAE	Filed on behalf of the group	Two or more Indian entities must file the CbC report locally

Two points catch most foreign groups. Part A has no threshold at all. The Indian entity owes the CbCR intimation even when the parent files the CbC report in its own country.

Which forms replaced Forms 3CEAA to 3CEAE?

Forms 56 to 60 replaced Forms 3CEAA to 3CEAE on 1 Apr 2026. That is the day the Income Tax Act, 2025 and the Income Tax Rules, 2026 took effect. Section 92D(4) became section 171(4), section 286 became section 511, rule 10DA became rule 123 and rule 10DB became rule 124.

The Income Tax Department lists the new titles on its page of FAQs and guidance notes on forms under the 2026 Rules. The guidance note on Forms 56 to 60 cites the rules. The table combines both.

Old form (1962 Rules)	New form (2026 Rules)	Old law	New law	Old rule	New rule	Official title of the new form, shortened
3CEAA	56	Section 92D(4)	Section 171(4)	10DA	123	Information and document to be furnished by a constituent entity under section 171(4)
3CEAB	57	Section 92D(4)	Section 171(4)	10DA	123(4)	Intimation by a designated constituent entity, resident in India, of an international group
3CEAC	58	Section 286(1)	Section 511(1)	10DB	124	Intimation by a constituent entity, resident in India, whose parent entity is not resident in India
3CEAD	59	Section 286(2) and 286(4)	Section 511(2) and 511(4)	10DB	124	Report by a parent entity, an alternate reporting entity or any other constituent entity resident in India
3CEAE	60	Proviso to section 286(4)	Section 511(5)	10DB	124	Intimation on behalf of the international group for section 511(5)

The definitions moved too. Section 171(5) borrows "constituent entity" and "international group" from section 511(10). Section 511(10) holds all the CbCR definitions in clauses (a) to (l).

The substance did not change. The thresholds, the Part A and Part B split, the two month intimation window and the 12 month CbCR deadline all carried over. For the wider picture, read our note on Income Tax Act, 2025 changes for foreign owned companies.

Which forms apply to FY 2025-26 and which to tax year 2026-27?

The 1961 Act still governs FY 2025-26, so the master file for that year goes in Form 3CEAA by 30 Nov 2026. Forms 56 and 57 start with tax year 2026-27. The first Form 56 is due by 30 Nov 2027, with the return for that tax year.

The CBDT's FAQs on interplay and transition settle the base rule. The return for income of FY 2025-26 is filed for AY 2026-27 under the 1961 Act (Q3.5). It uses the ITR forms of the 1961 Act (Q3.6). Tax audit reports for FY 2025-26 use Forms 3CA, 3CB and 3CD (Q4.32).

The FAQs do not name Form 3CEAA. They do say the income tax portal supports the old forms for AY 2026-27 and earlier (Q4.39). The new forms start with tax year 2026-27. The master file rides on the return for the same year, so the FY 2025-26 master file goes in Form 3CEAA.

CbCR is less tidy. The duty follows the parent's reporting year, not the Indian tax year. A parent year that ended on 31 Dec 2025 produces an intimation due on 31 Oct 2026, after the new Act began. Neither the transition FAQs nor the guidance note says which form covers such a year. We read the savings clause in section 536 as keeping Forms 3CEAC to 3CEAE for reporting years ending on or before 31 Mar 2026. Before you file, check which form the income tax portal offers for that reporting year, and keep a screenshot with the tax file.

Filing	FY 2025-26 (AY 2026-27)	Tax year 2026-27
Local file kept (not filed)	Rule 10D, ready by 31 Oct 2026	Rule 84, under section 171(1), ready by 31 Oct 2027
Transfer pricing accountant's report	Form 3CEB under section 92E, due 31 Oct 2026	Form 48 under section 172, due 31 Oct 2027
Master file designation	Form 3CEAB, at least 30 days before the master file due date: 31 Oct 2026	Form 57, by 31 Oct 2027
Master file	Form 3CEAA, due 30 Nov 2026	Form 56, due 30 Nov 2027
Return of income	ITR-6 for AY 2026-27, due 30 Nov 2026	New return form for tax year 2026-27, due 30 Nov 2027
CbCR forms	Follow the parent's reporting year (see the dates table below)	Forms 58, 59 and 60 for reporting years ending after 31 Mar 2026

The 30 Nov date applies where the company must furnish a transfer pricing report. The transition FAQs confirm it for AY 2026-27 (Q3.25). For tax year 2026-27, section 263(1)(c) sets the same date in serial number 1 of its table. A company with no international or specified domestic transaction has a 31 Oct due date instead.

Check the portal for any CBDT extension order before you rely on these dates.

Who must file Part A and Part B of Form 56?

Every constituent entity of an international group files Part A, whatever the group's size. Part B is added when consolidated group revenue exceeds Rs 500 crore for the accounting year. The entity's international transactions must also exceed Rs 50 crore, or its intangible property transactions Rs 10 crore.

The CBDT guidance note on Form 56 says so directly. It states that the entity furnishes Part A even when the rule 123(1) conditions are not met. That line reproduces rule 123(3).

Who counts as a constituent entity?

Section 511(10)(d) defines the term widely. A constituent entity is any separate entity of the group included in the consolidated financial statement. It also covers an entity that would be included if the equity of any group entity were listed on a stock exchange.

That second limb matters for private groups. A founder owned US company with an Indian subsidiary may never prepare consolidated accounts. The Indian subsidiary is still a constituent entity, because it would be consolidated on a listing.

The definition also covers an entity left out of consolidation only on size or materiality grounds. It covers a permanent establishment that prepares a separate financial statement too. If your Indian presence is a branch or project office rather than a Private Limited company, check that last limb with us.

Under section 511(10)(g), an international group means two or more enterprises resident in different countries. One enterprise with a permanent establishment abroad also counts. A foreign parent and one Indian subsidiary already form an international group.

What Part A and Part B ask for

The guidance note describes the two parts of Form 56.

Part	Contents under the guidance note	Who fills it	Practical source of the data
Part A	Name, address, PAN, email ID and contact number of the constituent entity	Every constituent entity	The Indian entity's own records
Part B	Accounting year of the information, details of the international group, details of all group entities operating in India, details of all group entities worldwide, and Annexures A-1 to A-11 as separate enclosures	Only entities that meet the rule 123(1) tests	Group tax team, group legal entity register, consolidated accounts

Part A is short, but missing it can still cost Rs 5 lakh, as the penalties section explains.

The entity files Form 56 itself and verifies it electronically on the income tax portal. The guidance note describes no accountant's report for it, unlike Form 48.

How is the group revenue test worked out?

Use the group's consolidated revenue, not the Indian company's revenue. For the master file, test the accounting year the file covers against Rs 500 crore. For CbCR, test the preceding accounting year against Rs 6,400 crore. Convert foreign currency revenue at the telegraphic transfer (TT) buying rate.

Which year is tested

The two tests look at different years. Many summaries blur this.

Point	Master file (Form 3CEAA or 56, Part B)	CbCR (Forms 3CEAC to 3CEAE or 58 to 60)
Revenue measure	Consolidated group revenue as per the consolidated financial statements	Total consolidated group revenue as per the consolidated financial statement
Year tested	The accounting year for which the master file is filed	The accounting year preceding the reporting accounting year (section 511(8))
Threshold	Exceeds Rs 500 crore	Exceeds Rs 6,400 crore
Second condition	Entity's international transactions above Rs 50 crore, or intangible property transactions above Rs 10 crore	None
Exchange rate	TT buying rate on the last day of the accounting year (rule 10DA, now rule 123(6))	TT buying rate on the last day of the accounting year preceding the reporting year (rule 10DB, now rule 124)
Legal source	Rule 10DA, now rule 123; guidance note on Form 56	Section 286(7), now section 511(8); rule 10DB, now rule 124

Rules 123 and 124 of the 2026 Rules keep the exchange rate wording of rules 10DA and 10DB. Rule 124 takes the meaning of "telegraphic transfer buying rate" from rule 207.

The CbCR threshold is "exceeds", not "equals or exceeds". Section 511(8) switches the whole section off when revenue "does not exceed" the prescribed amount. A group at exactly Rs 6,400 crore has no CbCR duty in India.

What "accounting year" means for a foreign parent

Section 511(10)(a) defines the accounting year. Where the parent is resident in India, it is the tax year. In other cases, it is the annual period for which the parent prepares its financial statements under its own law or accounting standards.

So a US parent with a December year end tests calendar year revenue. A Japanese parent with a March year end tests April to March revenue.

Rule 123(1) tests the Indian entity's international transactions "during the accounting year, as per the books of account". For a December year end parent, that is a calendar year figure, while the Indian books run April to March.

Rule 123 and the guidance note do not say which group year pairs with which Indian tax year. Form 56 Part B asks the entity to state the accounting year its information covers. In practice we pair the Indian FY 2025-26 with the group year that ends inside it, which is calendar year 2025. We state that year in the form and keep the working. Where the pairing changes the Part B answer, get advice before you file.

What the thresholds mean in dollars

The thresholds are fixed in rupees, so their dollar value moves with the exchange rate. At an assumed Rs 88 per US dollar, Rs 500 crore is about USD 57 million. Rs 6,400 crore is about USD 727 million. These are illustrations only. Use the actual TT buying rate for the relevant date.

A mid sized group can cross Rs 500 crore without thinking of itself as large. The CbCR threshold can also sit on a different side of the line from your parent's home threshold, because the currencies move apart. We cover that risk under local filing below.

What information goes into the master file?

The master file describes the whole group: its structure, business, intangibles, financing, consolidated accounts and tax rulings. Rule 10DA(1) lists 14 items in clauses (a) to (n). Form 56 Part B carries this content through Annexures A-1 to A-11.

The table groups the rule 10DA(1) clauses. We read the list from CBDT Notification 92/2017, which inserted rule 10DA.

Area	What the group must provide	Rule 10DA(1) clause
Structure	List of all group entities with addresses	(a)
Structure	Chart of the legal status of the constituent entity and the ownership structure of the whole group	(b)
Business	Nature of the business, drivers of profit, supply chain for the five largest products or services and for any product or service above 5% of group revenue, main service arrangements, main geographic markets, a functional analysis of entities contributing at least 10% of revenue, assets or profit, and major restructurings, acquisitions and divestments	(c)
Intangibles	Group strategy for developing, owning and exploiting intangible property, including the location of the main research and development facilities	(d)
Intangibles	List of entities engaged in developing and managing intangibles, with addresses	(e)
Intangibles	List of important intangibles and which entity legally owns each	(f)
Intangibles	List and short description of important agreements among group entities on intangibles, including cost contribution arrangements, research service agreements and licences	(g)
Intangibles	Transfer pricing policies for research and development and for intangibles	(h)
Intangibles	Important transfers of interests in intangibles among group entities, with the entities, countries and compensation	(i)
Financing	Description of how the group is financed, including the names and addresses of the top ten unrelated lenders	(j)
Financing	Group entities that provide a central financing function, with their place of operation and effective management	(k)
Financing	Transfer pricing policies for financing arrangements among group entities	(l)
Financial statements	The group's annual consolidated financial statements	(m)
Tax rulings	List and short description of existing unilateral advance pricing agreements and other tax rulings that allocate income among countries	(n)

If the group already prepares an OECD style master file for another country, most of this exists. The work is mapping it into the Indian form's fields and annexures, and checking that the numbers match the Indian local file.

Rule 123(5) of the 2026 Rules says to keep the information and documents for nine years from the end of the relevant tax year. Rule 10DA of the 1962 Rules said eight years from the end of the relevant assessment year. The two periods end on the same date. For FY 2025-26 records, both run to 31 Mar 2035.

When does an Indian entity file Form 57?

Form 57 (Form 3CEAB for FY 2025-26) is needed only when a group has two or more Indian constituent entities. It applies when the group chooses one of them to file Form 56 for all. The designated entity files it at least 30 days before the Form 56 due date. That is 31 Oct 2026 for FY 2025-26.

Designation is a choice, not a duty. The guidance note covers groups where more than one constituent entity must file Form 56. Any one of them may furnish it if the group has designated that entity. Without Form 57, each Indian entity files its own Form 56.

Form 57 has two parts. Part A gives the designated entity's name, address, PAN, email and phone. Part B gives the group name, the parent entity's details and the accounting year.

Keep two points in mind:

1. Form 57 is a master file form. It does nothing for CbCR. The CbCR designation form is Form 60.
2. The 30 day rule counts back from the Form 56 due date. Suppose the designated entity has no transfer pricing report, so its return is due on 31 Oct. The designation date then moves back to 1 Oct.

Who files Form 58 when the parent is outside India?

Every constituent entity resident in India files Form 58 (Form 3CEAC for older years) when two things hold. The parent is not resident in India, and group revenue exceeded Rs 6,400 crore in the preceding accounting year. It names who files the CbC report and where. It is due two months before the CbC report deadline.

Section 511(1) creates the duty. The Indian entity tells the income tax authority one of two things. Either it is itself the alternate reporting entity, or it names the parent entity or alternate reporting entity. In the second case it also gives that entity's country of residence.

Form 58 has two parts under the guidance note. Part A holds the Indian entity's particulars. Part B holds the group name, the parent entity's details, any alternate reporting entity and the reportable accounting year.

The CbC report deadline is 12 months after the end of the reporting accounting year (section 511(2)). Form 58 is due two months before that, which is ten months after the parent's year end.

Parent's reporting year ends	CbC report (Form 59) due	Form 58 intimation due	Form 60, if needed, at least 30 days before Form 59
31 Dec 2025	31 Dec 2026	31 Oct 2026	1 Dec 2026
31 Mar 2026	31 Mar 2027	31 Jan 2027	1 Mar 2027
30 Jun 2026	30 Jun 2027	30 Apr 2027	31 May 2027
30 Sep 2026	30 Sep 2027	30 Jul 2027	31 Aug 2027
31 Dec 2026	31 Dec 2027	31 Oct 2027	1 Dec 2027

The first two rows may still use Forms 3CEAC to 3CEAE, as the transition section above explains.

Two limits stop over filing. Form 58 applies only where the parent is not resident in India. It also applies only above the Rs 6,400 crore test, because section 511(8) switches off all of section 511 below it.

A group at Rs 900 crore has no Form 58 duty. It still has Form 56 Part A, and possibly Part B.

When does the Indian entity file the CbC report itself?

An Indian constituent entity files Form 59 locally only on one of three triggers. The parent's country does not require a CbC report, has no exchange agreement with India, or is in systemic failure notified to the entity. Otherwise the parent, or an alternate reporting entity, files at home and India receives the report by exchange.

Section 511(4) sets these three triggers. Section 511(6) lifts them where an alternate reporting entity has filed the report in its own country. That relief needs all of these conditions:

1. The alternate reporting entity was required to file the report under the law of its country.
2. That country has an agreement with India to exchange CbC reports.
3. That country has not been in systemic failure for India.
4. The alternate reporting entity has told its own country's tax authority in writing that it is the alternate reporting entity for the group.
5. The Indian entity has made its intimation under section 511(1).

Situation for the foreign parent	Indian filing	Legal basis
Parent files a CbC report at home, and its country exchanges reports with India	Form 58 only	Sections 511(1) and 511(4)
Parent's country has no CbCR obligation for the parent	Form 58 and Form 59 by the Indian entity	Section 511(4), first trigger
Parent's country has CbCR but no exchange agreement with India	Form 58 and Form 59 by the Indian entity	Section 511(4), second trigger
Parent's country is in systemic failure, and India has told the Indian entity	Form 58 and Form 59, within six months from the end of the month of that intimation	Section 511(4), third trigger; guidance note on Form 59
An alternate reporting entity files in a country that meets the section 511(6) conditions	Form 58 naming that entity; no Form 59	Section 511(6)
Two or more Indian entities must file Form 59	Form 60 to name one filer, then Form 59 by that entity	Section 511(5)

What an agreement means here

Section 511(10)(b) treats two kinds of agreement as enough. The first is an agreement with a foreign country or specified territory under section 159(1) or (2). The second is an agreement the Central Government notifies for exchanging CbC reports.

India and the US signed a bilateral agreement to exchange CbC reports on 27 Mar 2019. It covers fiscal years starting on or after 1 Jan 2016. The PIB release said it would remove the need for Indian subsidiaries of US groups to file CbC reports locally. For UK, Singapore, UAE and other parents, check the OECD's list of activated exchange relationships for the parent's country each year.

Our guides on US parent transfer pricing and UK parent transfer pricing cover the treaty side.

The currency mismatch risk

India tests Rs 6,400 crore at the TT buying rate. Your parent's country tests its own threshold in its own currency. When the rupee weakens, a group can cross India's line while staying under the home country's line.

In that case the parent has no CbCR obligation at home. The first trigger in section 511(4) then reads as if it applies, and the Indian entity may have to file Form 59 itself. Section 511, rule 124 and the guidance note on Forms 56 to 60 make no exception for currency movements.

If your group is close to either threshold, raise this with us before the Form 58 date.

Form 60 timing

Section 511(5) and rule 124(6) set no date for Form 60. The guidance note still asks for it at least 30 days before the Form 59 due date. We file it with that margin, because a late designation leaves each Indian entity exposed to the Form 59 penalty.

Where the parent is Indian

An Indian parent, or an Indian entity the group names as alternate reporting entity, files Form 59 itself under section 511(2). The guidance note describes five parts, Part A to Part E. They cover the reporting entity, other basic details, and the allocation of income, taxes and business activities by jurisdiction. The last two list the constituent entities by jurisdiction and give additional information.

What are the due dates for master file and CbCR filings?

For FY 2025-26, Form 3CEB is due 31 Oct 2026 and Form 3CEAA is due 30 Nov 2026. For tax year 2026-27, Form 48 is due 31 Oct 2027 and Form 56 on 30 Nov 2027. CbCR dates follow the parent's year end: intimation ten months after it, the report 12 months after it.

Here is the combined calendar for a foreign owned Indian subsidiary whose parent has a December year end and whose group crosses both thresholds.

Date	Filing	Period covered	Form
31 Oct 2026	Transfer pricing accountant's report	FY 2025-26	Form 3CEB
31 Oct 2026	Local file must exist (the specified date)	FY 2025-26	Kept, not filed
31 Oct 2026	Master file designation, if two or more Indian entities	FY 2025-26	Form 3CEAB
31 Oct 2026	CbCR intimation	Parent year ended 31 Dec 2025	Form 3CEAC or Form 58 [see transition note]
30 Nov 2026	Return of income	AY 2026-27	ITR-6
30 Nov 2026	Master file, Part A and Part B	FY 2025-26	Form 3CEAA
1 Dec 2026	CbCR designation, only if local filing applies and there are two or more Indian entities	Parent year ended 31 Dec 2025	Form 3CEAE or Form 60
31 Dec 2026	CbC report, only if local filing applies	Parent year ended 31 Dec 2025	Form 3CEAD or Form 59
31 Oct 2027	Transfer pricing accountant's report	Tax year 2026-27	Form 48
31 Oct 2027	Master file designation, if needed	Tax year 2026-27	Form 57
31 Oct 2027	CbCR intimation	Parent year ending 31 Dec 2026	Form 58
30 Nov 2027	Return of income and master file	Tax year 2026-27	Return form and Form 56

The dates come from section 263(1)(c), the transition FAQs, section 511(2) and the guidance note on Forms 56 to 60. For every other filing a foreign owned company faces, see our compliance calendar for 2026-27.

What are the penalties for missing the master file or CbCR?

Not filing Form 56 costs Rs 5 lakh under section 442(2) of the 2025 Act (section 271AA(2) of the 1961 Act). Under section 459(1), a late CbC report costs Rs 5,000 a day for the first month. After that it costs Rs 15,000 a day. An inaccurate CbC report costs Rs 5 lakh under section 459(4).

The 2025 Act renumbered the penalty sections and kept the amounts. Use the 1961 sections for FY 2025-26 filings and the 2025 sections for tax year 2026-27 onwards.

Default	1961 Act	2025 Act	Penalty	Imposed by
Master file (Part A or Part B) not furnished	Section 271AA(2)	Section 442(2)	Rs 5 lakh	The income tax authority prescribed for the master file
Transfer pricing documents not kept, a transaction not reported, or wrong information kept or furnished	Section 271AA(1)	Section 442(1)	2% of the value of each international or specified domestic transaction	Assessing Officer or Commissioner (Appeals)
Documents not furnished on a transfer pricing notice	Section 271G	Section 457	2% of the value of the transaction, for each failure	Assessing Officer, Transfer Pricing Officer or Commissioner (Appeals)
CbC report not furnished	Section 271GB(1)	Section 459(1)	Rs 5,000 a day up to one month; Rs 15,000 a day beyond one month	Prescribed authority under section 511
Information not produced on a CbCR notice	Section 271GB(2)	Section 459(2)	Rs 5,000 a day from the day after the notice period ends	Prescribed authority under section 511
Failure continues after a penalty order is served	Section 271GB(3)	Section 459(3)	Rs 50,000 a day from the date of service of the order	Prescribed authority under section 511
Inaccurate CbC report, or inaccurate reply to a notice	Section 271GB(4)	Section 459(4)	Rs 5 lakh	Prescribed authority under section 511
Relief where there was reasonable cause	Section 273B	Section 470	No penalty if the person proves reasonable cause	Same authorities

Section 459(4) sets out when a CbC report counts as inaccurate. The entity knew of the error when it filed and did not tell the authority. Or it found the error later and did not report it and file a correct report within 15 days. Or it gave inaccurate information in reply to a notice under section 511(7).

Section 459 covers the CbC report and replies to a section 511(7) notice. It does not name the section 511(1) intimation in Form 58. Section 442 does not name Form 57, and neither section names Form 60. Do not treat that as a free pass. The intimation is still a statutory duty under section 511(1), and a missing one shows in the entity's filing record.

Section 470 lists sections 442, 457 and 459 among the penalties that do not apply when the person proves reasonable cause. Reasonable cause is a defence you argue after the event, so file on time.

Which forms apply to a foreign owned Indian subsidiary?

Every foreign owned Indian subsidiary files Form 56 Part A. The other forms depend on group revenue and the subsidiary's international transactions. They also depend on whether the parent's country exchanges CbC reports with India. The matrix below reads across from your facts.

Group revenue and Indian transactions	Form 56 Part A	Form 56 Part B	Form 57	Form 58	Form 59	Form 60	Form 48
Group revenue up to Rs 500 crore; any transaction value	Yes	No	Optional, if two or more Indian entities	No	No	No	Yes, if any international transaction
Group revenue above Rs 500 crore but not above Rs 6,400 crore; Indian international transactions up to Rs 50 crore and intangibles up to Rs 10 crore	Yes	No	Optional	No	No	No	Yes
Same group revenue; Indian international transactions above Rs 50 crore	Yes	Yes	Optional	No	No	No	Yes
Same group revenue; transactions up to Rs 50 crore but intangible transactions above Rs 10 crore	Yes	Yes	Optional	No	No	No	Yes
Group revenue above Rs 6,400 crore in the preceding year; parent files CbCR at home with exchange to India; Indian transactions below both limbs	Yes	No	Optional	Yes	No	No	Yes
Same, but Indian transactions above either limb	Yes	Yes	Optional	Yes	No	No	Yes
Group revenue above Rs 6,400 crore; a section 511(4) trigger applies; one Indian entity	Yes	If a limb is met	Not relevant	Yes	Yes, by the Indian entity	No	Yes
Same, with two or more Indian entities	Yes, each unless Form 57 is filed	If a limb is met	Optional	Yes, each entity	Yes, by the designated entity	Yes	Yes

Three notes on the matrix:

1. Part B needs both the revenue test and a transaction limb. A group of Rs 20,000 crore with an Indian subsidiary doing Rs 30 crore of plain services files Part A only.
2. The revenue tests use different years. Part B tests the year the master file covers. CbCR tests the year before the reporting year.
3. The Rs 1 crore limit in rule 10D (now rule 84) affects only the local file. It does not remove Form 56 Part A or Form 48.

How do the master file and CbCR fit with the local file and Form 48?

India uses four linked documents. The local file proves the Indian entity's prices. Form 48 (Form 3CEB for FY 2025-26) is the accountant's report on those transactions. The master file describes the group. The CbC report gives country data. Only Form 48, the master file and the CbCR forms are filed.

Point	Local file	Form 48 (was 3CEB)	Master file (Form 56)	CbC report (Form 59)
What it covers	The Indian entity's transactions with associated enterprises and the arm's length analysis	An accountant's report on international and specified domestic transactions	The whole group's structure, business, intangibles, financing and accounts	Country by country revenue, profit, tax, capital, employees and assets
Law from tax year 2026-27	Section 171(1); rule 84	Section 172; rule 85 (was rule 10E)	Section 171(4); rule 123	Section 511(2) and (4); rule 124
Law for FY 2025-26	Section 92D(1); rule 10D	Section 92E; rule 10E	Section 92D(4); rule 10DA	Section 286; rule 10DB
Filed?	No. Kept and produced on notice	Yes	Yes	Yes, by the reporting entity
Threshold	Full documentation only above Rs 1 crore of international transactions (rule 10D, now rule 84)	Any international transaction	Part A none; Part B Rs 500 crore plus a transaction limb	Group revenue above Rs 6,400 crore
Due	Ready by the specified date under section 173, one month before the return due date	One month before the return due date: 31 Oct	Return due date: 30 Nov in transfer pricing cases	12 months after the reporting year end
Who prepares it	The Indian entity, usually with a transfer pricing adviser	A Chartered Accountant	The group tax team, filed by the Indian entity	The parent, or the Indian entity on local filing

Time to respond on a notice

The notice period for transfer pricing documents got shorter. Section 92D(3) of the 1961 Act gave 30 days, extendable by 30 more. Section 171(2) of the 2025 Act gives ten days from receipt of the notice. Under section 171(3), the officer may extend that by up to 30 days on application.

A local file that exists only as a plan will not survive a ten day window. Keep it complete by 31 Oct each year. Our guide to transfer pricing documentation requirements covers the local file. Our Form 3CEB guide covers the accountant's report.

Keep the four documents consistent

Tax officers read these documents side by side. Check these links each year:

1. The functional profile in the local file matches the master file's description of the Indian entity's role.
2. The international transaction total used for the Part B test matches the transactions reported in Form 48, adjusted for any difference in the year covered.
3. The Indian revenue, profit and tax in the CbC report for India reconcile to the Indian audited accounts and the return.
4. The master file's list of intangibles and their owners supports the royalty or licence terms tested in the local file.

How should the Indian entity work with the parent's tax team?

Send the parent's tax team a written data request early in the year, with dates tied to the Indian deadlines. The Indian entity owns the filing and the penalty. The parent owns most of the data. A signed off request list closes that gap.

We send a version of this list to parents in March, so the answers arrive before the Indian statutory audit closes.

Item to request	Why India needs it	Latest date we ask for it (December year end parent, FY 2025-26 cycle)
Consolidated revenue for the parent's last two years, with the currency	Part B test and CbCR test	30 Jun 2026
Name, address and tax residence of the ultimate parent and any alternate reporting entity	Form 3CEAC or Form 58, and Form 3CEAA Part B	30 Jun 2026
Confirmation that the parent files a CbC report at home, and for which year	Local filing check under section 511(4)	30 Jun 2026
List of all group entities with addresses, and the ownership chart	Rule 10DA(1)(a) and (b)	31 Aug 2026
Latest OECD style master file prepared for any country	Base text for Part B annexures	31 Aug 2026
Consolidated financial statements	Rule 10DA(1)(m)	31 Aug 2026
Intangibles list, owners and licence agreements	Rule 10DA(1)(d) to (i), and the local file	31 Aug 2026
Group financing summary and top ten unrelated lenders	Rule 10DA(1)(j) to (l)	31 Aug 2026
Unilateral APAs and tax rulings	Rule 10DA(1)(n)	31 Aug 2026
Written designation, if the group has two or more Indian entities	Form 3CEAB or Form 57, and Form 3CEAE or Form 60	30 Sep 2026

Ask one named person in the group tax team to sign off the list.

Our transfer pricing advisory team can run the threshold test and the filings. We work directly with parent tax teams in the US, UK, Singapore and the UAE.

What changed in 2026

On 1 Apr 2026 the Income Tax Act, 2025 replaced the Income Tax Act, 1961. The Income Tax Rules, 2026 replaced the 1962 Rules on the same day, through CBDT Notification 22/2026 (GSR 198(E), 20 Mar 2026). The master file and CbCR rules moved to new section, rule and form numbers. The thresholds did not change.

Item	Before (1961 Act, 1962 Rules)	From 1 Apr 2026 (2025 Act, 2026 Rules)	Date	Instrument
Master file duty	Section 92D(4)	Section 171(4)	1 Apr 2026	Income Tax Act, 2025 (30 of 2025)
CbCR duty	Section 286	Section 511	1 Apr 2026	Income Tax Act, 2025
Master file rule	Rule 10DA	Rule 123	1 Apr 2026	Notification 22/2026, GSR 198(E), 20 Mar 2026
CbCR rule	Rule 10DB	Rule 124	1 Apr 2026	Notification 22/2026
Local file rule	Rule 10D	Rule 84	1 Apr 2026	Notification 22/2026
Master file record retention	Eight years from the end of the relevant assessment year (rule 10DA)	Nine years from the end of the relevant tax year (rule 123(5))	1 Apr 2026	Notification 22/2026
Forms	3CEAA, 3CEAB, 3CEAC, 3CEAD, 3CEAE	56, 57, 58, 59, 60	Tax year 2026-27 onwards	Income Tax Rules, 2026
Transfer pricing report	Section 92E, Form 3CEB, rule 10E	Section 172, Form 48, rule 85	Tax year 2026-27 onwards	Income Tax Act, 2025 and Rules, 2026
Due date anchor	Section 139(1)	Section 263(1)(c)	Tax year 2026-27 onwards	Income Tax Act, 2025
Penalty sections	271AA, 271G, 271GB, 273B	442, 457, 459, 470	1 Apr 2026	Income Tax Act, 2025
Notice period for transfer pricing documents	30 days, extendable by 30 days (section 92D(3))	10 days, extendable by up to 30 days (section 171(2) and (3))	1 Apr 2026	Income Tax Act, 2025
Year concept	Previous year and assessment year	Tax year	1 Apr 2026	Income Tax Act, 2025
Thresholds	Rs 500 crore, Rs 50 crore, Rs 10 crore, Rs 6,400 crore	Unchanged	Not applicable	Rules 123(1) and 124(7); guidance note on Forms 56 to 60

The Income Tax (Fourth Amendment) Rules, 2026 (GSR 822(E), 17 Sep 2026) are the latest change we checked. They amend other rules and Forms 169 and 171, and leave rules 123 and 124 alone.

Worked example

Two illustrative groups show how the tests work. The names are made up. The exchange rates are assumptions for the arithmetic, not published rates.

A US parent above both thresholds

A Delaware parent reports on a calendar year. It owns one Indian Private Limited company that builds software for the parent.

Fact	Figure
Consolidated revenue, calendar year 2024	USD 960 million
Consolidated revenue, calendar year 2025	USD 1,050 million
Assumed TT buying rate, 31 Dec 2024	Rs 85 per USD
Assumed TT buying rate, 31 Dec 2025	Rs 88 per USD
Indian entity's international transactions, January to December 2025	Rs 61 crore
Indian entity's international transactions, FY 2025-26	Rs 67 crore (software services Rs 64 crore, cost recharges Rs 3 crore)
Intangible transactions	None

Step 1 is the Part B revenue test. Calendar year 2025 revenue is USD 1,050 million × Rs 88 = Rs 92,400 million, which is Rs 9,240 crore. That exceeds Rs 500 crore.

Step 2 is the transaction limb. The Indian entity's international transactions are Rs 61 crore on a calendar year basis and Rs 67 crore for FY 2025-26. Both exceed Rs 50 crore, so the pairing question does not change the answer. Part B applies.

Step 3 is the CbCR test for the reporting year ended 31 Dec 2025. It looks at calendar year 2024. USD 960 million × Rs 85 = Rs 81,600 million, which is Rs 8,160 crore. That exceeds Rs 6,400 crore, so section 286 (now section 511) applies.

Step 4 is the local filing check. The US parent files its CbC report with the IRS. India and the US exchange CbC reports under the 2019 agreement. No local filing trigger applies, so the Indian entity files only the intimation.

Step 5 is the CbCR test for the next reporting year, ending 31 Dec 2026. It looks at calendar year 2025: Rs 9,240 crore. The intimation duty continues.

Date	Filing by the Indian entity
31 Oct 2026	Form 3CEB for FY 2025-26, with the local file complete
31 Oct 2026	CbCR intimation for the parent year ended 31 Dec 2025, naming the US parent and the United States
30 Nov 2026	ITR-6 for AY 2026-27
30 Nov 2026	Form 3CEAA, Part A and Part B
31 Oct 2027	Form 48 for tax year 2026-27
31 Oct 2027	Form 58 for the parent year ending 31 Dec 2026
30 Nov 2027	Return for tax year 2026-27 and Form 56, Part A and Part B

If the group later adds a second Indian company, it can file Form 57 by 31 Oct. One entity then files Form 56 for both. Each Indian company still files its own Form 58.

A UK parent caught by the intangible limb

A UK parent has a 31 Mar year end. Its Indian subsidiary provides support services and pays the parent a royalty for its brand and platform.

Fact	Figure
Consolidated revenue, year ended 31 Mar 2025	GBP 65 million
Consolidated revenue, year ended 31 Mar 2026	GBP 72 million
Assumed TT buying rate, 31 Mar 2025	Rs 110 per GBP
Assumed TT buying rate, 31 Mar 2026	Rs 118 per GBP
Indian services income from the parent, FY 2025-26	Rs 26 crore
Royalty paid to the parent, FY 2025-26	Rs 11.5 crore
Total international transactions, FY 2025-26	Rs 37.5 crore

The group year and the Indian year match, so the pairing question does not arise.

The Part B revenue test gives GBP 72 million × Rs 118 = Rs 8,496 million, which is Rs 849.6 crore. That exceeds Rs 500 crore.

The general transaction limb fails, because Rs 37.5 crore is below Rs 50 crore. The intangible limb passes, because the Rs 11.5 crore royalty exceeds Rs 10 crore. Part B applies.

The CbCR test for the year ended 31 Mar 2026 looks at the year ended 31 Mar 2025. GBP 65 million × Rs 110 = Rs 7,150 million, which is Rs 715 crore. That is far below Rs 6,400 crore. No CbCR intimation is due.

The Indian entity files Form 3CEB by 31 Oct 2026 and Form 3CEAA with Parts A and B by 30 Nov 2026. If it filed only Part A, the exposure would be Rs 5 lakh under section 271AA(2).

Now change one fact. If the royalty were Rs 9.5 crore, both limbs would fail. The entity would file Part A only. A Rs 2 crore change in one royalty moves the whole Part B obligation. That is why we test the royalty figure before the parent fixes the year end licence fee.

Common mistakes

1. Skipping Part A because the thresholds are not met. Part A has no threshold. Fix: file Form 3CEAA Part A, or Form 56 Part A from tax year 2026-27, for every Indian constituent entity each year.
2. Using the Indian entity's revenue for the group test. Rule 123 and section 511(8) look at consolidated group revenue. Fix: take the figure from the group's consolidated financial statements and convert it at the TT buying rate.
3. Testing the wrong year. Part B tests the accounting year the master file covers. CbCR tests the year before the reporting year. Fix: build the test as two separate lines with two dates.
4. Reading "Rs 6,400 crore or more". The law says "exceeds". Fix: treat exactly Rs 6,400 crore as below the threshold, and record the calculation.
5. Missing Form 58 because the parent files CbCR abroad. Section 511(1) puts the intimation duty on each Indian entity whatever the parent does. Fix: calendar Form 58 for ten months after the parent's year end.
6. Ignoring the intangible limb. A royalty or software licence above Rs 10 crore triggers Part B. It does so even when total transactions are below Rs 50 crore. Fix: total intangible payments and receipts separately from services.
7. Confusing Form 57 with Form 60. Form 57 designates a master file filer. Form 60 designates a CbC report filer. Fix: check which duty needs a designation before filing either.
8. Assuming the parent's exemption at home settles India. A currency gap or a missing exchange agreement can move the CbC report to India. Fix: check the section 511(4) triggers and the exchange relationship every year.
9. Relabelling a foreign master file and uploading it. Form 56 has its own fields and Annexures A-1 to A-11. Fix: map the group document into the Indian structure and reconcile it with the local file.
10. Leaving the local file until a notice arrives. The 2025 Act gives ten days to respond. Fix: have the local file complete by 31 Oct, the specified date.

Checklist for master file and CbCR filings

1. Confirm that the Indian entity is a constituent entity of an international group under section 511(10)(d) and (g).
2. Record the parent's accounting year end and its country of tax residence.
3. Obtain consolidated group revenue for the current and the preceding accounting year, in the group's reporting currency.
4. Convert both figures to rupees at the TT buying rate on the relevant last day.
5. Total the Indian entity's international transactions and, separately, its intangible property transactions.
6. Decide whether Part B applies, using the Rs 500 crore test and the two transaction limbs.
7. Decide whether CbCR applies, using the Rs 6,400 crore test on the preceding year.
8. Check the parent's country for the three section 511(4) triggers and an activated exchange relationship with India.
9. Get a written designation from the group if two or more Indian entities will file Form 56 or Form 59.
10. Send the data request list to the parent's tax team, with dates.
11. File the CbCR intimation ten months after the parent's year end.
12. File Form 3CEB (or Form 48) and complete the local file by 31 Oct.
13. File Form 57 or Form 3CEAB at least 30 days before the master file due date, if designating.
14. File Form 3CEAA (or Form 56) with the return by 30 Nov.
15. Reconcile the master file, the local file, Form 48 and the CbC report figures for India.
16. Keep the working papers, the exchange rate evidence and the group's written confirmations with the tax file.

For a threshold check before the 31 Oct 2026 dates, contact us with the group revenue and the draft Form 3CEB.

Frequently Asked Questions

Is Form 56 the same as Form 3CEAA?+

Yes. Form 56 under rule 123 of the Income Tax Rules, 2026 replaced Form 3CEAA under rule 10DA of the 1962 Rules. Both carry the master file in Part A and Part B. Use Form 3CEAA for FY 2025-26, due 30 Nov 2026, and Form 56 from tax year 2026-27. The thresholds of Rs 500 crore, Rs 50 crore and Rs 10 crore are unchanged.

Does a small Indian subsidiary of a small foreign company have to file anything?+

Yes. It is a constituent entity of an international group, so it files Part A. That means Form 3CEAA for FY 2025-26 and Form 56 from tax year 2026-27. Part A has no revenue or transaction threshold. It asks for basic details such as the entity's name, address and PAN. Missing it can attract Rs 5 lakh under section 442(2).

Does Part A apply if the Indian company had no international transactions in the year?+

Yes. Part A depends on being a constituent entity of an international group, not on transactions. The due date then moves. A company with no international or specified domestic transaction files no Form 48. Its return is then due on 31 Oct under section 263(1)(c), not 30 Nov. Form 56 Part A follows that 31 Oct date.

What exchange rate converts the group's revenue into rupees?+

The master file test uses the telegraphic transfer buying rate on the last day of the accounting year (rule 10DA, now rule 123(6)). The CbCR test uses the rate on the last day of the preceding accounting year (rule 10DB, now rule 124). Rule 124 takes the meaning of that rate from rule 207. We keep a copy of the rate with the working papers.

Is the master file revenue test based on the current or the previous year?+

The current one. The guidance note on Form 56 tests consolidated group revenue "for the accounting year" the master file covers. Only the CbCR test looks back to the preceding accounting year, under section 511(8). Several published summaries apply the previous year to both tests, which can put a growing group on the wrong side of Rs 500 crore.

Is the CbCR threshold Rs 6,400 crore or more, or more than Rs 6,400 crore?+

More than Rs 6,400 crore. Section 511(8) switches off section 511 for a year when the preceding year's group revenue "does not exceed" the rule 124 amount. A group at exactly Rs 6,400 crore has no Form 58, 59 or 60 duty. Keep the calculation on file in case of a query.

Our US parent files its CbC report with the IRS. Does the Indian subsidiary still file anything?+

Yes, if the group's revenue exceeded Rs 6,400 crore in the preceding year. The Indian subsidiary files Form 58 (Form 3CEAC for older years) naming the US parent. It does not file Form 59, because India and the US exchange CbC reports under the agreement signed on 27 Mar 2019. It also files Form 56 Part A, and Part B if a limb is met.

Who files and signs Form 56, and does it need a Chartered Accountant?+

The Indian constituent entity files Form 56 itself on the income tax portal and verifies it electronically. The CBDT guidance note describes no accountant's report for it. Form 48 is different, because a Chartered Accountant must sign that report under section 172. In practice the group tax team drafts the content and the Indian entity files.

Can one Indian company file for all the group's Indian companies?+

Yes, for the master file and, where local filing applies, for the CbC report. For Form 56, the group designates one entity and that entity files Form 57 at least 30 days before the due date. For Form 59, the group files Form 60 under section 511(5). Form 58 has no designation route. Each Indian entity files its own.

What happens if the parent's country does not exchange CbC reports with India?+

The Indian entity must file the CbC report itself in Form 59 under section 511(4), within 12 months of the parent's year end. If two or more Indian entities exist, the group files Form 60 first to name one. The only escape is an alternate reporting entity that files in a country meeting the section 511(6) conditions.

What is an alternate reporting entity?+

It is a group entity, other than the parent, that files the CbC report for the group in its own country. Section 511(10)(c) defines it. India accepts that filing under section 511(6) only if that country requires the report, exchanges reports with India and is not in systemic failure. The entity must also have told its own tax authority in writing that it files for the group. The Indian entity must have filed its Form 58.

What does systemic failure mean for an Indian subsidiary?+

Under section 511(10), systemic failure describes a country that has an exchange agreement with India but does not honour it. It either suspends automatic exchange for reasons the agreement does not allow, or keeps failing to send India the CbC reports it holds. If India tells the Indian entity about it, the entity files Form 59 within six months from the end of the month of that intimation.

How is the daily penalty for a late CbC report worked out?+

Section 459(1) charges Rs 5,000 a day for a failure of up to one month. It charges Rs 15,000 a day for each day beyond one month. Take Form 59 filed 45 days late, with the first month counted as 30 days. The penalty is Rs 1.5 lakh plus Rs 2.25 lakh, a total of Rs 3.75 lakh. After a penalty order is served, the rate becomes Rs 50,000 a day.

Is there relief if we miss a master file or CbCR date for a good reason?+

Yes, but you must prove it. Section 470 of the Income Tax Act, 2025 replaced section 273B. It says no penalty under sections 442, 457 or 459 applies if the person proves reasonable cause for the failure. Keep evidence such as the dated data request to the parent and any portal errors. File as soon as the cause ends.

What if we find an error in the CbC report after filing it?+

Report it and file a corrected report within 15 days of finding it. Section 459(4) charges Rs 5 lakh where the entity finds an inaccuracy after filing and does not act within 15 days. Acting means informing the prescribed authority and furnishing a correct report. The same Rs 5 lakh applies if the entity knew of the error when it filed.

Does a group with Rs 900 crore of revenue file the CbCR intimation?+

No. Section 511(8) switches off section 511, including the Form 58 intimation, below the threshold. It applies when the preceding year's group revenue does not exceed Rs 6,400 crore. The same group still files Form 56 Part A. It files Part B too if its Indian entity has international transactions above Rs 50 crore or intangible transactions above Rs 10 crore.

When is Form 60 due, given that the Rules set no date?+

The Act and rule 124 prescribe no deadline for Form 60. The CBDT guidance note still says it should be filed at least 30 days before the Form 59 due date. For a parent year ending 31 Dec 2026, that means by 1 Dec 2027. File it with that margin, because without it each Indian entity carries the Form 59 duty.

How long must the master file records be kept?+

Rule 123(5) of the Income Tax Rules, 2026 requires nine years from the end of the relevant tax year. Rule 10DA of the 1962 Rules required eight years from the end of the relevant assessment year. The two periods end on the same date, so FY 2025-26 records run to 31 Mar 2035. The local file rule, rule 84, also uses nine years.

Sources

• Income Tax Department, Guidance note on Form No. 56 (master file) and Forms 57 to 60, undated, read 27 Sep 2026, https://www.incometaxindia.gov.in/documents/d/guest/fn-56
• Directorate of Income Tax (Public Relations, Publications and Publicity), Form Nos. 56, 57, 58, 59 and 60: master file and country by country report, March 2026, https://www.incometaxindia.gov.in/documents/d/guest/8-master-file-and-country-by-country-report-cbcr-pdf
• Income Tax Department, FAQs and guidance notes on forms as per the Income Tax Rules, 2026, read 27 Sep 2026, https://www.incometaxindia.gov.in/faqs-and-guidance-notes-on-forms-as-per-income-tax-rules-2026
• Income Tax Department, Form No. 58 page (title under section 511(1)), uploaded 24 Mar 2026, https://www.incometaxindia.gov.in/w/form-no.-58
• Income Tax Department, Section 171, Income Tax Act, 2025, https://www.incometaxindia.gov.in/w/section-171-82
• Income Tax Department, Section 511, Income Tax Act, 2025, https://www.incometaxindia.gov.in/w/section-511-2
• Income Tax Department, Section 263, Income Tax Act, 2025, https://www.incometaxindia.gov.in/w/section-263-72
• Income Tax Department, Section 173, Income Tax Act, 2025 (specified date), https://www.incometaxindia.gov.in/w/section-173-82
• Income Tax Department, Rule 84, Income Tax Rules, 2026 (information and documents under section 171(1)), https://www.incometaxindia.gov.in/w/rule-84-3
• Income Tax Department, Rule 123, Income Tax Rules, 2026, https://www.incometaxindia.gov.in/w/rule-123-2
• Income Tax Department, Rule 124, Income Tax Rules, 2026, https://www.incometaxindia.gov.in/w/rule-124-2
• Income Tax Department, Section 442, Income Tax Act, 2025, https://www.incometaxindia.gov.in/w/section-442-5
• Income Tax Department, Section 457, Income Tax Act, 2025, https://www.incometaxindia.gov.in/w/section-457-5
• Income Tax Department, Section 459, Income Tax Act, 2025, https://www.incometaxindia.gov.in/w/section-459-6
• Income Tax Department, Section 470, Income Tax Act, 2025, https://www.incometaxindia.gov.in/w/section-470-6
• Income Tax Department, Section 92D, Income Tax Act, 1961, https://www.incometaxindia.gov.in/w/section-92d-19
• Income Tax Department, Section 286, Income Tax Act, 1961, https://www.incometaxindia.gov.in/w/section-286-60
• Income Tax Department, Section 271AA, Income Tax Act, 1961, https://www.incometaxindia.gov.in/w/section-271aa-27
• Income Tax Department, Section 271G, Income Tax Act, 1961, https://www.incometaxindia.gov.in/w/section-271g-27
• Income Tax Department, Section 271GB, Income Tax Act, 1961, https://www.incometaxindia.gov.in/w/section-271gb
• Income Tax Department, Rule 10D, Income Tax Rules, 1962, https://www.incometaxindia.gov.in/w/rule-10d
• Income Tax Department, Rule 10DB, Income Tax Rules, 1962 (threshold substituted by the Income Tax (Ninth Amendment) Rules, 2021), https://www.incometaxindia.gov.in/w/rule-10db
• CBDT, Notification 92/2017 inserting rules 10DA and 10DB and Forms 3CEAA to 3CEAE, 2017, https://www.incometaxindia.gov.in/documents/20117/6507196/Notification92_2017.pdf/253cc386-bdae-b555-6f49-d4a330b16154?t=1763185541778
• CBDT, Notification 22/2026, Income Tax Rules, 2026 (GSR 198(E)), 20 Mar 2026, https://www.incometaxindia.gov.in/documents/d/guest/en-notified-it-rules-2026-20-03-2026-pdf
• Income Tax Department, Notification No. 22/2026 [F. No. 370142/41/2025-TPL] / GSR 198(E), notification page, 20 Mar 2026, https://www.incometaxindia.gov.in/w/notification-no.-22/2026-f.-no.-370142/41/2025-tpl-/-g.s.r.-198-e-
• CBDT, Income Tax (Fourth Amendment) Rules, 2026 (GSR 822(E)), 17 Sep 2026, https://www.incometax.gov.in/iec/foportal/sites/default/files/2026-09/Notification-no-120-2026.pdf
• CBDT, FAQs on interplay and transition to the Income Tax Act, 2025 (updated), 2026, https://www.incometaxindia.gov.in/documents/81799/11848482/Updated-FQAs-on-Interplay&Transitions.pdf/e10ad2b6-9495-de90-58d3-20606d8954ae?t=1775128640970
• Income Tax Department, Form No. 48 FAQs, 2026, https://www.incometaxindia.gov.in/documents/d/guest/form-48-faqs
• Income Tax Department, Guidance note on Form No. 48, 2026, https://www.incometaxindia.gov.in/documents/d/guest/fn-48
• Press Information Bureau, Signing of Inter Governmental Agreement for exchange of country by country reports between India and the United States of America, 27 Mar 2019, https://www.pib.gov.in/Pressreleaseshare.aspx?PRID=1569599&reg=48&lang=2