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The Government has released Draft Form No. 48, prescribing a comprehensive reporting framework under Section 172 of the Income Tax Act, 2025 for international transactions and specified domestic transactions. The draft form significantly expands disclosure requirements for transfer pricing complian
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FAQ :
Draft Form 48 is a new report required under Section 172 of the Income Tax Act, 2025, detailing international and specified domestic transactions for transfer pricing compliance. It requires comprehensive disclosures and certification by a Chartered Accountant.
The form covers international transactions, deemed international transactions, and specified domestic transactions, including the purchase and sale of goods, transfer of assets, royalty arrangements, capital financing, corporate guarantees, services, and business restructuring.
Assessees must disclose a list of Associated Enterprises, their country of residence, PAN/TIN or unique identifier, and the nature of their relationship. Both international and specified domestic AEs need to be reported separately.
Part E of Draft Form 48 requires detailed benchmarking disclosures, including the selection and application of the most appropriate method (e.g., CUP, RPM, CPM, PSM, TNMM), comparable margin disclosures, and detailed computation sheets.
Additional documentation requirements apply if the aggregate value of international transactions exceeds ₹1 crore, or if specified domestic transactions are reported. Assessees must confirm they have maintained the prescribed information and documents.
The report must be certified by a Chartered Accountant holding a valid certificate of practice, who will examine records, confirm documentation maintenance, and verify the accuracy of the particulars furnished.
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