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The Central Board of Direct Taxes (CBDT) has introduced Form 52 as the new Annual Compliance Report for taxpayers covered under Advance Pricing Agreements (APAs) under the Income-tax Act, 2025. The new form replaces the earlier Form 3CEF prescribed under the Income-tax Rules, 1962. As per the off
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Form 52 is a new annual compliance reporting form for taxpayers who have entered into Advance Pricing Agreements (APAs) with Indian tax authorities. It confirms adherence to the terms and conditions of the APA.
Form 52 is mandatory for all taxpayers who have entered into a Unilateral, Bilateral, or Multilateral APA with Indian tax authorities under the Income-tax Act, 2025.
Form 52 must be filed within 30 days from the due date of filing the income tax return for that year, or within 90 days of entering into the APA, whichever is later. A separate form is required for each year covered by the APA.
No, Form 52 must be filed electronically through the Income Tax e-Filing portal. No offline submissions are permitted.
Form 52 introduces a more detailed compliance reporting structure, including tabular adjustments for profit level indicator variations, specific reporting for aggregated transactions, detailed disclosure of critical assumptions (FAR), and explicit reporting on associated enterprises and invoicing patterns.
Taxpayers must maintain and furnish all documents agreed upon in the signed APA to justify the transfer pricing methodology and computation of the arm's length price at the time of filing Form 52.
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