Loading...

⚠ ✕
❮ Top
☎ Help
☰
×

By creating an account you can:

Logo TaxTMI
Call Us / Help / Feedback✕

Contact Us At :

✉ E-mail: [email protected]

✆ Call / WhatsApp at: +91 99117 96707

For more information, Check Contact Us

FAQs :

To know Frequently Asked Questions, Check FAQs

Most Asked Video Tutorials :

For more tutorials, Check Video Tutorials

Submit Feedback/Suggestion :

Email :
Please provide your email address so we can follow up on your feedback.
Category :
Description :
Min 15 characters 0/2000
Make Most of Text Search ✕
  1. Checkout this video tutorial: How to search effectively on TaxTMI.
  2. Put words in double quotes for exact word search, eg: "income tax"
  3. Avoid noise words such as : 'and, of, the, a'
  4. Sort by Relevance to get the most relevant document.
  5. Press Enter to add multiple terms/multiple phrases, and then click on Search to Search.
  6. Text Search
  7. The system will try to fetch results that contains ALL your words.
  8. Once you add keywords, you'll see a new 'Search In' filter that makes your results even more precise.
  9. Text Search
╳
Add to...
You have not created any category. Kindly create one to bookmark this item!
✕
Create New Category
Hide
Title :
Description :
❮❮ Hide
❮ Default View
Expand ❯❯
Close ✕
🔎 Filters / Advanced Search ❯
TEXT

Press 'Enter' to add multiple search terms. Rules for Better Search

Search In
Main Text + AI Text ❯
  • Main Text
  • Main Text + AI Text
  • AI Text
Category: ?
Categorized by AI
---- All Categories ---- ❯
  • ---- All Categories ----
  • Income Tax
  • GST
  • Customs, DGFT & SEZ
  • FEMA & RBI
  • Corp. Laws, SEBI & IBC
  • PMLA, Black Money & ED
  • Budget
  • News and Press Release
  • PTI News
Month:
---- All Months ---- ❯
  • ---- All Months ----
  • January
  • February
  • March
  • April
  • May
  • June
  • July
  • August
  • September
  • October
  • November
  • December
Year:
---- All Years ---- ❯
  • ---- All Years ----
  • 2026
  • 2025
  • 2024
  • 2023
  • 2022
  • 2021
  • 2020
  • 2019
  • 2018
  • 2017
  • 2016
  • 2015
  • 2014
  • 2013
  • 2012
  • 2011
Sort By: ?
In Sort By 'Default', exact matches for text search are shown at the top, followed by the remaining results in their regular order.
Relevance Default Date
☰   Show Results ❯
    15th Meeting of ASEAN-India Trade in Goods Agreement (AITIGA) Joint Committee held during 6-9 October 2026
    Commerce Secretary Shri Rajesh Agrawal Highlights Need for Rigorous Legal Thinking at CTIL’s 9th Anniversary Celebration
    Release of Draft Guideline for Compilation Gross State Domestic Product (GSDP) Estimates by Expenditure Approach with Base Year 2022-23
    NLMC Invites Bids for Monetisation of 5.119-Acre Prime Freehold Land Parcel of HIL (India) Limited in New Delhi
    Union Finance Minister Smt. Nirmala Sitharaman on visit to Singapore for high-level meetings with Singapore Leadership and CEOs of business firms in S...
    Recommendations of the 57th Meeting of the GST Council
    India Began Building Bridges When the World Was Building Walls: Union Minister of Commerce and Industry Shri Piyush Goyal
    CCI approves acquisition of sole control over Omega-Meyer Ltd and Meyer Organics by BCPE Wellbeing Holdco Two Ltd. and Integral Investments Asia IV Lt...
    CCI approves proposed acquisition of 100% shareholding of Vishavari Tollway Ltd and nine SPVs operating road assets in India by Concessoc 41 SAS
    CCI approves acquisition of certain shareholding in Prestige Hospitality Ventures Limited by CPP Investment Board Pvt. Holdings (4) Inc.
    CCI approves proposed combination related to internal restructuring of the JSW Group
    NLMC Organises Mock E-Auction Training Ahead of RINL Land E-Auction
    Central Bureau of Narcotics (CBN) conducts Jan Samvad at Malana in Kullu District to create preventive drug awareness and to promote development
    Adopted Joint Statement after the India-UK Financial Markets Dialogue 2026, held in London
    Commerce Secretary Shri Rajesh Agrawal Calls for Greater Utilisation of India-EFTA TEPA Opportunities
    Commerce and Industry Minister Shri Piyush Goyal Holds Meetings with Leading U.S. Companies in New York to Strengthen India–U.S. Trade and Investmen...
    Monetary Policy Statement, 2026-27 Resolution of the Monetary Policy Committee October 5 to 7, 2026
    An Approach Paper on Expanding the scope and coverage for the Index of Services Production
    DRI cracks down on cross-border gold smuggling along Indo-Bangladesh border; seizes over 8.3 kg foreign-origin gold; 4 arrested
    Secretary, DFS, Shri Sanjay Lohiya chairs review meeting on progress of Financial Inclusion Schemes with senior executives of Public Sector and Privat...
❮
❯
❯❯
Maximize Maximize Maximize
0 / 200
Expand Note
Add to Folder

No Folders have been created

+

Are you sure you want to delete "My most important" ?

NOTE:

News
Showing Results for :
Reset Filters
Results Found:
Show All Summaries Hide All Summaries
October 9, 2026
Show AI Summary
AITIGA review negotiations face time-bound subcommittee deliverables to resolve policy issues and modernise trade arrangements.
The AITIGA Joint Committee directed its sub-committees to accelerate pending review chapters through firm, time-bound deliverables and close coordination. Work covers legal and institutional issues, national treatment and market access, and rules of origin. ASEAN and India reaffirmed their commitment to resolve outstanding policy issues, deepen economic integration, and modernise the Agreement into a balanced and mutually beneficial framework strengthening bilateral trade.
October 9, 2026
Show AI Summary
International investment law requires balance between investment protection and States' regulatory authority amid sustainability and digital trade challenges.
International trade and investment law are increasingly shaped by sustainability-linked trade measures and digital trade and require rigorous legal analysis. CTIL supports trade capacity through legal analysis for free trade agreement negotiations, WTO processes, dispute settlement and institutional knowledge-building. International investment law increasingly recognises States' regulatory authority alongside investment protection, with institutionalisation, legitimacy and the balance between investment and public power identified as central concerns. Research and capacity-building also address climate, sustainability, supply chains, artificial intelligence and other emerging trade-policy areas.
October 9, 2026
Show AI Summary
Expenditure-side GSDP compilation framework standardises regional estimates through common methods, local data sources, and allocation indicators.
Draft guidelines establish a uniform framework for compiling expenditure-side Gross State Domestic Product estimates using base year 2022-23. They cover data sources, estimation procedures and methodologies for private and government consumption, gross fixed capital formation, inventory changes, valuables and net exports. State-specific data and allocation indicators are preferred, while recommended allocation methods support consistent estimates where direct subnational data are unavailable. The approach is intended to harmonise estimation practices and strengthen subnational national accounts capacity.
October 9, 2026
Show AI Summary
Freehold land monetisation proceeds through a two-stage electronic sale requiring technical bids and an Earnest Money Deposit.
Monetisation of a 5.119-acre freehold industrial land parcel owned by HIL (India) Limited at Najafgarh Industrial Area, New Delhi, is facilitated through an E-Tender followed by E-Auction. Eligible bidders must complete registration, submit technical bids, and furnish the required Earnest Money Deposit or Bank Guarantee by the stipulated deadline. Sale is subject to "as is where is", "as is what is", "whatever there is" and no-recourse or no-complaint conditions. The exact land extent is to be determined through a joint survey with the successful bidder.
October 9, 2026
Show AI Summary
India-Singapore investment cooperation advances through investor engagement, financial connectivity, capital-market participation, and support for identified investment opportunities.
India-Singapore investment cooperation is to be strengthened through engagements with political leadership, business representatives and global institutional investors. Discussions cover trade and investment, digital financial connectivity, capital markets, taxation, advanced manufacturing, skilling and aviation. The National Investment and Infrastructure Fund and GIFT City are identified as channels for Singaporean capital participation through investment vehicles and funds. The Ministry of Finance will facilitate connections between investors, Indian companies, financial institutions and State Governments for identified investment opportunities.
October 8, 2026
Show AI Summary
GST process reforms propose automated registration, refunds and return corrections while easing enforcement, credit access and trade compliance.
GST process reforms propose automated registration, registration amendments and cancellation, return reconciliation, input tax credit correction, and phased system-based refund processing. Standardised demand notices and adjudication safeguards are proposed alongside lower penalties, capped penalty-only appeal pre-deposits, withdrawal of arrest powers and narrowed prosecution provisions. Input tax credit reforms would expand refunds and remove specified blocked-credit restrictions, while export measures would broaden zero-rated and export-of-services eligibility. Goods interception would be intelligence-based and authorised, with further compliance relief for small taxpayers and targeted classification, exemption and reverse-charge measures.
October 8, 2026
Show AI Summary
Free trade agreement utilisation enables MSME market access, rules-of-origin awareness, export participation, and foreign investment opportunities while protecting sensitive sectors.
Free Trade Agreements are positioned to preserve sensitive domestic interests, particularly agriculture, fisheries and MSMEs, while widening market access for agricultural, marine, engineering, precision and electronic products and facilitating foreign investment. Proposed FTA utilisation desks across State Councils would assist MSMEs in using preferential arrangements, understanding rules of origin and market-access opportunities, participating in delegations and exhibitions, and presenting products and technologies to overseas markets.
October 8, 2026
Show AI Summary
Sole-control acquisition of nutraceutical and pharmaceutical businesses receives competition approval for Bain Capital-managed investment funds.
Competition Commission of India approval permits BCPE Wellbeing Holdco Two Limited and Integral Investments Asia IV Limited, funds managed or advised by Bain Capital, to acquire sole control over Omega-Meyer Limited and Meyer Organics Private Limited. The target businesses provide nutraceuticals globally and in India, while Meyer Organics Private Limited also produces and supplies certain over-the-counter and prescription finished-dose pharmaceuticals in India.
October 8, 2026
Show AI Summary
Highway asset acquisition approval covers full ownership transfer of a tollway operator and road-project special purpose vehicles.
Competition Commission of India approval covers the acquisition by Concessoc 41 SAS of the entire shareholding in Vishavari Tollway Private Limited and nine special purpose vehicles. The target entities operate designated national-highway stretches in Andhra Pradesh, Odisha and Gujarat, while Vishavari Tollway Private Limited provides operation and maintenance and engineering, procurement and construction services for those highway assets.
October 8, 2026
Show AI Summary
Competition clearance for hospitality share acquisition permits investment in a company owning and developing hotel and serviced apartment assets.
Competition Commission of India approved the proposed combination involving CPP Investment Board Private Holdings (4) Inc.'s acquisition of certain shareholding in Prestige Hospitality Ventures Limited. The target is an Indian public limited company within the Prestige group and owns and develops hospitality assets, including hotels and serviced apartments. The acquirer is incorporated in Canada and is managed by Canada Pension Plan Investment Board.
October 8, 2026
Show AI Summary
Internal group restructuring receives merger-control approval for amalgamating an integrated steel producer into the group's steel manufacturer.
Merger-control approval covers the proposed internal JSW Group restructuring through amalgamation of BMM Ispat Limited into JSW Steel Limited. The amalgamation would convert the group's majority interest in BMM into full ownership and is intended to enhance operational, financial and organisational efficiencies through economies of scale, resource pooling and capital rationalisation. BMM is commercially integrated in the group's supply chain through intra-group sales and procurements.
October 7, 2026
Show AI Summary
Transparent land e-auction procedures support bidder preparedness through mock training, registration and earnest-money requirements for phased asset monetisation.
National Land Monetization Corporation is facilitating a two-phase e-tender-cum-e-auction of 459 encumbrance-free land parcels of Rashtriya Ispat Nigam Limited through the RailTel E-Nivida e-Procurement Platform. Participation requires registration, fulfilment of prescribed requirements and submission of earnest money deposit within the applicable deadlines. Physical and online mock e-auction training familiarises prospective bidders with the bidding interface and participation procedure. Investor outreach provides information on plot details, eligibility requirements, registration and bidding conditions.
October 7, 2026
Show AI Summary
Preventive narcotics outreach promotes drug awareness, community participation, and sustainable livelihood alternatives to discourage illicit cannabis cultivation.
Preventive outreach in Malana village promoted drug awareness, youth engagement, community participation and alternative development in an area associated with illicit cannabis cultivation. Residents were sensitised to the harmful effects of cannabis, charas and hashish oil consumption and encouraged to pursue sustainable alternatives, including apiculture, animal husbandry, dairy activities and tourism. Community discussions addressed livelihood barriers, ecological concerns, and commitments to refrain from drug consumption and discourage illicit cannabis cultivation.
October 7, 2026
Show AI Summary
Cross-border financial cooperation guides work on market access, sustainable finance, fintech safeguards, and payment interoperability.
India-UK financial-markets cooperation covers capital-market connectivity, cross-border listings, investor access and development of GIFT IFSC as an international financial centre. Engagement also addresses insurance, pensions, asset management, sustainable-finance disclosures and cross-border investment. Fintech cooperation includes digital public infrastructure, central bank digital currencies, data exchange, responsible artificial intelligence, fraud prevention, cyber security and operational resilience. Cross-border payments work prioritises reduced frictions, transparency, efficiency and interoperability of electronic payment infrastructures.
October 7, 2026
Show AI Summary
Investment commitments and tariff predictability under India-EFTA TEPA support market access, supply-chain planning, and long-term bilateral trade.
India-EFTA TEPA establishes reciprocal market-access commitments, with EFTA coverage extending to most Indian exports and full coverage for non-agricultural products. Tariff predictability is intended to support investment planning, supply-chain development and longer-term business partnerships. Agricultural opportunities may arise where duties have been reduced to zero. Article 7.1 includes an investment commitment under which the EFTA States are to aim to increase foreign direct investment into India and facilitate employment generation within specified implementation periods.
October 7, 2026
Show AI Summary
Foreign investment engagement focuses on expanded partnerships across financial services, manufacturing, insurance, and emerging technologies in India.
India-U.S. trade and investment engagement was pursued through discussions with leading United States companies on expanding investment, partnerships and commercial operations in India. Financial-sector discussions addressed private equity, asset and wealth management, insurance, and financial services, including prospective engagement aligned with the objective of insurance access for all by 2047.
October 7, 2026
Show AI Summary
Policy repo rate recalibration responds to inflationary pressures, adopting calibrated tightening while future actions depend on growth and inflation conditions.
Monetary policy is recalibrated through an increase in the policy repo rate under the liquidity adjustment facility by 25 basis points to 5.50 per cent. The monetary policy stance shifts to calibrated tightening, indicating that near-term rate reductions are excluded and that subsequent action may consist of a rate increase or a pause, depending on evolving conditions and the outlook. Further rate action depends on growth-inflation developments, underlying inflation, broadening price pressures, second-round effects and demand impulses.
October 7, 2026
Show AI Summary
Index of Services Production expansion proposes broader service-sector coverage through education, health, residential care, public administration and defence.
The Index of Services Production is proposed to expand beyond its initial formal-sector coverage, which relies on high-frequency administrative data and GST outward-supplies data. Education, Human Health and Residential Care, and Public Administration and Defence are proposed for inclusion. Their incorporation would increase coverage of services-sector Gross Value Added and support aggregation of sub-sectoral indices into a unified measure of short-term services-sector movements. Stakeholder views are invited on the proposed methodology.
October 7, 2026
Show AI Summary
Cross-border gold smuggling enforcement addresses concealed foreign-origin gold transport through customs seizure, arrest, and investigation of organised networks.
Intelligence-led customs enforcement targeted cross-border gold smuggling through surveillance and interception of four persons travelling from a border route. Personal searches recovered foreign-origin gold biscuits concealed in specially tailored cloth waist belts. Seventy-two gold biscuits were seized under relevant provisions of the Customs Act, 1962, and the four persons were arrested. Investigation continues into organised networks and wider syndicates involved in the movement and distribution of smuggled gold.
October 6, 2026
Show AI Summary
Financial inclusion drives digital lending, insurance claim awareness, portal enrolment, and banking access for marginalised sections.
Banks were urged to expand brick-and-mortar branches and banking correspondent coverage in unbanked villages, strengthen digital outreach, and implement end-to-end digital loan processing. Working-capital lending for micro-enterprises through UPI-linked credit lines and credit cards was highlighted. Banks were also directed to increase awareness of insurance claim eligibility, exercise care in claim-related grievance handling, and enrol new PMJJBY and PMSBY beneficiaries through the Jan Suraksha portal.

News

Back

All News

Showing Results for :
Reset Filters
No Records Found

News

Back

All News

Guidance note - Form 51

March 27, 2026

Contents
Forms
Summary
Note

Note

-

Bookmark

Print

Print

Form 51- Application for an Advance Pricing Agreement

Name of Form as per I.T. Rules, 1962

Form 3CED & 3CEDA

Name of Form as per I.T. Rules, 2026

51

Corresponding section of I.T. Act, 1961

92CC

Corresponding section of I.T. Act, 2025

168

Corresponding Rule of I.T. Rules, 1962

10-I

Corresponding Rule of I.T. Rules, 2026

106

Purpose:

Form 51 of the Income Tax Act, 2025, is the application form for an Advance Pricing Agreement (APA). An APA is an agreement between a taxpayer and the Central Board of Direct Taxes (CBDT) to determine the transfer price or the manner of determining the transfer price for international transactions (and specified domestic transactions) for a specified period. Form 51 is filed under Rule 106 and Rule 111 of the Income-tax Rules, 2026, and can be filed by person to eligible to apply under Rule 104 of the Income-tax Rules, 2026. This form also combines the erstwhile Form 3CED (to apply for an Advance Pricing Agreement) and Form 3CEDA (to apply for Rollback of an Advance Pricing Agreement).

Who Should File:

Any person who has entered into or is contemplating entering into international transactions with an associated enterprise can apply for an APA by filing Form 51. Eligible applicants seeking rollback can also file Form 51.

Frequency & Due Dates:

The application must be filed before the start of the first tax year for which the APA is sought in respect of transactions which are of a continuing nature from dealings that are already occurring; or before undertaking the transaction in respect of remaining transactions and is applicable for a duration, typically of five tax years ahead in case of forward-looking APAs, and four tax years back in case of rollback, for a total of nine tax years.

Structure of Form 51:

⮚ Part A: Particulars of the Person

⮚ Part B: Other Details:

  • Particulars of proposed APA
  • Period of APA proposed
  • International Transactions proposed to be covered along with details of the same
  • International Transactions proposed to be covered along with details of the same in case Rollback request has been made.

⮚ Other details to be provided as annexures in separate enclosure:

General

A-1

History and background of the applicant and the associated enterprise.

A-2

General description of business and products/services.

A-3

Multinational structure, organizational arrangement, operational set-up, including major transaction flows.

A-4

Details of all other transaction flows of the multinational enterprise (volumes, directions and amounts) that may have an impact on the pricing of the covered transactions.

A-5

Proposed terms and conditions, and critical assumptions, for the APA.

A-6

Details of all the business location(s)

 

Address of the location(s)

Functions performed

Employee headcount

A-7

Details of parent company

a.

 

Details of all Immediate Parent Company:

Yes/ No

 

Name

 

 

Address

 

 

Country/region of residence

 

 

TIN or its equivalent

 

b.

Details of Ultimate Parent Company:

Yes/ No

 

Name

 

 

Address

 

 

Country/region of residence

 

 

TIN or its equivalent

 

Functional Analysis

A-8

Detailed functional analysis of the applicant and all relevant entities with respect to the covered transactions.

A-9

Business strategies:-

(i) current and future Budget statements,

(ii) projections and business plans for future period covered by proposed APA,

(iii) general business and industry trends,

(iv)future direction/business strategy including R&D,

(v) production and marketing,

(vi) Relevant marketing and financial studies (enclose copies).

A-10

Financial statements on a consolidated and unconsolidated basis for the prior 5 years, (Also provide interim statements for the most recent period prior to the date of the submission).

Industry and Market Analysis

A-11

Comprehensive description of industry as well as generally accepted industrial and commercial practices.

A-12

Identification and general profile of competitors, including respective market shares.

A-13

Industry and general business statistics, financial ratios, and analyses/studies.

A-14

Critical success factors for detailed industry analysis.

A-15

Detailed analysis of the markets for all countries involved.

Transfer Pricing Background

A-16

Discussion of relevant legal considerations and requirements as per Indian law, foreign Law and DTAA between India and the foreign country including competent authority history.

A-17

Discussion of relevant rulings, UAPAs/BAPAs/MAPAs, and other similar arrangements entered into with foreign tax administrations, for transfer pricing or other valuation bases, or other taxation matters entered into by the applicant (or its associated enterprises)

A-18

History of transfer pricing audits and present status of appeals.

Tax Year

Disputed International Transaction

Amount of Adjustment

Decision of each appellate authority

Current status

 

 

 

 

 

 

 

 

 

 

 

A-19

History of foreign transfer pricing audits and present status of appeals.

Tax Year

Disputed International Transaction

Amount of Adjustment

Decision of each appellate authority

Current status 

 

 

 

 

 

 

 

 

 

 

 

A-20

Copies of all relevant agreements (pricing, cost-sharing, licensing, agency, distributorship, etc.) relevant to this application is to be provided.

A-21

Operating data (gross and net) segmented by product line, division, unit, and geographic region for the prior 5 years,

Transfer Pricing Methodology (TPM) Analysis

A-22

Provide all information, including detailed analyses and explanations needed to establish the appropriateness of a proposed TPM, in accordance with transfer pricing regulations as contained in the Indian Income-tax law.

A-23

Discussion and analysis of each transfer pricing method, applied or rejected, for each covered transaction. In particular provide details on accepted or rejected internal comparable. (Indicate assumptions, strategies and policies that may have influenced the acceptance or rejection of each TPM).

A-24

Summary of selected TPMs and secondary TPMs, if used as a sanity check.

A-25

Application of the proposed TPMs to the covered transactions for the 5 prior years’ operations and the time period applicant wants to cover in APA, and discuss results.

A-26

Discussion and quantification of the variance from the proposed TPM, if any, from the TPM applied previously for the 5 prior years.

A-27

In case where rollback is not opted for any Transaction ID for any tax year, the reasons for the same is to be provided.

         

What are the documents required to file the Form 51?

Documents required are specifically mentioned in the Form and include (but are not limited to):

  • Financial Statements for the covered years of the APA Application
  • Inter-company agreements relevant to the Application

What is the process flow of filing Form 51?

The process flow includes following steps:

  1. The Applicant shall file Form 51 electronically to the Principal Chief Commissioner of Income-tax (International Taxation) or the Competent Authority in India (in case of Bilateral/Multilateral transactions).
  2. The PCCIT (IT)/Competent Authority shall assign the application to one of the 5 APA teams.
  3. On receipt of the Application, the relevant APA team shall take necessary action on the Application as per procedure outlined in the Income-tax Rules, 2026.

Outcome of Processed Form 51:

The outcome of a processed Form 51 could be:

  • Signing of an Advance Pricing Agreement (APA)
  • Withdrawal of the Application
  • Closure of the Application prior to signing or withdrawal

Brief note on broad or qualitative changes proposed:

  • The form 51 combines the erstwhile Form 3CED (to apply for an Advance Pricing Agreement) and Form 3CEDA (to apply for Rollback of an Advance Pricing Agreement). This has been done in view of the similarities of the two forms and shall lead to reduction in compliance burden and avoiding duplication of Forms
  • A number of queries which raised in the earlier version of the Form along with additional documentary requirements have been omitted with the aim of lowering compliance burden. Further, details have been asked for in easy-to-fill tabular form to the extent possible.
  • Erstwhile Form 3CEE: Application for withdrawal of APA request has been removed. A simple letter may be filed by the Applicant for withdrawal. This further reduces compliance burden for Applicant.

Challenges and Solutions:

Combining the erstwhile Form 3CED and Form 3CEDA (for rollback requests) represented a challenge in the form of unnecessary duplication of data in the same form. However, the current design of the form has eliminated such duplication, ensuring conciseness without sacrificing comprehensiveness.

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 “₹”.

Topics

Acts Income Tax