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    Form No. 25 – Frequently Asked Questions (FAQs)
    Guidance Note - Form 24
    CCI approves proposed acquisition of additional shareholding of Valuedrive Technologies Pvt Ltd by Setu AIF Trust, Konark Trust, and MMPL Trust
    CCI approves acquisition of certain shares in Shriram Finance by MUFG Bank Ltd.
    CCI approves acquisition of shareholding of Groww Asset Management by State Street Global Advisors, Inc.
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    Govt asks RBI to maintain retail inflation at 4 pc till Mar 2031
    Oppn slams insolvency law over delays; BJP hits back, calls it 'Licence Raj' mindset
    Himachal cuts power tariff by one paisa per unit for all consumers
    Mahadev app: ED attaches Rs 1,700 cr worth assets including in Dubai's Burj Khalifa
    IBC led to recovery of over Rs 4 lakh cr from insolvent firms in last 10 years: Anurag Thakur
    Haryana electricity commission keeps power tariff unchanged for next financial year
    Form No. 24 – Frequently Asked Questions (FAQs)
    Guidance Note - Form 23
    FORM 23 — Frequently Asked Questions (FAQs)
    Guidance Note - Form 22
    Union Minister of Commerce and Industry Shri Piyush Goyal Urges Industry to Leverage FTAs with Developed Nations through Quality Focus
    14th Ministerial Conference of the World Trade Organization to be held in Yaoundé from 26–29 March 2026 under Cameroon’s chairmanship
    DPIIT Signs MoU with a Leading Fintech Platform to Strengthen India’s Startup Ecosystem
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March 26, 2026
Show AI Summary
Daily case register compliance for medical practitioners requires tabular records, electronic access safeguards, and preservation obligations.
Form No. 25 is the prescribed daily case register for practitioners of any system of medicine under Rule 46 of the Income-tax Rules, 2026, subject to the prescribed gross receipt threshold and the position of newly set-up medical practices. It records patient and fee particulars in tabular form, is not furnished to the Income-tax Department, but must be maintained daily, produced before the Assessing Officer when called for, may be kept electronically with India-based access and backups, and must be preserved for seven tax years or until completion of reassessment proceedings.
March 26, 2026
Show AI Summary
Permanent establishment audit reporting for royalty and technical services income now uses a structured Chartered Accountant certification format.
Form No. 24 is a statutory audit report for non-residents and foreign companies earning royalty or fees for technical services from India through a permanent establishment or fixed place of profession in India. It requires a Chartered Accountant's certification of the correctness of income computation, verification of the PE or fixed place, maintenance of books of account, and deduction only of expenses attributable to the PE while computing income under section 59. The form is filed annually, contains structured particulars of the assessee, agreement, PE, books examined, and income computation, and is submitted through the e-filing portal with digital signature verification.
March 26, 2026
Show AI Summary
Competition approval for additional shareholding acquisition in Valuedrive Technologies through an alternative investment and trust co-investment structure.
The Competition Commission of India approved the proposed acquisition of additional shareholding in Valuedrive Technologies Private Limited by Setu AIF Trust, Konark Trust and MMPL Trust. The transaction concerns acquisition of shares on a fully diluted basis through an alternative investment fund and private trust co-investment structure. Valuedrive Technologies Private Limited operates as an operating-cum-holding company for the Spinny Group and carries on an electronic platform business for used motor vehicles, together with related subsidiary activities.
March 26, 2026
Show AI Summary
Competition law approval for acquisition of shares in a listed NBFC by a Japan-based banking institution.
Competition Commission of India approval was granted for the acquisition of certain shares in Shriram Finance Limited by MUFG Bank Ltd. The acquirer is a Japan-based banking institution wholly owned and controlled by Mitsubishi UFJ Financial Group, Inc., and carries on banking-related activities in India including corporate banking loans, deposit accounts, remittances, trade finance, bank guarantees and hedging. The target is a listed non-banking financial company registered with the Reserve Bank of India, classified as an Investment and Credit Company and an NBFC-Upper Layer, engaged in financing commercial goods and passenger vehicles, construction equipment, farm equipment, MSMEs, two-wheelers, gold and personal loans.
March 26, 2026
Show AI Summary
Competition approval for acquisition of Groww Asset Management shareholding by State Street Global Advisors
Competition approval was granted for the proposed acquisition of shareholding in Groww Asset Management Limited by State Street Global Advisors, Inc. The target manages schemes of Groww Mutual Fund, including equity, hybrid, debt and exchange traded fund schemes. State Street operates under the State Street Investment Management brand as the asset management arm of State Street Corporation. The detailed order of the Commission would follow.
March 26, 2026
Show AI Summary
Competition combination approval for Coursera and Udemy merger, creating sole control over Udemy through a subsidiary merger.
Competition Commission of India approved a proposed combination involving the merger of Chess Merger Sub, a wholly owned subsidiary of Coursera Inc., with and into Udemy Inc., with Udemy surviving as a wholly owned subsidiary of Coursera. The transaction results in Coursera acquiring sole control over Udemy, and the combined company is expected to have post-closing shareholding in which existing Coursera stockholders hold approximately 59% and existing Udemy stockholders approximately 41% on a fully diluted basis.
March 26, 2026
Show AI Summary
Competition approval for renewable energy investment in Aditya Birla Renewables through equity subscription by GIP EM Star.
Competition Commission of India approved the subscription of certain equity share capital of Aditya Birla Renewables Limited by GIP EM Star Pte. Ltd. The acquirer is incorporated in Singapore and is ultimately linked to Global Infrastructure Management, LLC and BlackRock, Inc. The target, headquartered in Mumbai, is engaged in renewable energy power generation, including solar and wind power.
March 25, 2026
Show AI Summary
Inflation targeting framework retained with a 4 per cent objective and a 2 per cent tolerance band for the next cycle.
The central government, in consultation with the Reserve Bank, has notified the inflation target for 1 April 2026 to 31 March 2031 at 4 per cent, with an upper tolerance level of 6 per cent and a lower tolerance level of 2 per cent. The framework continues to place the Monetary Policy Committee in charge of setting the policy rate needed to achieve the inflation objective within the prescribed band.
March 25, 2026
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Insolvency resolution delays under the bankruptcy code draw debate over tribunal capacity, creditor recoveries, and reform priorities.
Delay in insolvency resolution under the Insolvency and Bankruptcy Code remained the central issue in parliamentary discussion on the Insolvency and Bankruptcy Code (Amendment) Bill, 2025. Members referred to tribunal capacity constraints, overburdened case loads, delayed liquidation and resolution timelines, value deterioration, and low realisations to creditors as continuing problems in the insolvency ecosystem. The select committee report was noted as seeking to address these structural concerns through amendments aimed at improving the functioning of the insolvency and bankruptcy framework.
March 25, 2026
Show AI Summary
Electricity tariff reduction cuts power charges by one paisa per unit across all consumer categories for FY27.
Electricity tariff for all consumer categories in Himachal Pradesh has been reduced by one paisa per unit for FY27, effective from 1 April 2026. The tariff order fixes the average cost of supply at Rs 6.75 per unit after truing up, resulting in a corresponding reduction in energy charges across consumer classes. The revised schedule sets category-wise tariffs for domestic, commercial, industrial, agricultural, railway, EV charging, irrigation, bulk supply, and street lighting consumers, while domestic subsidy is left to the state government decision and compensation mechanism.
March 25, 2026
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Money laundering attachment over Mahadev betting assets targets alleged proceeds of crime and overseas luxury properties.
Provisional attachment under the Prevention of Money Laundering Act was issued against immovable assets linked to the Mahadev Online Book betting operation, including luxury properties in Dubai, apartments in Burj Khalifa and two properties in Delhi. The attached assets were alleged to represent proceeds of crime generated from illegal online betting activities controlled through entities associated with the main promoter of the platform.
March 25, 2026
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Insolvency and Bankruptcy Code reform focuses on faster resolution, out-of-court settlements, and cross-border insolvency provisions.
The Insolvency and Bankruptcy Code is described as a revival and resolution framework that has generated substantial recoveries through resolution of bankrupt companies and improved creditor-debtor discipline. The proposed amendment bill seeks to reduce the time taken for admission of insolvency resolution applications, speed up case clearance, support out-of-court resolution, and address cross-border insolvency and discretionary provisions.
March 25, 2026
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Power tariff unchanged as the commission prioritizes revenue neutrality, loss reduction, and efficiency in electricity distribution.
The Haryana Electricity Regulatory Commission kept power tariff unchanged for the 2026-27 financial year and treated the Annual Revenue Requirement of the distribution licensees as revenue-neutral despite a projected revenue gap. The order linked the decision to improved efficiency in revenue collection, receivables management, power procurement and loss reduction, while also fixing distribution loss levels and directing feeder-level monitoring to curb losses.
March 25, 2026
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Permanent Establishment audit reporting governs royalty and technical fees income for non-residents under the prescribed form.
Form No. 24 is a prescribed audit report for non-residents, foreign companies, and other non-resident entities deriving royalty or fees for technical services from India through a Permanent Establishment or fixed place of profession in India. It is certified by an Accountant and is mandatory where such income is effectively connected with the Indian Permanent Establishment or fixed place of profession. The form requires books of account, supporting documents, annexures, and electronic certification details, and is furnished annually before the return due date. Furnishing and acceptance of the form support assessment on a net income basis.
March 25, 2026
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Skill Development Project notification under income tax law links approval, audit compliance, and renewal conditions for eligible companies.
Form 23 is the CBDT notification form for an approved Skill Development Project under Section 47(1)(b) of the Income-tax Act, 2025 read with Rules 39 and 40. It is issued after Form 22 is examined and recommended by NCVET, and it specifies the approved Tax Year(s), project particulars, conditions, and validity for up to three Tax Years. The framework requires separate books, audit, prescribed reporting, compliance with notification conditions, and permits renewal or revocation depending on project performance and statutory compliance.
March 25, 2026
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Skill development project notification governs approval, tax-year limits, conditions, and compliance for income-tax benefits.
Form 23 is the income-tax notification form for an approved skill development project under Section 47(1)(b) of the Income-tax Act, 2025, issued after approval under Rule 39. It notifies the project in the Official Gazette, specifies the approved tax years, and sets the terms, duration, and expenditure limits. The notification is issued by the Central Board of Direct Taxes on recommendation of NCVET, and contains the company's particulars, project details, training institute details, approved tax years, estimated expenditure, and attached conditions.
March 25, 2026
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Skill Development Project approval under income tax rules requires Form 22 filing, structured disclosures, and electronic verification.
Form 22 is the prescribed Income-tax application by which an eligible company seeks approval of a Skill Development Project under Section 47(1)(b) of the Income-tax Act, 2025 read with Rule 39. The form is filed with the National Council for Vocational Education and Training for recommendation to the Central Board of Direct Taxes, and it must be submitted electronically using DSC or EVC before commencement of the project. It requires disclosure of company particulars, project particulars, training institute details, prior notifications or revocations, return of income data, penalties, outstanding tax demands, expenditure projections, and supporting annexures.
March 25, 2026
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Free trade agreements and voluntary CSR are highlighted as tools for quality-led growth and inclusive development.
India's expanded free trade agreements are presented as a means of securing preferential market access for goods and services, with reduced or zero duty benefits linked to stronger export competitiveness. Indian industry, farmers, MSMEs, fishermen and artisans are urged to use these opportunities through a sustained focus on quality, higher standards and improved production and service capability. The statement also presents voluntary corporate social responsibility beyond statutory minima as an example of tangible social commitment.
March 25, 2026
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Multilateral trading system priorities shape India's agenda on WTO reform, food security, digital trade, and development concerns.
The WTO Ministerial Conference agenda covers WTO reform, the e-commerce work programme and moratorium, investment facilitation for development, fisheries subsidies, and agriculture-related issues. India's priorities include a development-centric multilateral trading system, a permanent solution on Public Stockholding for food security, effective Special and Differential Treatment, and a fully functional, automatic, and binding dispute settlement mechanism. India also supports policy space in digital trade, balanced fisheries subsidy disciplines, and investment facilitation for developing countries.
March 25, 2026
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Startup ecosystem partnership expands incorporation support, mentorship and financial tools for early-stage founders through a dedicated platform.
DPIIT entered into a strategic partnership with a leading fintech platform through a Memorandum of Understanding to strengthen India's startup ecosystem by supporting startups, innovators and entrepreneurs with financial tools, founder enablement programmes and ecosystem assistance. The collaboration is directed towards helping early- and growth-stage startups scale through digital payment solutions, financial infrastructure, incorporation support, mentorship and structured guidance for formalising and expanding operations. A dedicated platform, Startup Sahayak, has been launched to provide end-to-end assistance for early-stage founders, including company incorporation, access to schemes and guidance on funding opportunities.

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FORM NO. 120 – FREQUENTLY ASKED QUESTIONS (FAQS)

April 1, 2026

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FORM NO. 120 – FREQUENTLY ASKED QUESTIONS (FAQS)

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

Form 34C, 34D, 34DA, 34E & 34EA

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

Form No. 120

Corresponding section of I.T. Act, 1961

245N to 245W

Corresponding section of I.T. Act, 2025

380 to 389

Corresponding Rule of I.T. Rules, 1962

44E, 44F and 44FA

Corresponding Rule of I.T. Rules, 2026

200 to 202

1. What is Form No. 120?

Ans: Form No. 120 is an application form primarily used by non-resident applicants to seek a determination or ruling from the Board for Advance Rulings (BAR) on questions of law or fact relating to proposed or undertaken transactions by the applicant. These forms facilitate clarity and certainty on tax liability issues in advance, avoiding future disputes and litigations.

2. Who should file Form No. 120 and what is prescribed fee for seeking an Advance Ruling?

Ans: Form No. 120 can be filed by following category of applicants by paying prescribed fee as mentioned against respective category of applicants/transaction value below:

Applicant Category

Basis for Fee Determination

Transaction Value

Application Fee

Non-resident applicants

Aggregate value of transaction(s)

Amount not exceeding Rs. 100 crores.

₹2 lacs

Amount exceeding Rs. 100 Crores but not exceeding Rs. 300 Crores.

₹5 lacs

Amount exceeding Rs. 300 Crores.

₹10 lacs

Resident applicants transacting with non-residents

Aggregate value of transaction(s)

Amount not exceeding Rs. 100 crores.

₹2 lacs

Amount exceeding Rs. 100 Crores but not exceeding Rs. 300 Crores.

₹5 lacs

Amount exceeding Rs. 300 Crores

₹10 lacs

Specified resident applicants (including high-value residents)

Aggregate value of transaction(s)

Amount not exceeding Rs. 100 crores.

₹2 lacs

Amount exceeding Rs. 100 Crores but not exceeding Rs. 300 Crores.

₹5 lacs

Amount exceeding Rs. 300 Crores.

₹10 lacs

Public Sector Companies

In all cases

₹10,000

GAAR applicants

(resident or non-resident)

In all cases

₹10,000

3. When is Form No. 120 required to be filed?

Ans: Form No. 120 is required to be filed only if the applicant/taxpayer intends to seek a determination or ruling from the Board for Advance Rulings (BAR) on questions of law or fact relating to proposed or undertaken transactions by the applicant.

4. What is the time limit for filing Form No. 120?

Ans: There is no time limit for filing Form No. 120. Filing of Form No. 120 purely depends upon the intention of assessee i.e. whether he intends to obtain advance ruling in respect of a transaction already completed or proposed to be completed in future.

5. How many times can Form No. 120 be filed in a year?

Ans: Form No. 120 is transaction/event based and is only filed in case of an applicant intending to obtain advance ruling from the Board of Advance Rulings (BAR). There is no fixed annual frequency; it depends upon the number of transactions in respect of which an applicant wishes to obtain advance ruling. It is quite important to mention here that an applicant cannot file multiple Form No. 120 in respect of a single transaction.

6. What documents are required to file Form No. 120?

Ans: Proof of payment of application fee (challan, bank receipt, etc.).

  • PAN card copy (for residents and non-residents if allotted).
  • Taxpayer Identification Number (TIN) or equivalent for non-residents.
  • Certificate of incorporation/registration (company, trust, partnership, etc.).
  • Address and identity proof of applicant.
  • Proof of being Non-resident.
  • Details and documents regarding business/profession (Memorandum of Association, Partnership/Trust deed, etc.).
  • Question(s) relating to the transaction on which advance ruling is required.
  • Statement of relevant facts having a bearing on the question(s).
  • Statement of interpretation of law or facts.
  • Copies of relevant agreements/arrangements giving rise to transaction, if any.
  • Supporting documents for group structure/beneficial ownership (for non-residents).
  • Details of other parties to arrangement (Identity, PAN, Relation).
  • Document indicating Tax year(s) during which the tax benefit is likely to arise (give year wise break-up).
  • Any relevant assessment orders, appellate orders, or documents if proceedings/arbitrations are pending or decided.
  • Authorization letter/power of attorney if the application is filed by an authorized representative.
  • Any other document as required by the Board or mentioned in instructions relevant to the case.
  • The applicant shall, along with the attachment, provide an index of the documents uploaded with the description and corresponding page numbers.

7. Do I need to attach proof of fee payment?

Ans: Yes. Proof of fee payment (challans/BSR codes) is mandatory for filing of Form No. 120.

8. How and where is the fee paid?

Ans: The fee must be paid online through the Bharat Kosh portal, and the receipt must be attached with the application.

9. If I don’t have PAN and I have never been assessed to tax in India, can I still apply for an advance ruling before BAR?

Ans: Yes. If you do not have a PAN and have never been assessed to tax in India, you can still apply for an advance ruling before the Board for Advance Rulings (BAR). In such cases, the Department will allot a PAN after obtaining the required particulars from you.

10. While filling Part A, can I leave mobile number blank?

Ans: Mobile number ensures faster communication and verification; it is recommended to provide it.

11. What if I don’t upload requisite documents at the time of filing Form No. 120?

Ans: Your application for seeking advance ruling will be processed only when the requisite documents are submitted. If your application is found defective, the Secretary, BAR shall seek an explanation from you as to why the application may not be rejected and direct you to submit any relevant material or information in support of such application within such time as allowed by the BAR.

12. Can I file Form No. 120 after filing an appeal against the order of any Income Tax Authority, the Appellate Tribunal or any court?

Ans: No. Form No. 120 can only be filed in respect of question(s) or transaction(s) on which on which the advance ruling is sought, which is/are not pending before any Income Tax Authority, the Appellate Tribunal or any court.

13. Can Form No. 120 be filed offline?

Ans: No. Henceforth, Form No. 120 can only be submitted online through the Income Tax e-Filing Portal.

14. Can I edit Form No. 120 after submission?

Ans: No. Once Form No. 120 is submitted and acknowledgment is generated, it cannot be edited. Ensure all details are correct before submission.

15. What are common mistakes to avoid?

Ans: Following common mistakes should be avoided: -

  • Incomplete or unsigned forms
  • Missing Annexures or Proof of Fee Payment
  • Inadequate disclosure of Group Structure and Beneficial Ownership
  • Submitting from an unregistered Email ID.

16. Is advance ruling available only before entering into a transaction?

Ans: No. An advance ruling can be sought both before or after undertaking a transaction, as long as the issue is not pending before any income-tax authority, Tribunal, or Court (except for PSUs).

17. What type of questions can I ask in an advance ruling application?

Ans: You may ask questions of law, fact, or mixed questions directly relating to your tax liability, including:

  • DTAA interpretation
  • Permanent Establishment
  • Withholding tax
  • Taxability of services, royalties, fees
  • GAAR applicability

18. Can multiple questions be raised in one application?

Ans: Yes. Multiple questions may be raised, provided they arise from the same transaction/arrangement and are clearly framed.

19. Can advance rulings be sought for proposed or ongoing/completed transactions?

Ans: Yes. Advance rulings may be sought for transactions proposed or already undertaken, provided the question is not pending before any income-tax authority, Tribunal, or Court (subject to PSU relaxation).

20. Can I withdraw my advance ruling application?

Ans: Yes. An application may be withdrawn within 30 days from the date of filing.

21. I want to declare that no question(s) on which advance ruling is sought is pending before any Income Tax Authority, the Appellate Tribunal or any court. Where should this be mentioned?

Ans: This is mandatory part of the Verification Section of Form No. 120.

22. What happens if my application is found defective?

Ans: If the application is defective, the Secretary of the BAR will intimate the defects and grant a reasonable opportunity to rectify them. The application will be treated as filed only after defects are removed.

23. Will my application be rejected automatically if the tax department does not send records?

Ans: If the jurisdictional PCIT/CIT fails to furnish records, the BAR may still proceed to allow or reject the application without waiting for those records.

24. Is the applicant entitled to a hearing before rejection or final disposal?

Ans: Yes. Before rejection or final disposal, the applicant must be given a reasonable opportunity of being heard.

25. Can I modify or reframe questions after filing the application?

Ans: Normally, questions cannot be amended. However, in deserving cases, the BAR may permit modification or reframing of questions before the hearing.

26. What are the conditions which may cause my application to be summarily rejected?

Ans: Under section 384(3) of the Income Tax Act, 2025 certain restrictions have been imposed on the admissibility of the application. The BAR is bound to reject applications which raise the following three categories of questions.

  • The question is pending before any income-tax authority, Tribunal, or Court (except PSU relaxation);
  • It involves determination of fair market value of property; or
  • It relates to a transaction designed primarily for tax avoidance (other than GAAR rulings).

27. What are the legal consequences of a ruling (binding effect, appeal, voidness, limitation)?

Ans:

  • Binding effect: Binding on the applicant and jurisdictional income-tax authorities for the specific transaction.
  • Voidness: Can be declared void ab initio if obtained by fraud/misrepresentation.
  • Appeal: Appeal lies to the jurisdictional High Court within 60 days of communication.
  • Limitation: Pendency period before BAR is excluded while computing limitation for assessment/reassessment.

28. Can BAR ask for additional facts or documents later?

Ans: Yes. BAR may permit or require submission of additional facts, which must be duly verified.

29. Can the advance ruling be appealed?

Ans: Yes. Either the taxpayer or the Department may appeal to the High Court within 60 days of communication.

30. Is the time taken by BAR excluded from limitation periods?

Ans: Yes. The period during which the advance ruling application is pending is excluded while computing limitation periods for assessment.

31. Can an advance ruling be declared void later?

Ans: Yes. If the ruling is obtained by fraud or misrepresentation, BAR may declare it void ab initio.

32. Can the BAR amend or correct its own order?

Ans: Yes. The BAR may rectify mistakes apparent from the record, either on its own motion or on an application by the taxpayer or the Department, after giving an opportunity of being heard.

33. Is an advance ruling binding forever?

Ans: No. The ruling is binding only so long as there is no change in facts or law. Any material change can render the ruling inapplicable.

34. Can Public Sector Companies seek advance rulings despite pendency of proceedings?

Ans: Yes. Public Sector Companies are permitted to seek advance rulings even if proceedings are pending on the same or similar issues before income-tax authorities or appellate forums.

35. Is GAAR determination available to all categories of persons?

Ans: Yes. Any person (resident or non-resident) may seek an advance ruling on whether an arrangement constitutes an impermissible avoidance arrangement under GAAR.

36. What practical benefit does an advance ruling offer in cross-border transactions?

Ans: Advance rulings offer certainty on DTAA interpretation, withholding tax, PE exposure, and income characterization, enabling taxpayers to structure cross-border transactions confidently and compliantly.

37. Who can be an Authorized Representative?

Ans: An applicant’s authorized representative should fulfil the requirements spelt out in section 515(3)(a) of the Income Tax Act, 2025. The expression “authorized representative”, in relation to the PCIT/ CIT, means a person authorized by it in writing to appear, plead and act for it in any proceedings before the BAR.

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