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India: Draft rules updating transfer pricing reporting, advance pricing agreement (APA) program, block transfer pricing assessments

Comments due by February 22, 2026

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February 12, 2026

The Central Board of Direct Taxes (CBDT) released the draft income tax rules, 2026 along with the proposed forms, in relation to the Income tax Act, 2025, which is scheduled to become effective on April 1, 2026.

The draft rules propose significant amendments to the safe harbor regime for transfer pricing (read TaxNewsFlash), as well as (1) replacing transfer pricing reporting Form 3CEB with a new Form 48 requiring significant new disclosures, (2) changes to the advance pricing agreement (APA) program in line with the Budget 2026-2027 proposal to fast-track unilateral APAs, and (3) rules for “block transfer pricing assessments” covering multiple years in a single proceeding.

Comments on the draft rules and forms are due by February 22, 2026.

Read a February 2026 report prepared by the KPMG member firm in India

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