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Form No. 46

Exercise of option for determination of arm‘s length price (ALP) under section 166(9)

Prescribed under rule 82(1) · Rule 82

Part A: Particulars ofthe Person

1.

Name:

(refer Note 1)

2.

Address:

(refer Note 2)

3.

Permanent Account Number (PAN):

4.

E-mail Id:

5.

Contact Number:

Country

Code

Number

Part B: Other Information

6

.

Tax year (TY) for which reference has been made under section 166(1) by the Assessing Officer:

7

.

Details of Return of income (ITR) and Form No. 48:

Sl.

No.

Tax Year (TY) and

second tax year (TY+1)

Date of

furnishing of

ITR

Acknowledgment Number ofthe ITR

Date of

furnishing of

Form No. 48

Acknowledgment Number of the Form No. 48

1.

TY

2.

TY + 1

8

.

Details of the transactions for which determination of ALP is to be carried out as per section 166(9):

S

l.

N

o.

Name

of the

Associ

ated

Enterp

rise

(AE)

AE‘s

Taxpay

er

Identifi

cation

Numbe

r or its

equival

ent in

the

country

/region

of

locatio

n

Add

ress

Nature

of

transac

tion

TY

TY + 1

TY + 2

Total amount

paid/

received or

payable/

receivable in

the

transaction

Meth

od

used

to

deter

mine

ALP

Total amount

paid/

received or

payable/

receivable in

the

transaction

Metho

d used

to

deter

mine

ALP

Total amount

paid/

received or

payable/

receivable in

the

transaction

Meth

od

used

to

deter

mine

ALP

As

per

boo

ks

of

acc

oun

t

As per

ALP

determ

ined

As

per

boo

ks

of

acc

oun

t

As per

ALP

determ

ined

As

per

book

s of

acco

unt

As

per

ALP

deter

mine

d

1.

2.

(Repea

t, if

requir

ed)

Certification

I hereby agree to the determination of ALP as per the provisions of section 166(9) for the tax years < Prefill> , < Prefill> and < Prefill> [TY, TY+1 and TY+2].

I also certify the following:

●There has not been any material change in the analysis of the transaction(s) in respect of functions performed, taking into account assets employed and the risks assumed, in the table above for TY, TY+1 and TY+2.

●There has not been any material change in the business result or holding structure of the Associated Enterprise, or change in the Associated Enterprise in the table above during TY, TY+1 and TY+2 which impact the transactions or the functions performed, taking into account assets employed and the risks assumed.

●None of the Associated Enterprises in the table above is a resident of a jurisdiction which has been notified un- der section 176.

●There has not been any change in the contractual terms relevant to the transactions in the table above during TY, TY+1 and TY+2.

●Further, I declare that I will furnish the return of income as well as Form No. 48 for the tax year ______ [TY+2] by the due date as given in section 263(1) and section 172 respectively.

I declare that I have examined the information contained in this information, including the accompanying documents, and to the best of my knowledge and belief, the facts presented within this report and accompanying documents are true, comprehensive, and accurate.

Place: Signature:

Date: Name:

Notes:

1. The name shall include full name of the person.

2. The address shall include flat/door/building, road/street/block/sector, area/locality, post office, town/city/district, state, country and pin code.

3. Where the region is a specified territory, the same may be mentioned.

4. Some of the information in the form would be pre-filled to the extent possible.

5. The amount mentioned in this form is to be filled in rupees unless stated otherwise.

Source: Income-tax Rules, 2026, Appendix III – notified by the CBDT vide G.S.R. 198(E) dated 20 March 2026. Reproduced for reference; the layout of the official Gazette form may differ slightly. Please verify with the official notification.

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