Report from an accountant to be furnished under section 172 relating to international transaction(s) and/or specified domestic transaction(s)

Part A: Particulars of the Assessee

1.

Name:

(refer Note1)

2.

Address:

(refer Note 2)

3.

Permanent Account Number (PAN):

4.

Part B: Aggregate amount of transactions as per books of account (refer Note 3) <auto-populated>

International

Deemed International

Specified Domestic

Received

Paid

Received

Paid

Received

Paid

5. List of associated enterprises (AE) with whom the assessee has entered into international transactions

Sl.

No.

Identification of AE (AE.

ID.)

Name

Address

Country or

territory of residence

PAN/ TIN or

other unique identifier

Nature of relationship with the AE as referred to in Section 162(1)

1.

AE-1

<drop down>

(refer Note 4)

<drop down>

[Multiple options can be selected]

(refer Note 5)

6. List of persons with whom the assessee has entered into the deemed international transactions

Sl.

No.

Identification of

Person (Person ID)

Name

Address

Country or territory of residence

PAN/ TIN or other unique identifier

1.

P-1

<drop down>

(refer Note 4)

7. International transactions (To be provided for each international transaction type including deemed interna- tional transaction type)

Sl.No.

Transaction ID

Transaction

Type (refer Note 6)

AE

ID.

and/or

Person ID

Additional Infor-

mation (Refer Col-

umn B of Note 7)

[in respect of each AE or Person]

Transaction amount as per the books of account

Received

Paid

1.

T-1AE-1/P-1

Aggregate amount of transaction as per books of account

(Auto populated)

(Auto populated)

Amount of adjustment:

(Auto populated)

(Auto populated)

Arm‘s length price as computed in Part E:

(Auto populated)

(Auto populated)

2.

T-2 AE-1/P-1

(Repeat for each transaction ID)

8. Details of advance pricing agreement (APA)

i

.

Is the assessee signatory of any advance pricing agreement (APA):

Yes/No

If yes, please provide

(a)

Date of agreement

(b

)

Acknowledgement Number of application

(c)

Sl.

No.

Transaction ID covered under APA (Choose the transactions from the list of transaction IDs)

Total amount of the transaction

Amount of the transaction covered under APA

1.

 2.

9. List of AE with whom the assessee has entered into specified domestic transactions

Sl.

No.

Identification of AE (DAE ID.)

Name

Address

PAN

Nature of relationship with the AE as referred to in Section 162(2)

DAE-1

<drop down>

[Multiple options can be selected]

(refer Note 8)

10. Specified Domestic Transactions with AE (To be provided for each specified domestic transaction type for an AE)

Sl.

No.

Transaction ID

Transaction Type (refer Note 9)

DAE.ID

(Choose from the list

for which the data has been filled up in row 9)

Transaction amount as per the books of account

Received

Paid

1.

SDT-1DAE-1

Aggregate amount of transaction as per books of account:

(Auto populated)

(Auto populated)

Amount of adjustment:

(Auto populated)

(Auto populated)

Arm‘s length price as computed in Part E:

(Auto populated)

(Auto populated)

2.

SDT-2DAE-1

(Repeat for each transaction ID)

11. Determination ofarm’s length price (To be filled up after the Part C and/or D have been filled up for each transaction)

1

.

(i

)

Have any of the transaction been aggregated with other closely linked transaction(s) for determina- tion ofarm‘s length price

Yes/No

(a)

If yes in (i), the details of the transactions which have been aggregated

Sl

No

.

Transac-

tion ID

Total

Amou

nt (re-

fer

Note

10)

Amount

aggre-

gated

Amount

not-

aggre-

gated

<drop

down>

Choose

the trans- actions

from the

list of

transaction IDs

(b)

If No in (i), the details of the transaction (the details of all the transactions which are ei- ther not aggregated or partly aggregated are to be filled in separately for each transac- tion)

<drop down>

(Choose the transactions from the list of

transaction IDs)

Total

Amount

(refer Note 10)

(ii)

Most Appropriate Method u/s 165 (Select one op- tion from Note 11)

<drop down>

(iii)

RPM

CPM

TNM

M

CUP

PSM

Other

Method

(a)

(refer Note 12)

Number of

comparables

< drop down>

A: one

B: more

than one & less

than six

C: six or more

Details of

determina- tion of

arm‘s length price

Details of

determina- tion of

arm‘s length price

Number ofcompa- rable uncontrolled transac-

tions/enterprises used for determi- nation ofarm‘s length price

< drop down>

A: one

B: more

than one & less

than six

C: six or more

If case of “A”:

margin ofcompa- rable (%)

If case of “A”

Arm‘s

length

price

If case of “B”:

margin ofcompa- rables (%)

Arithme-

tic Mean

If case of “B”

Arithme-

tic Mean

If case of “C”:

margin ofcompa- rables (%)

Median

35th per- centile 65th per- centile

If case of “C”

Median

35th per- centile 65th per- centile

(b)

Arm‘s length price (refer Note 13)

Arm‘s length price (refer

Note 13)

Arm‘s length price (refer Note 13) $

(c)

Please fill the additional details (refer note 14)

Amount of adjustment (refer Note 13) $

(d)

Whether any

transaction, out of the transactions

chosen in (ii) (a),

has also been sepa- rately bench-

marked. (refer note 15)

Yes/No

2

.

(i)

Have any of the transaction, which are not includ- ed or partially included in 1(i)(a) above, been ag- gregated with other closely linked transaction(s) for determination ofarm‘s length price.

Yes/No

(a)

If yes, repeat 1(i)(a)

(b)

If no, repeat 1(i)(b)

3

.

(Repeat 2 till the reporting of aggregated transactions is completed)

Part- F(Documentation): To be opened only if the aggregate value of international transaction exceeds Rs. 1Cr.

Or if specified domestic transaction is reported

Whether the assessee satisfies the conditions mentioned for non- maintenance of fresh documents in the proviso to rule 84(4)?

Yes/No

If no, whether the assessee has kept and maintained the information and documents as prescribed under section 171?

Yes/No

Certification

I have examined the accounts and records of (name of the assessee) having (PAN) relating to the international transaction(s) and the specified domestic transaction(s) entered into by the assessee during the tax year ending on 31st March .

In my opinion proper information and documentation as are prescribed have been kept by the assessee in respect of the international transaction(s) and the specified domestic transaction(s) entered into so far as appears from my exam- ination of the records of the assessee.

The particulars required to be furnished under section 172 are mentioned in the above Form. In my opinion and to the best of my information and according to the explanation given to me, the particulars given in the Form are true and correct.

Signature:

Name of the accountant:

Membership No:

Name of the proprietorship/firm:

PAN of the proprietorship/firm:

Firm registration No:

UDIN, if any:

Place:

Date:

1

162(1)(a)(i)

2

162(1)(a)(ii)

3

162(1)(a)(iii)

4

162(1)(b)

5

162(1)(c)

6

162(1)(d)

7

162(1)(e)

8

162(1)(f)

9

162(1)(g)

10

162(1)(h)

11

162(1)(i)

12

162(1)(j)

13

162(1)(k)

14

162(1)(l)

Sl.

No.

Transaction Type

A

B

1

Purchase of raw material, consumables or any other supplies for assembling or processing or manufacturing of goods or articles.

2

Purchase of traded or finished goods.

3

Purchase of any tangible property including building, transportation vehicle, machinery, equipment, tools, plant, furniture, commodity or any other article, product or thing not covered in A 1 or A 2

4

Lease or use of any tangible property including building, transportation vehicle, machinery, equipment, tools, plant, furniture, commodity or any other article, product or thing

5

Sale of raw material, consumables or any other supplies for assembling or processing or manufacturing of goods or articles

6

Sale of traded or finished goods

7

Sale or transfer of any tangible property including building, transportation vehicle, machinery, equipment, tools, plant, furniture, commodity or any other article, product or thing not covered in A 5 or A 6

8

Lease or use of any tangible property including building, transportation vehicle, machinery, equipment, tools, plant, furniture, commodity or any other article, product or thing

9

(a)

Purchase of intangible property

(i)

the transfer of

ownership of

A marketing related intangible assets-

(i) trademarks

(ii) trade names

(iii) brand names

(iv) logos

(v) others (please specify)

B technology related intangible assets-

(i) process patents

(ii) patent applications

(iii) technical documentation such as laboratory note- books

(iv) technical know-how

(v) others (please specify)

C artistic related intangible assets-

(i) literary works and copyrights

(ii) musical compositions

(iii) copyrights

(iv) maps

(v) engravings

(vi) others (please specify)

D data processing related intangible assets-

(i) proprietary computer software

(ii) software copyrights

(iii) automated databases

(iv) integrated circuit masks and masters

(ii)

the provision of use of rights of

Sl.

No.

Transaction Type

A

B

(iii)

Others (please specify)

(v) others (please specify)

E engineering related intangible assets-

(i) industrial design

(ii) product patents

(iii) trade secrets

(iv) engineering drawing and schematics

(v) blueprints

(vi) proprietary documentation

(vii) others (please specify)

F customer related intangible assets-

(i) customer lists

(ii) customer contracts

(iii) customer relationship

(iv) open purchase orders

(v) others (please specify)

G contract related intangible assets-

(i) favourable supplier

(ii) contracts

(iii) licence agreements

(iv) franchise agreements

(v) non-compete agreements

(vi) others (please specify)

H human capital related intangible assets-

(i) trained and organised work force

(ii) employment agreements

(iii) union contracts

(iv) others (please specify)

I location related intangible assets-

(i) leasehold interest

(ii) mineral exploitation rights

(iii) easements

(iv) air rights

(v) water right

(vi) others (please specify)

J goodwill related intangible assets-

(i) institutional goodwill

(ii) professional practice goodwill

(iii) personal goodwill of professional

(iv) celebrity goodwill

(v) general business going concern value

(vi) others (please specify)

(b)

Lease or use of intangible property where the assessee is lessee or user

(c)

Sale or transfer of intan- gible property

(i)

the transfer of

ownership of

(ii)

the provision of use of rights of

(iii)

Others (please specify)

Sl.

No.

Transaction Type

A

B

(d)

Lease or use of intangible property where the AE is lessee or user

K other intangible properties-

(i) methods,

(ii) programmes,

(iii) systems,

(iv) procedures,

(v) campaigns,

(vi) surveys,

(vii) studies,

(viii) forecasts,

(ix) estimates,

(x) customer lists,

(xi) technical data

(xii) patents

(xiii) know-how

(xiv) commercial secret

(xv) marketing channel

(xvi) copyrights

(xvii) industrial property right

(xviii) land use

(xix) exterior design or practical and new design

L any other business or commercial rights of similar nature or any other similar item that derives its value from its intellectual content rather than its physical attributes (please specify)

10

(a)

Capital financing, borrowing of money,-

(i) short term loan

(ii) long term loan

(iii) guarantee

(iv) others (please specify)

(b)

Capital financing, borrowing of money- purchase of marketable securities

(c)

Capital financing, borrowing of money,-

(i) advances received,

(ii) deferred payment obligations,

(iii) any other debt obligation arising during the course of business (please specify)

11

(a)

Interest paid in respect of any transaction referred to in 10 above

(b)

Guarantee fee/commission paid in respect of transaction referred to in 10(a)(iii)

12

(a)

Capital financing, lending of money,-

(i) short term loan

(ii) long term loan

(iii) guarantee

(iv) others (please specify)

(b)

Capital financing, lending of money- sale of marketable securities

Sl.

No.

Transaction Type

A

B

(c)

Capital financing, lending of money,-

(i) advances granted,

(ii) deferred payment arrangements,

(iii) any other debt claim arising during the course of business (please specify)

13

(a)

Interest received in respect of any transaction referred to in 12 above

(b)

Guarantee fee/commission received in respect of transaction referred to in 12(a)(iii)

14

Provision of services to AE-

(a) market re- search

(b) market

development

(c) marketing management

(d) administra- tion

(e) agency

(f) technical

service ***

(i) Software development services

(ii) Information technology enabled services

(iii) Knowledge process outsourcing services

(iv) Any other technical services

(g) repairs

(h) design

(i) scientific

research***

(A) Contract

(i)Contract research and develop-

ment services wholly or partly relat- ing to the software development

(ii)Contract research and develop-

ment services wholly or partly relat- ing to generic pharmaceutical drugs

(iii)Other contractual research (please specify)

(B) Others (please specify)

(j) consultation

(k) legal

(l) accounting service

(m) others

(please specify)

*** For the services as mentioned in column (f)(i) to (f)(iii), and in column (i)A(i) to (i)(A)(ii), the services are as defined in rule 86.

15

Provision of services from AE-

(a) market research

(b) market development

(c) marketing management

(d) administration

(e) technical service

(f) repairs

(g) design

(h) consultation

(i) agency

(j) scientific research

(k) legal

(l) accounting service

(m) others (please specify)

16

A transaction of business restructuring or reorganisation, entered into by an enterprise with an associated enter- prise, irrespective of the fact that it has any bearing on the profit, income, losses or assets of such enterprises at the time of the transaction or at any future date.

17

Mutual agreement or arrangement between two or more AEs for-

(a) the allocation or apportionment of any cost or expense incurred or to be incurred in connection with a benefit, service or facility provided or to be provided to any one or more of such enterprises, or

(b) any contribution to any cost or expense incurred or to be incurred in connection with a benefit, service or facility provided or to be provided to any one or more of such enterprises.

18

Any other transaction between two or more AEs having a bearing on the profits, income, losses or assets of such

enterprises (please specify)- (a) …

Sl. No.

Additional Information to be provided

A

B

9 (a)(ii),

9(a)(iii), 9(b)

Date of royalty agree- ment

Rate of Royalty

Amount of royalty paid/payable

9(c)(ii), 9(c)(iii),

9(d)

Date of royalty agree- ment

Rate of Royalty

Amount of royalty received/receivable

10 (a)(i),

10(a)(ii), a(iv)

Nature offinanc- ing agreement

Quantum

of transac- tion

Currency in which transaction has tak- en place

Interest rate in re- spect of each bor- rowing

Interest paid or payable

10(a)(iii)

Total amount of the guarantee

Rate of corporate guar- antee commission or

fee charged

Currency in which the transaction was under- taken for which guar- antee was granted

Amount of corporate guar- antee commission or fee

charged

12(a)(i),

12(a)(ii),

12(a)(iv)

Nature of fi-

nancing agree- ment

Quantum

of transac- tion

Currency in which transaction has

taken place

Interest rate in re- spect of each lend- ing

Interest received or receivable

12(a)(iii)

Total amount of the guarantee

Rate of corporate guar- antee commission or fee charged

Currency in which

the transaction was

undertaken for which guarantee was grant- ed

Amount of corporate guar- antee commission or fee

charged

16

Nature of trans- action (please

specify)

Title of agreement

Date of agreement

Terms of restructuring/re- organization

Whether is there any impact on profits, income, loss or assets? Yes/ No. If yes, please specify.

1

162(2)(a)

2

162(2)(b)

3

162(2)(c)

Sl. No.

Transaction Type

A

B

1

Any transaction referred to in section 122

A

Transfer of goods to any other business of the assessee

B

Transfer of services to any other business of the assessee

C

Acquisition of goods from any other business of the as- sessee

D

Acquisition of services from any other business of the as- sessee

2

Any transfer of goods or services referred to in section 140(9)

A

Transfer of goods to any other business of the assessee

B

Transfer of services to any other business of the assessee

C

Acquisition of goods from any other business of the as- sessee

D

Acquisition of services from any other business of the as- sessee

3

Any business transacted between the assessee and any other person as referred to in section 140(13)

4

Any transaction, referred to in any

other section under Chapter VIII or

section 144, to which section 140(9) or 140(13) of the Income-tax Act,

2025 (30 of 2025) applies, or to

which section 80-IA(8) or 80-IA(10) of the Income-tax Act, 1961 (43 of

1961) (as it existed prior to its repeal) applies.

A

Transfer of goods to any other business of the assessee

B

Transfer of services to any other business of the assessee

C

Acquisition of goods from any other business of the as- sessee

D

Acquisition of services from any other business of the as- sessee

E

Any other transaction (please specify)

5

Any business transacted between the persons referred to in section 205(4).

A

Transfer of goods by the assessee

B

Transfer of services by the assessee

C

Acquisition of goods by the assessee

D

Acquisition of services by the assessee

E

Any other transaction (please specify)

Code

Transfer Pricing Method

A

B

CUP

Comparable Uncontrolled Price Method

RPM

Resale Price Method

CPM

Cost Plus Method

PSM

Profit Split Method

TNMM

Transactional Net Margin Method

OTM

Other Method

Code

Computation

A

B

RPM

Particulars

(i)

Total resale price as per books of accounts (₹)

A

(ii)

Amount of gross profit margin for the comparable un- controlled transactions (before adjustment) (₹)

(iii)

Rate of gross profit margin for the comparable uncon- trolled transactions (before adjustme t) (%)

C

(iv)

Expenses incurred in connection with the purchase of property or obtaining of services (₹)

D

(v)

Price at which property purchased or services obtained for the comparable uncontrolled transactions (₹)

E= A-B-D

(vi)

Details of adjustme t made, if any.

Amount (₹)

F

Description

(vii)

Amount of gross profit margin for the comparable un- controlled transactions (after adjustment) (₹)

G= B +/- F

(viii)

Rate of gross profit margin for the comparable uncon- trolled transactions (%) (after adjustment)

H

(ix)

Price at which property purchased or services obtained for the comparable uncontrolled transactions (after ad- justment) (arm‘s length price) (₹)

I= A-G-D

(x)

Price at which property purchased or services obtained as per the books of account (₹)

J

(xi)

Is there any adjustment required in the price at which the international transaction or specified domestic transac-

tion has actually been undertaken in accordance with the provisions of section 165 of the Act?

Yes/No

(a)

If yes, amount of adjustment (₹)@

(b)

If no,

No adjustment

CPM

Particulars

(i)

The direct and indirect costs of production incurred, in re- spect of property transferred or services provided, as per books of accounts (₹)

A

(ii)

Amount of gross profit mark-up for the comparable uncon- trolled transactions (before adjustment) (₹)

B

(iii)

Rate of gross profit mark-up for the comparable uncon- trolled transactions (befor adjustment) (%)

C

(iv)

The costs as increased by the gross profit mark-up for the comparable uncontrolled transactions (before adjustment) (₹)

D= A+B

(v)

Details of adjustment made, if any

Amount (₹)

E

Description

(vi)

Amount of gross profit mark-up for the comparable uncon- trolled transactions (after adjustment) (₹)

F= B+/-E

(vii)

Rate of gross profit mark-up for the comparable uncon- trolled transactions (after adjustment) (%)

G

(viii)

The costs as increased by the gross profit mark-up for the comparable uncontrolled transactions (after adjustment) (arm‘s length price) (₹)

H= A+F

(ix

The revenue earned, in respect of property transferred or services provided, as per the books of account (₹)

I

(x)

Is there any adjustment required in the price at which the international transaction or specified domestic transaction has actually been undertaken in accordance with the provi- sions of section 165 of the Act?

Yes/No

(a)

If yes, amount of adjustment (₹)@

(b)

If no,

No adjustment

TNMM

articulars

(i)

Net profit margin in relation to

<drop down>

(Select one from the following options:

1. costs incurred

2. sales effected

3. assets employed or to be employed

4. any other relevant base (please specify))

(ii)

Amount of the base as per books of account (₹)

A

(iii)

Rate of net profit margin realized as per books of account (%)

B

(iv)

Amount of net profit margin realized as per books of account (₹)

C= A*B/100

(v)

Rate of net profit margin for the comparable uncontrolled transactions (before adjustm nt) (%)

D

(vi)

Details of adjustment made, if any

Amount (%)

E

Description

(vii)

Rate of net profit margin for the comparable uncontrolled transactions (after adjustment) (%)

F= D+/-E

(viii)

Arm‘s length price for the comparable uncon- trolled transactions (after adjustment) (₹)

G= A*F/100

(ix)

Is there any adjustment required in the price at which the international transaction or spec- ified domestic transaction has actually been

undertaken in accordance with the provisions of section 165 of th Act?

Yes/No

(a)

If yes, amount of adjustment (₹)@

(b)

If no,

No adjustment

CUP

Particula s

(i)

The price charged or paid for property transferred or services provided, as per books of accounts (₹)

A

(ii)

The price charged or paid for property transferred or services provided in comparable uncontrolled transaction(s) (before adjustment) (₹)

B

(iii)

Details of adjustment made, if any

Amount (₹)

C

Description

(iv)

The price charged or paid for property trans-

ferred or services provided in comparable uncon- trolled transaction(s) (after adjustment) (arm‘s

length price) (₹)

D= B+/-C

( )

Is there any adjustment required in the price at

which the international transaction or specified

domestic transaction has actually been undertaken in acc rdance with the provisions of section 165 of the Act?

Yes/No

(a)

If yes, amount of adjustment (₹)@

(b)

If no,

No adjustment

A.

Details regarding certain expenses

Sl. No.

Nature of expense

Amount record- ed in the books of account

Amount

not rec-

orded in the

books of

account

Total

amount of ex-

pense

The amount

out of total

expenses in Column C included in

the compu- tation of

arm‘s

length price

The amount of total expenses in column C not

included in the computation of arm‘s length

price

A

B

C= A+B

D

E

(i)

Stock compensation or any other bonus/ incentive paid by

the assessee or its AE to the employ- ees ofthe assessee

(ii)

Cost and/or depreci- ation of assets,

software, tools, li-

censes, or databases provided by the AE including third-party software, databases, licenses, and other

assets or tools as

well as those devel- oped in-house by

the AE

(iii)

Cost incurred by the AE towards travel

and other expenses ofthe employees of the assessee in con- nection with work, training, or other

business purpose of the assessee outside India

(iv)

Training expenses incurred by AEs for employees of the

assessee, or man-

agement, consultan- cy, or other services provided by AE

(v)

All cost incurred by the AE on the em-

ployees second-

ed/transferred by the AE to the assessee

(vi)

All cost relating to

outsourcing incurred by the assessee

and/or AE

(vii)

Any other expense incurred by the AE but utilized in the business operations of the assessee

(please specify)

B.

Details regarding revenue

Sl

No.

Nature of revenue

Total amount of revenue

The amount out of total revenue in Column A

included in the computa- tion of arm‘s length price

The amount of total rev- enue in column A not

included in the computa- tion of arm‘s length price

A

B

C

(i)

Income arising on

account of foreign

currency fluctuations

(ii)

Assistance in the

form of a subsidy or grant or cash incen-

tive or duty drawback or waiver or conces- sion or reimburse-

ment (by whatever

name called) by the Central Government or a State Govern-

ment or any authority or body or agency in cash or kind to the

assessee.