Form explained: this guide covers what it means, who it applies to, the step-by-step process, documents required, fees, due dates and penalties in India — so you can stay compliant with confidence and avoid costly mistakes.
Form No. 120 is the application to the Board for Advance Rulings: the applicant states the question, the facts and its own view, pays the fee, and gives group and transaction details. It is used by non-resident applicants and by resident applicants in the cases the Act allows. This guide explains the form as printed in the Income-tax Rules, 2026 (G.S.R. 198(E), notified on 20 March 2026), read with the amending notifications issued up to 22 September 2026.
Under rule 200(1), an application for an advance ruling under section 383(1) is made by a resident or a non-resident applicant in Form No. 120 and verified in the manner indicated in it. The fee follows the Table in rule 200(2) and depends on the category and the amount of the transaction; proof of payment must go with the application (rule 200(4)). The application and its annexures are furnished electronically and signed or digitally signed as sub-rule (3) says. The form and rule print no time limit for making the application.
The section and the rule
Section 383 of the Income-tax Act, 2025 allows an applicant who wants an advance ruling to apply in the prescribed form and manner, stating the question, with the prescribed fee. The applicant may withdraw the application within thirty days from the date of the application. Section 380 defines "advance ruling" to include determinations on a transaction by a non-resident, on a non-resident's tax liability arising from a transaction with a resident, on the tax liability of a resident, on an issue about computation of total income pending before an authority or the Tribunal, and on whether an arrangement is an impermissible avoidance arrangement under Chapter XI. The sections are explained in sections 380 to 384.
Rule 200 is covered in rule 200 on the advance ruling application and fees. Its sub-rule (3) says that where the applicant must file a return of income, the application and papers are signed or digitally signed by the person authorised to verify the return under section 265, using a digital signature if the return needs one, or an electronic verification code otherwise; where the applicant does not have to file a return, a person duly authorised and holding a valid power of attorney signs. After the ruling, certified copies are dealt with in rules 201 and 202.
If you are considering an advance ruling for a cross-border transaction or an arrangement, our legal consultation service can help you frame the question and the supporting statements.
The fee Table in rule 200(2)
The Table is printed wrapped in the text, so the amounts are read with its categories.
| Category in column B | Amount of transaction | Fee |
|---|---|---|
| 1. Advance ruling on tax liability from a transaction undertaken or proposed by a non-resident applicant (section 380(a)(i)) or a resident applicant (section 380(a)(ii)) | Less than one hundred crore rupees | ₹200000 |
| Between one hundred crore rupees and three hundred crore rupees | ₹500000 | |
| More than three hundred crore rupees | Ten lakh rupees | |
| 2. Advance ruling on the tax liability of a resident applicant from a transaction by a resident applicant (section 380(a)(iii)) | Between one hundred crore rupees and three hundred crore rupees | ₹500000 |
| More than three hundred crore rupees | Ten lakh rupees | |
| 3. Any other applicant | In all cases | ₹10000 |
The text consulted prints no band below one hundred crore rupees for category 2, and this article gives no fee for it.
What the form asks
| Part | Rows | What it asks |
|---|---|---|
| A: Basic Information | 1 to 11 | Name; PAN if any (mandatory only for resident individuals, Note 2); status (eleven options in Note 3, from individual to limited liability partnership); for an individual without PAN, gender, name of father or husband and date of birth; address; contact details; country of residence or citizenship; date of incorporation; authorised representative in India; jurisdictional Assessing Officer if no PAN; business of the applicant as per the Memorandum of Association, partnership deed or trust deed, with a copy |
| B: Purpose of application | 12 to 16 | Residential status; the Double Taxation Avoidance Agreement involved; for a non-resident, the basis of the claim to be non-resident (a up to 200 words) with proof; the subject of the ruling, chosen from the five options in Note 5; the questions (upload), a brief summary of the questions asked and the relevant sections of the Act (each a up to 200 words) |
| C: Specific Details and Annexures | 17 to 27 | The relevant facts (upload); the applicant's interpretation of law or facts (upload); relevant agreements, copies and period covered; fee payment details; non-resident parties, group structure, shareholding, immediate and ultimate parent and beneficial owners; amount of transaction and tax years; same or similar issues decided in the applicant's case; proceedings on the same or similar transaction pending before the Board for Advance Rulings; consent to anonymised publication; the arrangement details for a Chapter XI question; the assessment and appeal details for a notified resident applicant's pending computation issue |
The five options in row 15
Note 5 lists the five choices, which match section 380: a transaction undertaken or proposed by a non-resident applicant; the tax liability of a non-resident arising from a transaction by a resident applicant with such non-resident; the tax liability of a resident applicant from a transaction with a resident; an issue on computation of total income of a notified resident applicant that is pending before an income-tax authority or the Tribunal; and an arrangement, by a resident or non-resident, to be tested against Chapter XI as an impermissible avoidance arrangement.
Specific rows worth noting
Row 21 collects group structure: total non-resident parties including the applicant, a tree-format group chart (Note 7), and for each party the name, PAN, status, taxpayer identification number, address, country and shareholding percentage, then the immediate parent, ultimate parent and beneficial owners. Note 8 refers to beneficial ownership rules under other laws, namely the Companies (Significant Beneficial Owners) Rules, 2018 and the Prevention of Money Laundering (Maintenance of Record) Rules, 2005; read those laws separately.
Row 23 asks whether the same or similar issues were decided in the applicant's case by a tax authority, Tribunal or court, and row 24 whether proceedings are pending before a Board for Advance Rulings on the same or similar transaction, giving the Board (I, II or III), application number, dates and status. Row 26 applies to a Chapter XI question: the arrangement, its purposes, other parties and the tax benefit. Row 27 applies to a notified resident applicant's pending computation issue and records the assessment order and appeal details.
Note 6 requires an index of uploaded documents with descriptions and page numbers. Note 7 says the group structure chart is not applicable to a resident applicant covered under notification no. 73/2014 dated 28.11.2014 or a resident notified public sector undertaking covered under notification no. 11456/2000 dated 03.08.2000; those notifications are not in the text consulted. Note 9 says that where the form is furnished by a person in column B of the section 265 Table, it is verified and signed by the person in column C against that entry.
Verification
The signatory, giving name, relationship, PAN and entity, solemnly declares that what is stated in the form, annexures and accompanying documents is correct and complete to the signatory's knowledge and belief, that the application is made in the stated capacity with competence to make and verify it, and that the questions on which the ruling is sought are not pending or are pending (as applicable) before any income-tax authority, the Appellate Tribunal or any court.
An example
Kestrel Marine Services Pte Ltd, a non-resident, plans a contract with an Indian company and wants a ruling on its tax liability. It selects "Non-Resident" in row 12, gives the basis in row 14, selects the first option in row 15, uploads its questions, facts and interpretation, and attaches the contract in row 19. Because the transaction is below one hundred crore rupees, the fee in category 1 of the Table is ₹200000, and it records the challan in row 20. It uploads the group chart for row 21 and, as it consents to anonymised publication, answers Yes in row 25.
Need help with an advance ruling application?
The application turns on how the question is framed and how fully the facts and the applicant's view are stated. Our legal consultation team can help you assess whether a ruling is the right route, prepare the annexures and check the fee category.
Key takeaways
- Form No. 120 is the application for an advance ruling under section 383(1), made under rule 200.
- The fee is set by the rule 200(2) Table by category and amount of transaction.
- Part B fixes the purpose, including whether the question concerns a non-resident, a resident, a pending computation issue or a Chapter XI arrangement.
- Part C collects the facts, the applicant's view, agreements, fee proof, group details and related proceedings.
- The application is furnished electronically and signed as rule 200(3) says.
Read next
- Rule 200: advance ruling application, Form No. 120 and fees
- Rules 201 and 202: certified advance ruling and appeal to the High Court
- Form No. 129: application to determine the taxable portion of a payment to a non-resident
- Form No. 119: application to the Dispute Resolution Committee
Disclaimer: Based on the Income-tax Rules, 2026 (G.S.R. 198(E), notified on 20 March 2026), read with the amending notifications issued up to 22 September 2026, as consulted on 4 October 2026. It explains the words of the forms and rules only; later notifications, the forms and utilities on the e-filing portal, circulars and the way the tax authorities apply these provisions should be checked. This article is general information, not legal advice; check the official text before acting.