Form 48 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 48 is the report from an accountant required under section 172 of the Income-tax Act, 2025 from every person who has entered into an international transaction or a specified domestic transaction in a tax year. This article describes the form as printed, as per 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, including the corrigendum G.S.R. 286(E), which corrects the wording of cells in the method tables. Later notifications should be checked.
Rule 85 requires the report in Form 48, from an accountant as defined in section 515(3)(b), at least one month before the due date of the return under section 263(1)(c). Part A identifies the assessee, Part B shows aggregate amounts, Part C lists associated enterprises and international transactions, Part D the specified domestic transactions, a block (printed as row 11) computes the arm's length price by method, and Part F asks about documentation.
The rule and the section
Rule 85(1) says the report required under section 172 shall be in Form 48 and verified as indicated in it; rule 85(2) requires it to be furnished at least one month before the due date of furnishing the return of income as per section 263(1)(c). The rule is explained in rule 85 on the accountant's report in Form 48; the section in sections 171 to 173 on transfer pricing documents, the accountant's report and definitions. The arm's length price methods are in section 165 on arm's length price.
The form is headed "Report from an accountant to be furnished under section 172 relating to international transaction(s) and/or specified domestic transaction(s)", with the reference "". The Part letters are not printed in sequence: row 4 is headed "Part B", the block for the arm's length price (row 11) carries no Part heading but is called Part E in the rows and Notes, and the last Part is headed "Part F". This article follows the print. If you are preparing the transfer pricing file behind the report, our tax planning advisory team can help with the documentation and the timeline.
Parts A and B
| Part and row | What is asked |
|---|---|
| Part A, rows 1 to 3 | Name (Note 1), address (Note 2), Permanent Account Number |
| Part B, row 4 | Aggregate amount of transactions as per books of account (auto-populated per the form), received and paid, for three groups: international, deemed international and specified domestic (Note 3: "paid" includes payable and "received" includes receivable) |
Part C: international transactions, including deemed international transactions
| Row | What is asked |
|---|---|
| 5 | List of associated enterprises with whom international transactions were entered into: identification (AE-1 etc.), name, address, country or territory of residence, PAN, TIN or other unique identifier (Note 4), and nature of relationship as referred to in section 162(1) (more than one may be selected; Note 5 lists fourteen clauses) |
| 6 | List of persons with whom deemed international transactions were entered into: person ID, name, address, country or territory, identifier |
| 7 | International transactions, for each transaction type: transaction ID, transaction type (Note 6), associated enterprise or person ID, additional information (Note 7), and the amount as per books received and paid; below each, the aggregate amount, the amount of adjustment and the arm's length price as computed in Part E, auto-populated; repeated for each transaction ID |
| 8 | Advance pricing agreement: whether the assessee is signatory to one (Yes/No) and, if yes, date of agreement, acknowledgement number of the application, and a table of the transactions covered, with total amount and amount covered |
Part D: specified domestic transactions
| Row | What is asked |
|---|---|
| 9 | List of associated enterprises with whom specified domestic transactions were entered into: identification (DAE-1 etc.), name, address, PAN, nature of relationship as referred to in section 162(2) (Note 8: clauses (a), (b) and (c)) |
| 10 | Specified domestic transactions with the associated enterprise: transaction ID (SDT-1 etc.), type (Note 9), enterprise ID, and amounts received and paid; with the same auto-populated aggregate, adjustment and arm's length price lines |
The arm's length price block (row 11)
Row 11 is to be filled after Parts C and D, for each transaction.
| Item | What is asked |
|---|---|
| 1(i) | Whether any transaction has been aggregated with other closely linked transactions for determining the arm's length price (Yes/No); if yes, a table of the aggregated transactions (transaction ID, total amount, amount aggregated, amount not aggregated; Note 10); if no, the transaction's details |
| 1(ii) | Most appropriate method under section 165, selected from Note 11 |
| 1(iii)(a) | Under each method (RPM, CPM, TNMM, CUP, PSM, other method): the number of comparables used, in bands of one, more than one and fewer than six (arithmetic mean) and six or more (median, 35th and 65th percentile); margin per Note 12 |
| 1(iii)(b) and (c) | Arm's length price (Note 13) and the amount of adjustment; additional details (Note 14) |
| 1(iii)(d) | Whether any transaction chosen has also been separately benchmarked (Note 15) |
| 2 and 3 | Repeat for transactions not included, or partly included, until the reporting of aggregated transactions is complete |
For transactions benchmarked by the profit split method or another method, the arm's length price and amount of adjustment are provided in Part E (note marked with a dollar sign).
Part F: documentation
The Part is headed "to be opened only if the aggregate value of international transaction exceeds Rs. 1Cr. or if specified domestic transaction is reported". It asks (1) whether the assessee satisfies the conditions in the proviso to rule 84(4) for non-maintenance of fresh documents (Yes/No) and (2) if no, whether the assessee has kept and maintained the information and documents prescribed under section 171 (Yes/No). The documentation rules are in rule 84.
Certification and signatory
The accountant states that he has examined the accounts and records of the named assessee relating to the transactions entered into in the tax year; that in his opinion proper information and documentation as prescribed have been kept so far as appears from his examination; and that the particulars under section 172 are, as far as he knows and believes, true and correct. The block carries signature, name, membership number, firm name and PAN, firm registration number, UDIN if any, place and date.
The Notes
| Note | Content |
|---|---|
| 1 to 5 | Name; address; meaning of "paid" and "received"; PAN or TIN or unique identifier for the associated enterprise; list of relationships under section 162(1) |
| 6 | Eighteen types of international transaction: purchases and sales of goods and tangible property; lease or use of tangible and intangible property (a long list of intangible kinds); capital financing by borrowing and lending, with interest and guarantee commission; services to and from an associated enterprise; business restructuring; cost allocation arrangements; and any other transaction having a bearing on profits, income, losses or assets |
| 7 | Additional information by type: royalty agreement date, rate and amount; financing nature, quantum, currency and interest; guarantee amount and commission; restructuring title, date and terms |
| 8 and 9 | Relationships under section 162(2); five types of specified domestic transaction |
| 10 to 12 | Unaggregated balance; method codes (CUP, RPM, CPM, PSM, TNMM, OTM); how margin is read |
| 13 to 15 | Computation blocks by method; additional details of expenses and revenue (amount recorded, amount included in and not included in the arm's length price); separate benchmarking in Part E |
The Note 13 blocks set out, method by method, lettered lines and formulas for the arm's length price: for the resale price method I = A - G - D; for the cost plus method H = A + F; for the transactional net margin method G = A x F / 100; and for the comparable uncontrolled price method D = B +/- C. Each block ends by asking whether any adjustment is required to the price under section 165 (Yes/No), and the amount, or "No adjustment". For an international transaction in the nature of expense the adjustment is reduced from the book value, and for income it is added; for a specified domestic transaction it is the reverse.
Example. Sapphire Components Private Limited (invented) has purchased goods from an overseas associated enterprise. It lists the enterprise in row 5, records the transaction in row 7, benchmarks it in row 11 and answers the documentation question in Part F.
Need help with the transfer pricing report?
The report depends on documentation kept through the year and on the benchmarking behind each row. Our tax planning advisory team can help you prepare for the report and its one-month-before timeline.
Key takeaways
- Form 48 is the accountant's report under section 172, named by rule 85.
- It is furnished at least one month before the due date under section 263(1)(c).
- Parts C and D list associated enterprises and transactions; row 11 benchmarks each transaction by method.
- Part F opens only if international transactions exceed the printed limit or a specified domestic transaction is reported.
- The Part letters are printed out of sequence; this article follows the print.
Read next
- Rule 85: accountant's report in Form 48
- Form 49: application for opting for safe harbour
- Rule 86: safe harbour definitions
- Form 44: foreign tax credit statement
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 2 October 2026. It explains the words of the rules and forms 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.