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.
Once an Advance Pricing Agreement is signed, the assessee must report each year how it complied with it; that report is Form No. 52. When the agreement is about to end, Form No. 54 is the application to renew it. This guide explains both 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. Form No. 53 is another subject and is not covered here.
Under rule 113, the assessee furnishes Form No. 52 to the Principal Chief Commissioner of Income-tax (International Taxation) for each year covered in the agreement, within thirty days of the due date of filing the income-tax return for that year, or within ninety days of entering into the agreement, whichever is later. Under rule 119, a renewal is requested as a new application in Form No. 54, using the same procedure except the pre-filing consultation.
The section and the rules
An Advance Pricing Agreement under section 168 of the Income-tax Act, 2025 determines the arm's length price, or the manner of determining it, for the covered international transactions, and is valid for the period specified in it, not exceeding five consecutive tax years. The sections on safe harbour rules and the agreement are explained in sections 167 to 169. The application stage, including the first Form No. 51, is in Form Nos. 50 and 51.
Rule 113 has four sub-rules. The assessee furnishes the report to the Principal Chief Commissioner of Income-tax (International Taxation) for each year covered in the agreement (sub-rule (1)); the report is in Form No. 52 (sub-rule (2)); the time limit is as quoted above (sub-rule (3)); and the Principal Chief Commissioner sends one copy each to the competent authority of India, to the Commissioner with jurisdiction over the assessment, and to the Transfer Pricing Officer with jurisdiction (sub-rule (4)). The compliance audit and later rules are in rules 113 to 117; renewal belongs with rules 110 to 112, 119 and 120.
If you hold an agreement and want the yearly report checked against its critical assumptions, our tax planning advisory team can review the working before it is filed.
Form No. 52: the annual compliance report
| Part | Rows | What it asks |
|---|---|---|
| A: Particulars of the Person | 1 to 7 | Name, address, PAN, email ID, contact number, authorised representative, and the tax year |
| B: Other Details | 8 | Acknowledgement number of the APA application |
| B | 9 | For each type of covered international transaction, the adjustment required as per Annexure A-1 and the amount of adjustment made in the return of income |
| B | 10 | Other details as a separate annexure |
The Notes say the report is filed for every year covered in the agreement and that a separate report is filed for each year (Note 5); that the information on a covered transaction is furnished for each covered transaction separately (Note 6); and that all documents agreed upon in the agreement to justify the transfer pricing methodology and the computation of the arm's length price are attached (Note 7). The verification affirms that the information is true and correct as far as the signatory knows and that no relevant fact has been concealed, and the signatory states the designation and PAN and that he or she is competent to verify and submit.
The annexures
| Annexure | What it asks |
|---|---|
| A-1 (1) | Computation of adjustment where the operating profit margin on operating expense is the profit level indicator: operating expense as per books, additions and deductions required by the agreement (items listed separately), operating revenue likewise, operating profit as per the agreement and as per books, operating profit margin in each case, the variance, and the amount of adjustment required |
| A-1 (2) | The same computation where the operating profit margin on operating revenue is the profit level indicator |
| A-1 (3) | Other cases based on amounts paid or payable or received or receivable: value of the transaction as per books, as per the agreement, and the adjustment |
| A-2 | Critical assumptions as per the agreement, each answered yes or no with details if not complied with |
| A-3 | Whether the documentation referred to in the agreement has been maintained and furnished |
Where two or more transactions are aggregated, the form says the total adjustment may be shown against one of them and the others shown as Nil if no adjustment is required under a secondary check or other check in the agreement.
The critical assumptions in A-2 are grouped as follows: general (the transfer pricing methodology applied, the business activities, and the financial, tax and accounting methods); functions performed, assets employed and risk undertaken, and classification of the applicant; associated enterprises (a new associated enterprise from a jurisdiction notified under section 176 or a no tax or low tax jurisdiction as per rule 86(m), or an existing one that has become resident there); invoicing and credit terms (seven questions on the frequency and timing of invoices, realisation and payment, and whether interest income has been offered where the terms were not complied with); and other compliances (sections 170 and 177, segmental accounts, certificates as agreed from the management, cost accountant, chartered accountant, chartered engineer and registered valuer, and other critical assumptions).
Form No. 54: renewal
Rule 119 treats renewal as a new application in Form No. 54, following the same procedure as outlined in the rules except the pre-filing consultation in rule 105. The rules do not give a separate window for renewal in the text read.
| Part | Rows | What it asks |
|---|---|---|
| A: Particulars of the Applicant | 1 to 6 | Name, address, communication address in India, PAN, contact details in India, authorised representative |
| B: Other Details | 7 to 10 | Acknowledgement number of the application for the last agreement; type of agreement; for bilateral or multilateral, whether the associated enterprises applied in their country (evidence, proposed date, period); period of the proposed agreement and the date from which it is requested |
| B | 11 and 12 | Transactions proposed to be covered (transaction ID, type, estimated amount, associated enterprise details, proposed method, whether rollback is opted); for each rollback transaction, the prior four tax years: date of return and of the audit report in Form No. 48, pending appeals, and whether the Appellate Tribunal has disposed of an appeal on the arm's length price |
| B | 13 | Fee particulars: application fee and rollback fee with amount and transaction reference number |
| B | 14 | Whether there are changes in the details or documents at Annexures A-1 to A-26 from the last application, with the relevant annexures updated if the answer is yes |
The verification is the same as in Form No. 52. Note 7 refers to the fee under rules 106(1) and 111(5), and Note 9 repeats the annexures A-1 to A-26 of the application form, from the history of the applicant and associated enterprise to the transfer pricing methodology analysis. A renewing applicant updates those that have changed.
An example
Larkspur Pharma India Private Limited has an agreement covering three tax years. For the first year it must file Form No. 52 within thirty days of the due date of the return for that year, or within ninety days of entering into the agreement if that is later. It files one form for each year and fills Annexure A-1 using the profit level indicator in its agreement, and A-2 with each critical assumption answered. As the agreement nears its end, Larkspur files Form No. 54 as a new application, without a pre-filing consultation, with row 14 recording which annexures have changed.
Need help with an APA compliance report?
A single missed critical assumption or a wrongly computed adjustment can affect the yearly report and the agreement. Our tax planning advisory team can help you prepare the annexures, test the adjustment and keep the timeline for each year.
Key takeaways
- Form No. 52 is filed for each year covered by the agreement, as a separate report for each year.
- Rule 113(3) fixes thirty days from the due date of the return or ninety days from entering into the agreement, whichever is later.
- Annexure A-1 computes the adjustment; A-2 tests the critical assumptions; A-3 confirms documentation.
- Renewal is a new application in Form No. 54 under rule 119, with no pre-filing consultation.
- Form No. 54 row 14 records changes since the last application.
Read next
- Rules 113 to 117: APA compliance audit, revision and cancellation
- Rules 110 to 112, 119 and 120: APA terms, rollback and renewal
- Form Nos. 56 and 57: Master File and intimation by the designated constituent entity
- Form Nos. 50 and 51: pre-filing consultation and application for an Advance Pricing Agreement
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.