Rule 200 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.
Rule 200 of the Income-tax Rules, 2026 puts an advance ruling application under section 383(1) into Form No. 120, filed electronically under digital signature or EVC, with fees running from Rs 10,000 to Rs 10,00,000 by transaction size.
The application
Sub-rule (1) of rule 200: an application for obtaining an advance ruling under section 383(1) shall be made by a resident or a non-resident applicant in Form No. 120 and verified in the manner indicated therein in accordance with the rule. The 1962 parallel is rule 44E.
One form serves both classes of applicant. What separates them is not the form but the fee, and the fee turns on which sub-clause of section 380(a) the applicant falls under and how large the transaction is.
The fee table
Sub-rule (2) of rule 200 sets the fees payable along with the application:
| Sl. No. | Category under Chapter XVIII-D(2) | Amount of transaction | Fee |
|---|---|---|---|
| 1 | Tax liability arising out of a transaction undertaken or proposed by a non-resident applicant under section 380(a)(i), or a resident applicant under section 380(a)(ii) | Less than one hundred crore rupees | Rs 2,00,000 |
| Between one hundred crore and three hundred crore rupees | Rs 5,00,000 | ||
| More than three hundred crore rupees | Ten lakh rupees | ||
| 2 | Tax liability of a resident applicant arising out of a transaction undertaken or proposed by a resident applicant under section 380(a)(iii) | Between one hundred crore and three hundred crore rupees | Rs 5,00,000 |
| More than three hundred crore rupees | Ten lakh rupees | ||
| 3 | Any other applicant | In all cases | Rs 10,000 |
Sl. No. 1 of the table in rule 200(2) carries three bands, opening with "less than one hundred crore rupees". Sl. No. 2 carries only two, starting at "between one hundred crore rupees and three hundred crore rupees". A section 380(a)(iii) resident applicant whose transaction is below one hundred crore rupees therefore has no band of his own in the printed table. The natural reading is that such an applicant falls into Sl. No. 3, "any other applicant", at Rs 10,000, since Sl. No. 3 is the residuary entry and applies "in all cases". The printed table is reproduced here rather than silently amended; confirm the position with the Board's utility before paying, because an underpaid fee makes the application defective.
Note also the drafting of the middle band in rule 200: "between one hundred crore rupees and three hundred crore rupees". Amounts exactly at either boundary sit in that band on the ordinary reading, since the outer bands are expressed as less than and more than.
Electronic filing and signature
Sub-rule (3) requires the application, the verification appended to it, the annexures and the statements and documents accompanying it to be furnished electronically and signed or digitally signed. Who signs depends on whether the applicant files a return:
| Applicant | Signatory | Mode |
|---|---|---|
| Required to furnish a return of income under the Act — clause (a) | The person authorised to verify that return under section 265 | Digital signature if the return itself must be under digital signature; electronic verification code in any other case |
| Not required to furnish a return — clause (b) | Any person duly authorised by the applicant for this purpose and holding a valid power of attorney | Digital signature or EVC as specified by the Board |
Clause (a) of rule 200(3) does not offer a choice. If the applicant's return of income must be furnished under digital signature, then Form No. 120 must be too; EVC is available only where the return itself may be verified that way. A non-resident applicant with no Indian return obligation falls into clause (b) instead, and there the requirement is a valid power of attorney — which is the document most often missing when a foreign applicant's filing is rejected.
Proof of payment
Sub-rule (4): every application in the applicable Form shall be accompanied by the proof of payment of fees as specified in sub-rule (2). The fee and its proof are part of the filing, not a follow-up.
Worked example
| Facts | Fee and filing under rule 200 |
|---|---|
| Non-resident under section 380(a)(i); transaction Rs 80 crore | Rs 2,00,000 — Sl. No. 1, first band |
| Non-resident under section 380(a)(i); transaction Rs 250 crore | Rs 5,00,000 — Sl. No. 1, middle band |
| Resident under section 380(a)(ii); transaction Rs 400 crore | Ten lakh rupees — Sl. No. 1, top band |
| Resident under section 380(a)(iii); transaction Rs 200 crore | Rs 5,00,000 — Sl. No. 2 |
| Resident under section 380(a)(iii); transaction Rs 40 crore | No band printed in Sl. No. 2; residuary Sl. No. 3 at Rs 10,000 is the natural reading — confirm before paying |
| Public sector undertaking not within Sl. Nos. 1 or 2 | Rs 10,000 — Sl. No. 3, in all cases |
| Indian company that files its return under DSC | Form No. 120 must be signed under digital signature too |
| Foreign applicant with no Indian return obligation | Signed by an attorney holding a valid power of attorney |
| Application filed, fee paid the following week | Defective — sub-rule (4) requires proof of payment to accompany it |
Compliance checklist
- Fix the applicant's sub-clause of section 380(a) first — it selects the row of the fee table in rule 200(2).
- Value the transaction, aggregating one or more transactions for which the ruling is sought.
- Read the band boundaries as less than / between / more than, and place a boundary figure in the middle band.
- For a section 380(a)(iii) applicant below one hundred crore rupees, confirm the fee with the Board's utility before paying.
- Decide the signature mode from the return obligation, not from convenience.
- For a non-filing applicant, put the power of attorney in place before the filing window.
- File the verification, annexures, statements and documents electronically — rule 200(3) covers all of them, not just the form.
- Attach proof of fee payment to the application itself.
Common mistakes
- Paying Rs 10,000 by default when the applicant falls in Sl. No. 1 or Sl. No. 2.
- Valuing a single leg of a multi-leg transaction when the table speaks of one or more transactions for which the ruling is sought.
- Using EVC where the applicant's return must be filed under digital signature.
- Filing without a power of attorney for a non-resident applicant with no return obligation.
- Filing the form electronically but the annexures on paper.
- Treating the fee as payable after admission rather than with the application.
Which year this governs
The Income-tax Rules, 2026 are made under the Income-tax Act, 2025. The 1962 parallel to rule 200 is rule 44E, given for tracing only. Section references are to the Income-tax Act, 2025. Verify the current text and the fee table before paying on a live matter.