Guidance Note on Report Under Section 92E of The Income-Tax ACT, 1961 (Transfer Pricing) (Revised 2017)


Taxation laws pertaining to cross border transactions have always been complex as also interesting. Frequent changes in the taxation laws have made the area more dynamic. Having dynamism and the complexity involved, over a period of time, Transfer Pricing has surfaced as a distinct area of practice for our members.

The onerous responsibility of examining the records and thereafter issuing Report in Form No. 3CEB under section 92E of the Income tax Act, 2017 is being discharged efficiently by our members. Time and again changes in law pose challenges which are to be addressed in a most professional manner. In order to guide and support the members, ICAI through its dedicated Committee on International Taxation takes all efforts in the said direction.

Issuance of this revised version of the “Guidance Note on Report under section 92E of the Income tax Act, 1961” is also a step in the said direction. Even though the Guidance Note was recently revised in the year 2016, considering the changes effected by the Finance Act, 2017 and OECD TP Guidelines (2017), the Committee thought it fit to update the same this year also. The exposure draft of this Guidance Note was hosted on ICAI’s website for inputs from members at large. The suggestions so received have been considered and appropriately incorporated.

I extend my heartiest thanks to CA. Nilesh S. Vikamsey, President and CA. Naveen N.D.Gupta, Vice-President of the Institute of Chartered Accountants of India for being a guiding force behind the activities being undertaken by the Committee.


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