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Knowledge Bank / Income-tax Act, 2025 / Chapter X - Special Provisions Relating to Avoidance of Tax

Section 172

Section 172: accountant's report for international and specified domestic transactions

Section 172 is a short but important compliance requirement in the transfer pricing chapter: anyone who has entered into an international transaction or a specified domestic transaction during a tax year must get an accountant's report and file it by the specified date.

This explanation is AI-assisted and pending review by our CA/CS team. It is general information, not professional advice - always cross-check against the bare law text above or talk to our tax team for guidance specific to your situation.

What the section requires

Every person who has entered into an international transaction or specified domestic transaction during a tax year shall obtain a report from an accountant and furnish that report on or before the specified date, in the prescribed form, duly signed and verified by the accountant in the prescribed manner, and setting out such particulars as may be prescribed.

Frequently asked questions

Who must obtain the accountant's report under Section 172?

Every person who has entered into an international transaction or a specified domestic transaction during the tax year.

By when must the report be furnished?

On or before the specified date, in the prescribed form, duly signed and verified by the accountant in the manner prescribed. ("Specified date" is defined in Section 173(d) as one month before the due date for furnishing the return of income under Section 263(1) for the relevant tax year.)

Related sections

  • Section 166 - reference to Transfer Pricing Officer
  • Section 171 - maintaining and furnishing transfer pricing documentation
  • Section 173 - transfer pricing definitions

Want this applied to your actual filing, not just explained?

Get your transfer pricing accountant's report prepared

Last updated 9 September 2026

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