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.
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This article is for general information. Refer to the Income-tax Act, 2025 as amended by the Finance Act, 2026 and the Taxation and Other Laws (Amendment) Act, 2026 for the official provisions. If you need professional advice for your situation, contact Bizeneed.
Statutory text
Bare law
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 such report on or before the specified date in the prescribed form duly signed and verified in the manner as may be prescribed by such accountant and setting forth such particulars as may be prescribed.
Introduction
The duty is triggered by entering into an international transaction or specified domestic transaction during a tax year. The person must obtain an accountant’s report and furnish it by the specified date in the prescribed form, duly signed and verified, with prescribed particulars.
Key takeaways
Who files
Every person who entered into either specified transaction during the tax year is covered.
Report form and date
The report must be furnished by the specified date in the prescribed form and manner.
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.
When this provision applies
Classify the transactions before preparing the report. The obligation concerns an international transaction or a specified domestic transaction; those statutory categories must be tested rather than treating every foreign invoice or domestic related-party payment as automatically reportable.
Obtaining the report and furnishing it are both required. The report must contain the prescribed particulars and be signed and verified by the accountant in the prescribed manner. A completed draft held in the company’s records is not evidence of furnishing.
Limits and procedural safeguards
Section 173(d) defines the specified date as one month before the Section 263(1) return due date for the relevant tax year. Work from the applicable legal date and any valid extension, rather than assume that a date used in an earlier year necessarily governs.
The accountant’s report does not replace the separate obligation to keep and furnish transfer-pricing information under Section 171. Maintain the underlying transaction and pricing records and reconcile them to the report.
Step-by-step review
1. Identify the international and specified domestic transactions using the applicable definitions and conditions.
2. Reconcile the transaction register, accounts, agreements and supporting pricing documentation.
3. Obtain the prescribed signed and verified accountant’s report and determine the specified date.
4. Furnish the report through the required process and retain the acknowledgement and final version.
Hypothetical example
Hypothetical illustration: a company obtains the signed accountant’s report before the specified date but leaves it unsubmitted. Preparation alone does not satisfy the separate duty to furnish it. Its compliance record should include the submission acknowledgement as well as the signed report.
Records to prepare
Transaction classification and register reconciled to the accounts.
Supporting agreements and Section 171 documentation.
Final prescribed report, signature and verification record, due-date calculation and furnishing acknowledgement.
Official amended Act source
Practical checklist
Do
- Identify reportable transactions and obtain the accountant's prescribed report before the specified date.
- Reconcile the report to the transaction register and supporting Section 171 documentation.
- Transaction classification and register reconciled to the accounts.
- Supporting agreements and Section 171 documentation.
- Final prescribed report, signature and verification record, due-date calculation and furnishing acknowledgement.
Avoid
- Do not mistake mere preparation for furnishing the report by the deadline.
- Do not omit a specified domestic transaction that crosses Section 164's threshold.
Glossary
- Specified date
- The date defined in Section 173(d), one month before the return due date for the relevant tax year.
- Accountant's report
- The prescribed signed and verified transaction report required by Section 172.
- Furnishing
- Submitting the report through the required process, distinct from merely preparing or obtaining it.
Frequently asked questions
Does Section 172 itself state a calendar filing date?
No. It requires filing by the “specified date”; section 173 defines that term.
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.)
Is obtaining the signed report enough without submitting it?
No. Section 172 requires both obtaining the report and furnishing it by the specified date.
Does the report replace the underlying transfer-pricing records?
No. Section 171 separately governs maintaining and furnishing the relevant information and documents.
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Get your transfer pricing accountant's report preparedLast updated 10 October 2026