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Rule 119Published

Rule 119: Renewing an APA in Form 54

Rule 119 provides for renewal of an APA through a new application in Form 54. The agreement procedure applies again, with the express exception of the Rule 105 pre-filing consultation.

Official notified Income-tax Rules, 2026

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Rule 119 - Renewing an agreement

Request for renewal of an agreement may be made as a new application in Form No. 54 for agreement, using the same procedure as outlined in these rules except pre-filing consultation as referred to in rule 105.

Rule breakdown

Renewal is a new application

The rule requires a new Form 54 application for agreement renewal. An approaching expiry does not itself extend the existing APA.

Check the current agreement’s coverage and intended renewed period early enough to prepare the application.

Pre-filing consultation is the stated exception

The same procedure applies except the pre-filing consultation under Rule 105. That exception does not say that every other filing, evidence or approval requirement disappears.

Review the applicable procedure as a whole and confirm the current official filing requirements for renewal.

Update the facts and proposed terms

Review changes in transactions, functions, assets, risks, business conditions and critical assumptions since the original agreement. Support the requested renewed terms with current evidence.

Do not copy an old factual description where operations have materially changed.

Keep existing-period compliance separate

Continue the existing APA’s annual reporting and compliance requirements for its covered years while the renewal application is considered.

Maintain separate records for the current agreement and the requested new period so expiry, renewal and outstanding compliance are clear.

Key takeaways

Form 54

Renewal uses a new prescribed application.

No automatic extension

The existing APA does not renew itself.

Consultation exception only

Other applicable procedural requirements remain for review.

Practical checklist

  • Plan renewal before the current coverage ends.
  • Update facts and proposed terms.
  • Maintain separate current-agreement compliance records.

Avoid

  • Do not treat a renewal request as automatic approval.
  • Do not reuse materially outdated factual assumptions.

FAQs

Does an APA automatically continue after expiry?

Rule 119 provides renewal through a new application; it does not state automatic extension.

Which form is used?

Form 54.

Is Rule 105 pre-filing consultation required for renewal under this rule?

The rule expressly excepts that consultation from the procedure.

Glossary

Form 54
The new application prescribed for renewal of an agreement.

Official sources