Section 172 — Report from an accountant to be furnished by persons entering into international transaction or specified domestic transaction. Successor to s.92E of the 1961 Act.
Every person who has entered into an international transaction or a specified domestic transaction during a tax year must obtain a report from an accountant and furnish it on or before the specified date. The report must be in the prescribed form, signed and verified by the accountant in the prescribed manner, and set out the prescribed particulars. The section is a single sentence with no sub-sections, no thresholds and no exemptions.
Why it is there
It puts an accountant's certification behind every covered transaction as a matter of course, so the Department has an independent report on the transactions before it examines the pricing.
Who it applies to
Every person who has entered into an international transaction during a tax year
Every person who has entered into a specified domestic transaction during a tax year
The accountant who signs and verifies the report
What this means in practice
The obligation attaches to entering into even one covered transaction — the section sets no monetary threshold and gives no exclusion, so value is irrelevant to whether the report is due. The form, the manner of verification, the particulars and the specified date are all left to be prescribed, so none of them can be answered from this section. Note that section 447, which previously imposed a penalty of Rs. 1,00,000 for failing to furnish this report, has been omitted with effect from 1 April 2026.
An example
Illustrative only, and invented for this page. The figures are chosen to show the rule biting, not taken from any real matter.
A company enters into a single international transaction during the tax year — one intra-group service charge of Rs. 8 lakh. It must still obtain a report from an accountant and furnish it on or before the specified date: the section applies to every person who has entered into such a transaction and states no monetary threshold and no exemption, so size is no answer. What the section does not supply is the detail — the form, the manner in which the accountant signs and verifies, and the particulars are all 'as may be prescribed', so none of them can be read out of the section itself.
Where you meet this section
As a standing annual compliance for anyone with an international transaction or a specified domestic transaction: an accountant's report, in the prescribed form, furnished on or before the specified date. Both the form and the date come from the rules, not from this section.
The words themselves
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
Section section 172, Income-tax Act, 2025.
What people get wrong
Assuming a value threshold. The section applies to every person entering into such a transaction, with no monetary limit stated.
Looking in the section for the due date. It says only "on or before the specified date"; the date, the form and the particulars are prescribed elsewhere.
Assuming the penalty section still applies — section 447, the penalty for failure to furnish this report, was omitted by Act No. 4 of 2026 with effect from 1 April 2026.
What this replaced
The correspondence is the Income Tax Department’s own, from its comparison utility for the 1961 and 2025 Acts. A renumbering is the easy half; whether the words changed is the half that decides cases.
92E - Report from an accountant to be furnished by persons entering into international transaction or specified domestic transaction
Rules of the Income-tax Rules, 2026 that work section 172. Where the rule’s own heading names the section we say so; the rest are marked on reading the rule, which is our derivation and not the department’s. A rule that serves the section silently and that we have missed will not appear here.
Rule 85 — Report from an accountant to be furnished under section 172
Rule 97 — Safe harbour for eligible specified domestic transaction — on reading the rule
Rule 274 — Procedure for investment fund for availing benefit under section 9(12) read with Schedule I to Act — on reading the rule
A circular binds the department, not you and not a court. Every one below was written under the 1961 Act; it reaches this section because the department’s own concordance carries the provision it names to this one.
Circular No. 18/2024 — Extension of due date for furnishing return of income in the case of an assessee who is required to furnish a report referred to i 2024-11-30
Circular No. 1/2022 — Extension of timelines for filing of income tax returns and various reports of audit for the assessment year 2021 22 2022-01-11
Circular No. 17/2021 — Extension of time lines for filing of Income-tax returns and various reports of audit for the Assessment Year 2021-22 2021-09-09
Circular No. 9/2021 — Extension of time limits of certain compliances to provide relief to taxpayers in view of the severe pandemic 2021-05-20
Read this before you rely on it. Every decision below was decided under the Income-tax Act, 1961. It appears here because it is tagged to a 1961 provision that the department’s own mapping carries to section 172. That is an inference we have drawn, not a holding on the new section: where the words changed in the move, the reasoning may not survive. Treat this as the place to start looking, not as authority on the 2025 Act.
Shell India Markets P Ltd v ACITHigh CourtHelps taxpayertagged s.92E The TPO says we issued shares to our parent too cheaply. Can he tax the shortfall?
Sony Ericsson Mobile Communications India P Ltd v CITHigh CourtCuts both waystagged s.92E The TPO says my advertising spend is higher than comparables and has added the excess as brand building for my foreign parent. Can he do that?
Explainers
Specified domestic transactionstagged s.92E Do I still have to benchmark payments to my own directors and group companies under transfer pricing?
What this page does not tell you. It does not reproduce the section. Everything above was written from the section’s own text as the Income Tax Department publishes it — the text is here, and nothing here is advice on your facts. Where a figure matters, read the sub-section it comes from.
