Section 511 — Furnishing of report in respect of international group. Successor to s.286 of the 1961 Act.
Section 511 is in Chapter XXIII — Miscellaneous, which runs from section 499 to section 536.
Sub-section (1) puts a notification duty on every constituent entity resident in India that is a constituent of an international group whose parent entity is not resident in India. It must notify the prescribed income-tax authority, in the form and manner and on or before the date as may be prescribed, whether it is the alternate reporting entity of the group, or else the details of the parent entity or alternate reporting entity and their country or territory of residence.
Sub-section (2) requires every parent entity or alternate reporting entity resident in India to furnish, for every reporting accounting year, a report on the international group to the prescribed income-tax authority within twelve months from the end of that year, in such form and manner as may be prescribed. Sub-section (3) fixes the contents for sub-sections (2) and (4): aggregate information on revenue, profit or loss before income-tax, income-tax paid, income-tax accrued, stated capital, accumulated earnings, number of employees and tangible assets other than cash or cash equivalents, for each country or territory in which the group operates; details of each constituent entity including its country of incorporation, organisation or establishment and of residence; the nature and details of each entity's main business activities; and any other prescribed information.
Sub-section (4) is the local filing rule: a constituent entity resident in India other than the sub-section (2) entity must itself furnish the report within the period as may be prescribed, where the parent entity is resident in a country that does not oblige it to file such a report, or that has no agreement with India providing for exchange of the report, or where a systemic failure of that country has been intimated to the constituent entity by the prescribed income-tax authority. Sub-section (5) allows a group with more than one Indian constituent entity to file through one of them, where the group has designated it to furnish the report on behalf of all and has conveyed that in writing to the prescribed income-tax authority.
Sub-section (6) switches sub-sections (4) and (5) off where an alternate reporting entity has furnished such a report with the tax authority of its country of residence on or before that country's date, and five conditions in clause (b) hold: the report is required under the law in force there; that country has an agreement with India for exchange of the report; no systemic failure in respect of it has been conveyed to any Indian constituent entity; the country has been informed in writing by the constituent entity that it is the alternate reporting entity; and the prescribed income-tax authority has been informed under sub-section (1).
Sub-section (7) lets the prescribed income-tax authority, to determine the accuracy of a report, issue a written notice requiring the reporting entity to produce specified information and documents within thirty days of receipt, extendable by up to an additional thirty days on the entity's application. Sub-section (8) disapplies the section for an accounting year where the total consolidated group revenue, per the consolidated financial statement for the preceding accounting year, does not exceed the prescribed amount. Sub-section (9) applies the section as per such guidelines and conditions as may be prescribed. Sub-section (10) defines twelve terms — among them accounting year, agreement, alternate reporting entity, constituent entity, group, international group, parent entity, reporting entity and systemic failure — and takes "permanent establishment" from section 173(c).
A country-by-country picture of where an international group books revenue, profit, tax, people and assets can only be assembled by the entity that prepares the consolidated statements, and that entity is often outside India. The section therefore builds three layers: an Indian parent or alternate reporting entity files directly; where the parent's country neither requires nor exchanges the report, an Indian constituent entity files locally; and where a foreign alternate reporting entity has filed and the report will actually reach India, the local filing falls away. The notification in sub-section (1) exists so the authority knows in advance which layer applies to which entity.
| What | Figure | The condition on it | Where |
|---|---|---|---|
| Deadline for the report by an Indian parent or alternate reporting entity | Within twelve months from the end of the reporting accounting year | For every reporting accounting year, in such form and manner as may be prescribed | Sub-section (2) |
| Period for a local filing by another Indian constituent entity | Within the period as may be prescribed — the section states no period | Where the parent's country does not require the report, has no exchange agreement with India, or a systemic failure has been intimated | Sub-section (4) |
| Date for the sub-section (1) notification | On or before such date as may be prescribed — the section states no date | In the form and manner also as may be prescribed | Sub-section (1) |
| Time to answer an accuracy notice | Thirty days from the date of receipt of the notice | To produce the information and documents specified in the notice | Sub-section (7) |
| Extension of that time | Up to an additional thirty days | Upon application by the entity | Sub-section (7) |
| Revenue threshold below which the section does not apply | The prescribed amount — the section states no figure | Total consolidated group revenue per the consolidated financial statement for the accounting year preceding the accounting year in question | Sub-section (8) |
Which obligation an Indian entity carries depends on facts about a foreign country rather than about itself — whether the parent's country requires the report, whether it exchanges it with India, and whether a systemic failure has been intimated. That is why the notification in sub-section (1) is owed by every Indian constituent entity of a foreign-parented group, not only by the one that may eventually file. The section states almost none of its own numbers: the revenue threshold, the notification date and the local filing period are all left to be prescribed, so the only fixed periods in it are the twelve months in sub-section (2) and the thirty plus thirty days in sub-section (7). Sub-section (6) is the relief route, and it fails if any one of its five conditions is missing.
An international group has an Indian subsidiary and a parent resident abroad, and its consolidated group revenue for the preceding accounting year exceeds the prescribed amount, so sub-section (8) does not exempt it. The Indian subsidiary must notify the prescribed income-tax authority under sub-section (1) that it is not the alternate reporting entity and give the parent's details and country. If that country neither obliges the parent to file the report nor exchanges it with India, the subsidiary must itself furnish the full report under sub-section (4) — unless an alternate reporting entity elsewhere has filed with its own authority by that country's date and all five conditions in sub-section (6)(b) are met. On an accuracy notice it has thirty days from receipt, and may apply for up to thirty more.
You meet it as the notification every Indian constituent entity of a foreign-parented group files with the prescribed income-tax authority, as the country-by-country report an Indian parent or alternate reporting entity furnishes within twelve months of the reporting accounting year end, and as a written notice under sub-section (7) seeking information to check the report's accuracy. The forms, dates and revenue threshold are all left to be prescribed.
furnish a report, to the prescribed income-tax authority within twelve months from the end of the said reporting accounting year
requiring the entity to produce such information and document as specified in the notice within thirty days of the date of receipt of the notice and such period may be extended by up to an additional thirty days upon application by the entity
if the total consolidated group revenue, as per the consolidated financial statement for the accounting year preceding such accounting year, does not exceed the prescribed amount
See the full 1961 to 2025 concordance.
All of them are in the Rules 2026 index.
See the circulars index.
See the notifications index.