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Case lawCBDT Circulars & Instructions › Statutory position — s.286 with Rule 10DB: country-by-country reporting — who notifies in Form 3CEAC, who files the report in Form 3CEAD within twelve months, when the burden falls on the Indian constituent entity instead, and the alternate reporting entity route out
CBDT Circulars & InstructionsCuts both waysValidity unconfirmeds.286s.286(1)s.286(2)s.286(3)s.286(4)s.286(5)s.286(6)s.286(9)s.271GBs.92Ds.92FRule 10DB

Statutory position — s.286 with Rule 10DB: country-by-country reporting — who notifies in Form 3CEAC, who files the report in Form 3CEAD within twelve months, when the burden falls on the Indian constituent entity instead, and the alternate reporting entity route out

We are the Indian subsidiary of a foreign parent. Do we have to file a country-by-country report ourselves, or only tell the department who does, and by when?

We are the Indian subsidiary of a foreign parent. Do we have to file a country-by-country report ourselves, or only tell the department who does, and by when?

Two obligations, and they fall on different people. Under s.286(1), EVERY constituent entity resident in India whose parent entity is not resident in India must notify the prescribed authority whether it is the alternate reporting entity of the international group, or else give the details of the parent entity or alternate reporting entity and the country of which they are resident. Rule 10DB(2) requires that notification in Form No. 3CEAC, and it must be made TWO MONTHS PRIOR to the due date for furnishing the report under s.286(2). Under s.286(2), a parent entity or alternate reporting entity RESIDENT IN INDIA must furnish the report itself, "within a period of twelve months from the end of the said reporting accounting year", and Rule 10DB(3) prescribes Form No. 3CEAD for it. Under s.286(4), the burden shifts on to an Indian constituent entity that is not the reporting entity where the parent is resident in a country that does not require such a report, or with which India has no exchange agreement, or where a systemic failure has been intimated; Rule 10DB(4) gives it twelve months from the end of the reporting accounting year, or six months from the end of the month in which a systemic failure was intimated. The proviso to s.286(4) lets a group with several Indian constituent entities designate one to file, and Rule 10DB(5) requires that designation to be conveyed in Form No. 3CEAE. Section 286(5) provides a complete escape from sub-section (4) where an alternate reporting entity has filed the report with its own country's tax authority and five conditions are all satisfied, including that the said country has an exchange agreement with India and that the prescribed authority here has been informed under sub-section (1). Section 286(6) lets the prescribed authority call for information to test the accuracy of the report, by notice, within thirty days, extendable by a further period not exceeding thirty days on an application.

Decided by the CBDT Circulars & Instructions (Not applicable — statutory text), reported as Section 286 of the Income-tax Act, 1961, transcribed from incometaxindia.gov.in/w/section-286-60 (heading "Furnishing of report in respect of international group", Year: 2022) and incometaxindia.gov.in/w/section-286-62 (Year: 2024 (No. 1)), with sub-section (7) read again on incometaxindia.gov.in/w/section-286-64 (Year: 2025); Rule 10DB transcribed from incometaxindia.gov.in/w/rule-10db (Income-tax Rules, 1962, no "Year:" stamp). It bears on section 286, section 286(1), section 286(2), section 286(3), section 286(4), section 286(5), section 286(6), section 286(9), section 271GB, section 92D, section 92F, section Rule 10DB of the Income Tax Act 1961, in Assessment & Scrutiny and How Tax Law Is Read matters.

Validity check could not be completed. Validity check could not be completed. The section text is verified across three departmental pages with different "Year:" stamps (2022, 2024 (No. 1) and 2025), all carrying the heading "Furnishing of report in respect of international group", and the rule text from the departmental rule page. But I located no footnote on any of those pages dating the insertion of the present s.286, and departmental rule pages carry no "Year:" stamp, so neither instrument could be dated from the page. I found no judicial decision construing s.286 and did not check judicial treatment.

Why it matters

The commonest and most expensive mistake is treating the s.286(1) notification as optional or as something that follows the report. It does not: it is a stand-alone obligation on every Indian constituent entity of a foreign-parented group, it falls due TWO MONTHS BEFORE the report date, and s.286(5)(e) makes compliance with it a CONDITION of the escape route in sub-section (5) — an Indian constituent entity that has not filed Form 3CEAC cannot rely on the alternate reporting entity's foreign filing to get out of the sub-section (4) obligation to file the report here. The second trap is s.286(4)(aa), which was added to the original text: it is not enough that the parent's country requires a report; India must actually have an agreement providing for exchange of it. Groups parented in a country whose exchange relationship with India has lapsed find the filing obligation landing on the Indian subsidiary. Third, the s.286(6) notice carries its own thirty-day clock with a single extension of not more than thirty days, and the penalty for missing it under s.271GB(2) is a daily one.

Binding on the department, not on the assessee or the courts. An assessee may rely on a circular that is beneficial to them.

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