Our group is nowhere near the master file thresholds. Do we still have to file anything under Rule 10DA?
Yes. This is the most-missed compliance in Indian transfer pricing. Rule 10DA(3) says in terms: "The constituent entity shall furnish Part A of Form No. 3CEAA even if the conditions specified under sub-rule (1) are not satisfied." Every constituent entity of an international group files Part A, regardless of any threshold. Part B — the substantive master file information in clauses (a) to (n) of Rule 10DA(1) — is due only where BOTH conditions in sub-rule (1) are satisfied: (i) the consolidated group revenue of the international group for the accounting year, as reflected in its consolidated financial statement, exceeds FIVE HUNDRED CRORE RUPEES; AND (ii) the aggregate value of international transactions during the accounting year, as per the books of account, exceeds FIFTY CRORE RUPEES, or, in respect of purchase, sale, transfer, lease or use of intangible property, exceeds TEN CRORE RUPEES. The obligation itself comes from s.92D(1)(ii), which requires every person being a constituent entity of an international group to keep and maintain such information and document in respect of an international group as may be prescribed, and from s.92D(4), which requires the person referred to in that clause to furnish it to the authority prescribed under s.286(1) in the prescribed manner and by the prescribed date. Section 92D was substituted in this form by Act No. 23 of 2019 with effect from 1 April 2020; for assessment years 2018-19 and 2019-20 the same obligation sat in a proviso to s.92D(1), and s.92D(4) then referred to "the person referred to in the proviso to sub-section (1)". Rule 10DA(2) fixes that date as the s.139(1) due date for the return of income, and Rule 10DA(4) allows one designated constituent entity to file for all of them, provided the designation is conveyed in Form No. 3CEAB to the Joint Director referred to in Rule 10DB(1) THIRTY DAYS BEFORE the due date for furnishing Form No. 3CEAA.
Decided by the CBDT Circulars & Instructions (Not applicable — statutory text) on 2020-04-01, reported as Section 92D of the Income-tax Act, 1961 as substituted with effect from 1 April 2020, transcribed from incometaxindia.gov.in/w/section-92d-19 (heading "Maintenance, keeping and furnishing of information and document by certain persons", Year: 2021) and read again on incometaxindia.gov.in/w/section-92d-20 (Year: 2022); the pre-substitution text read on incometaxindia.gov.in/w/section-92d-16 (Year: 2017) and -18 (Year: 2019 (No. 2)); Rule 10DA transcribed from incometaxindia.gov.in/w/rule-10da (Income-tax Rules, 1962, no "Year:" stamp). It bears on section 92D, section 92D(1)(ii), section 92D(2), section 92D(3), section 92D(4), section 286, section 286(1), section 286(9), section 271AA, section 271AA(2), section 139(1), section Rule 10DA, section Rule 10DB, section Rule 10D of the Income Tax Act 1961, in Assessment & Scrutiny, Penalty and How Tax Law Is Read matters.
The Part A filing is missed constantly, because advisers screen for the thresholds and stop when the group fails them. Rule 10DA(3) is a standalone obligation that does not depend on the thresholds at all, and the sanction for missing it is s.271AA(2) — a flat penalty of five hundred thousand rupees for failure to furnish the information and document required under s.92D(4). A group below every threshold can therefore be exposed to a Rs 5 lakh penalty per constituent entity for not filing a form that takes an afternoon. Three further points. First, the sub-rule (1) conditions are cumulative for Part B — "exceeds five hundred crore rupees; AND" — so a group with very large international transactions but consolidated revenue of Rs 400 crore does not file Part B. Second, within condition (ii) the two limbs are alternatives — Rs 50 crore of international transactions generally, OR Rs 10 crore of intangible-property transactions — so an intangibles-heavy group crosses far earlier. Third, the Form 3CEAB designation is due THIRTY DAYS BEFORE Form 3CEAA, and a group that files 3CEAB late loses the single-filing concession in Rule 10DA(4) and is back to every constituent entity filing. Rule 10DA(6) requires the information to be kept for eight years from the end of the relevant assessment year, which is longer than the ordinary retention period practitioners work to.
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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Section 92D, as substituted by Act No. 23 of 2019 with effect from 1 April 2020 and as printed on the departmental pages stamped Year 2021 and Year 2022 under the heading "Maintenance, keeping and furnishing of information and document by certain persons", reads: "92D. (1) Every person,— (i) who has entered into an international transaction or specified domestic transaction shall keep and maintain such information and document in respect thereof as may be prescribed; (ii) being a constituent entity of an international group, shall keep and maintain such information and document in respect of an international group as may be prescribed. Explanation.—For the purposes of this clause,— (A) 'constituent entity' shall have the meaning assigned to it in clause (d) of sub-section (9) of section 286; (B) 'international group' shall have the meaning assigned to it in clause (g) of sub-section (9) of section 286. (2) Without prejudice to the provisions contained in sub-section (1), the Board may prescribe the period for which the information and document shall be kept and maintained under the said sub-section. (3) The Assessing Officer or the Commissioner (Appeals) may, in the course of any proceeding under this Act, require any person referred to in clause (i) of sub-section (1) to furnish any information or document referred therein, within a period of thirty days from the date of receipt of a notice issued in this regard: Provided that the Assessing Officer or the Commissioner (Appeals) may, on an application made by such person, extend the period of thirty days by a further period not exceeding thirty days. (4) The person referred to in clause (ii) of sub-section (1) shall furnish the information and document referred therein to the authority prescribed under sub-section (1) of section 286, in such manner, on or before such date, as may be prescribed." Before that substitution, and for assessment years 2018-19 and 2019-20, the same obligation was carried by a proviso to s.92D(1) reading "Provided that the person, being a constituent entity of an international group, shall also keep and maintain such information and document in respect of an international group as may be prescribed", and s.92D(4) then read "Without prejudice to the provisions of sub-section (3), the person referred to in the proviso to sub-section (1) shall furnish the information and document referred to in the said proviso to the authority prescribed under sub-section (1) of section 286, in such manner, on or before the date, as may be prescribed." Rule 10DA(1) requires every person being a constituent entity of an international group to keep and maintain the fourteen categories of information and document set out in clauses (a) to (n) — from a list of all entities of the group and their addresses, through the supply chain for the five largest products or services, the transfer pricing policies for intra-group services, the group's intangible property strategy and agreements, its financing arrangements including the names and addresses of the top ten unrelated lenders, to a copy of the annual consolidated financial statement and a list of existing unilateral advance pricing agreements and other tax rulings — but only "(i) if the consolidated group revenue of the international group, of which such person is a constituent entity, as reflected in the consolidated financial statement of the international group for the accounting year, exceeds five hundred crore rupees; and (ii) the aggregate value of international transactions,— (A) during the accounting year, as per the books of account, exceeds fifty crore rupees, or (B) in respect of purchase, sale, transfer, lease or use of intangible property during the accounting year, as per the books of account, exceeds ten crore rupees". Rule 10DA(2) requires that information to be furnished to the Joint Director referred to in Rule 10DB(1) "in Form No. 3CEAA on or before the due date for furnishing the return of income as specified under sub-section (1) of section 139". Rule 10DA(3) reads: "The constituent entity shall furnish Part A of Form No. 3CEAA even if the conditions specified under sub-rule (1) are not satisfied." Rule 10DA(4) permits one designated constituent entity to furnish Form No. 3CEAA where the group has designated it and "the information has been conveyed in Form No. 3CEAB to the Joint Director referred to in sub-rule (1) of rule 10DB, in this behalf thirty days before the due date of furnishing the Form No. 3CEAA". Rule 10DA(6) requires the information and documents to be kept for eight years from the end of the relevant assessment year, and Rule 10DA(7) fixes the rate of exchange for a foreign-currency consolidated group revenue as the telegraphic transfer buying rate on the last day of the accounting year.
Not a judgment. The statutory position is that a constituent entity of an international group must keep and maintain master file information under s.92D(1)(ii) and furnish it under s.92D(4) to the authority prescribed under s.286(1); that under Rule 10DA(2) the furnishing is in Form No. 3CEAA by the s.139(1) return due date; that under Rule 10DA(3) Part A of Form No. 3CEAA must be furnished by the constituent entity even where the sub-rule (1) conditions are not satisfied; that the substantive master file information is required only where both the Rs 500 crore consolidated group revenue condition and the Rs 50 crore international transactions or Rs 10 crore intangible property condition are satisfied; and that a single designated entity may file for the group only if Form No. 3CEAB is conveyed thirty days before the Form No. 3CEAA due date.
Not a judgment; no judicial reasoning is stated for these provisions.
(3) The constituent entity shall furnish Part A of Form No. 3CEAA even if the conditions specified under sub-rule (1) are not satisfied.
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Handle my notice → Ask a CA on WhatsAppYes. This is the most-missed compliance in Indian transfer pricing. Rule 10DA(3) says in terms: "The constituent entity shall furnish Part A of Form No. 3CEAA even if the conditions specified under sub-rule (1) are not satisfied." Every constituent entity of an international group files Part A, regardless of any threshold. Part B — the substantive master file information in clauses (a) to (n) of Rule 10DA(1) — is due only where BOTH conditions in sub-rule (1) are satisfied: (i) the consolidated group revenue of the international group for the accounting year, as reflected in its consolidated financial statement, exceeds FIVE HUNDRED CRORE RUPEES; AND (ii) the aggregate value of international transactions during the accounting year, as per the books of account, exceeds FIFTY CRORE RUPEES, or, in respect of purchase, sale, transfer, lease or use of intangible property, exceeds TEN CRORE RUPEES. The obligation itself comes from s.92D(1)(ii), which requires every person being a constituent entity of an international group to keep and maintain such information and document in respect of an international group as may be prescribed, and from s.92D(4), which requires the person referred to in that clause to furnish it to the authority prescribed under s.286(1) in the prescribed manner and by the prescribed date. Section 92D was substituted in this form by Act No. 23 of 2019 with effect from 1 April 2020; for assessment years 2018-19 and 2019-20 the same obligation sat in a proviso to s.92D(1), and s.92D(4) then referred to "the person referred to in the proviso to sub-section (1)". Rule 10DA(2) fixes that date as the s.139(1) due date for the return of income, and Rule 10DA(4) allows one designated constituent entity to file for all of them, provided the designation is conveyed in Form No. 3CEAB to the Joint Director referred to in Rule 10DB(1) THIRTY DAYS BEFORE the due date for furnishing Form No. 3CEAA. This was decided by the CBDT Circulars & Instructions (Not applicable — statutory text) and bears on section 92D, section 92D(1)(ii), section 92D(2), section 92D(3), section 92D(4), section 286, section 286(1), section 286(9), section 271AA, section 271AA(2), section 139(1), section Rule 10DA, section Rule 10DB, section Rule 10D of the Income Tax Act 1961. It is reported as Section 92D of the Income-tax Act, 1961 as substituted with effect from 1 April 2020, transcribed from incometaxindia.gov.in/w/section-92d-19 (heading "Maintenance, keeping and furnishing of information and document by certain persons", Year: 2021) and read again on incometaxindia.gov.in/w/section-92d-20 (Year: 2022); the pre-substitution text read on incometaxindia.gov.in/w/section-92d-16 (Year: 2017) and -18 (Year: 2019 (No. 2)); Rule 10DA transcribed from incometaxindia.gov.in/w/rule-10da (Income-tax Rules, 1962, no "Year:" stamp). The Part A filing is missed constantly, because advisers screen for the thresholds and stop when the group fails them. Rule 10DA(3) is a standalone obligation that does not depend on the thresholds at all, and the sanction for missing it is s.271AA(2) — a flat penalty of five hundred thousand rupees for failure to furnish the information and document required under s.92D(4). A group below every threshold can therefore be exposed to a Rs 5 lakh penalty per constituent entity for not filing a form that takes an afternoon. Three further points. First, the sub-rule (1) conditions are cumulative for Part B — "exceeds five hundred crore rupees; AND" — so a group with very large international transactions but consolidated revenue of Rs 400 crore does not file Part B. Second, within condition (ii) the two limbs are alternatives — Rs 50 crore of international transactions generally, OR Rs 10 crore of intangible-property transactions — so an intangibles-heavy group crosses far earlier. Third, the Form 3CEAB designation is due THIRTY DAYS BEFORE Form 3CEAA, and a group that files 3CEAB late loses the single-filing concession in Rule 10DA(4) and is back to every constituent entity filing. Rule 10DA(6) requires the information to be kept for eight years from the end of the relevant assessment year, which is longer than the ordinary retention period practitioners work to. If it applies to you, the first step is this: File Part A of Form No. 3CEAA for every constituent entity of the international group, by the s.139(1) due date, whether or not any threshold is crossed. Rule 10DA(3) requires it in terms and s.271AA(2) is the sanction.
Section 92D, as substituted by Act No. 23 of 2019 with effect from 1 April 2020 and as printed on the departmental pages stamped Year 2021 and Year 2022 under the heading "Maintenance, keeping and furnishing of information and document by certain persons", reads: "92D. (1) Every person,— (i) who has entered into an international transaction or specified domestic transaction shall keep and maintain such information and document in respect thereof as may be prescribed; (ii) being a constituent entity of an international group, shall keep and maintain such information and document in respect of an international group as may be prescribed. Explanation.—For the purposes of this clause,— (A) 'constituent entity' shall have the meaning assigned to it in clause (d) of sub-section (9) of section 286; (B) 'international group' shall have the meaning assigned to it in clause (g) of sub-section (9) of section 286. (2) Without prejudice to the provisions contained in sub-section (1), the Board may prescribe the period for which the information and document shall be kept and maintained under the said sub-section. (3) The Assessing Officer or the Commissioner (Appeals) may, in the course of any proceeding under this Act, require any person referred to in clause (i) of sub-section (1) to furnish any information or document referred therein, within a period of thirty days from the date of receipt of a notice issued in this regard: Provided that the Assessing Officer or the Commissioner (Appeals) may, on an application made by such person, extend the period of thirty days by a further period not exceeding thirty days. (4) The person referred to in clause (ii) of sub-section (1) shall furnish the information and document referred therein to the authority prescribed under sub-section (1) of section 286, in such manner, on or before such date, as may be prescribed." Before that substitution, and for assessment years 2018-19 and 2019-20, the same obligation was carried by a proviso to s.92D(1) reading "Provided that the person, being a constituent entity of an international group, shall also keep and maintain such information and document in respect of an international group as may be prescribed", and s.92D(4) then read "Without prejudice to the provisions of sub-section (3), the person referred to in the proviso to sub-section (1) shall furnish the information and document referred to in the said proviso to the authority prescribed under sub-section (1) of section 286, in such manner, on or before the date, as may be prescribed." Rule 10DA(1) requires every person being a constituent entity of an international group to keep and maintain the fourteen categories of information and document set out in clauses (a) to (n) — from a list of all entities of the group and their addresses, through the supply chain for the five largest products or services, the transfer pricing policies for intra-group services, the group's intangible property strategy and agreements, its financing arrangements including the names and addresses of the top ten unrelated lenders, to a copy of the annual consolidated financial statement and a list of existing unilateral advance pricing agreements and other tax rulings — but only "(i) if the consolidated group revenue of the international group, of which such person is a constituent entity, as reflected in the consolidated financial statement of the international group for the accounting year, exceeds five hundred crore rupees; and (ii) the aggregate value of international transactions,— (A) during the accounting year, as per the books of account, exceeds fifty crore rupees, or (B) in respect of purchase, sale, transfer, lease or use of intangible property during the accounting year, as per the books of account, exceeds ten crore rupees". Rule 10DA(2) requires that information to be furnished to the Joint Director referred to in Rule 10DB(1) "in Form No. 3CEAA on or before the due date for furnishing the return of income as specified under sub-section (1) of section 139". Rule 10DA(3) reads: "The constituent entity shall furnish Part A of Form No. 3CEAA even if the conditions specified under sub-rule (1) are not satisfied." Rule 10DA(4) permits one designated constituent entity to furnish Form No. 3CEAA where the group has designated it and "the information has been conveyed in Form No. 3CEAB to the Joint Director referred to in sub-rule (1) of rule 10DB, in this behalf thirty days before the due date of furnishing the Form No. 3CEAA". Rule 10DA(6) requires the information and documents to be kept for eight years from the end of the relevant assessment year, and Rule 10DA(7) fixes the rate of exchange for a foreign-currency consolidated group revenue as the telegraphic transfer buying rate on the last day of the accounting year. The matter was decided on 2020-04-01 by the CBDT Circulars & Instructions (Not applicable — statutory text). On those facts the CBDT Circulars & Instructions held as follows. Not a judgment. The statutory position is that a constituent entity of an international group must keep and maintain master file information under s.92D(1)(ii) and furnish it under s.92D(4) to the authority prescribed under s.286(1); that under Rule 10DA(2) the furnishing is in Form No. 3CEAA by the s.139(1) return due date; that under Rule 10DA(3) Part A of Form No. 3CEAA must be furnished by the constituent entity even where the sub-rule (1) conditions are not satisfied; that the substantive master file information is required only where both the Rs 500 crore consolidated group revenue condition and the Rs 50 crore international transactions or Rs 10 crore intangible property condition are satisfied; and that a single designated entity may file for the group only if Form No. 3CEAB is conveyed thirty days before the Form No. 3CEAA due date.
Not a judgment; no judicial reasoning is stated for these provisions. In the words reproduced by the source cited on this page: "(3) The constituent entity shall furnish Part A of Form No. 3CEAA even if the conditions specified under sub-rule (1) are not satisfied."
It was decided by the CBDT Circulars & Instructions on 2020-04-01 and is reported as Section 92D of the Income-tax Act, 1961 as substituted with effect from 1 April 2020, transcribed from incometaxindia.gov.in/w/section-92d-19 (heading "Maintenance, keeping and furnishing of information and document by certain persons", Year: 2021) and read again on incometaxindia.gov.in/w/section-92d-20 (Year: 2022); the pre-substitution text read on incometaxindia.gov.in/w/section-92d-16 (Year: 2017) and -18 (Year: 2019 (No. 2)); Rule 10DA transcribed from incometaxindia.gov.in/w/rule-10da (Income-tax Rules, 1962, no "Year:" stamp). Binding on the department, not on the assessee or the courts. An assessee may rely on a circular that is beneficial to them. A CBDT circular or instruction binds officers of the department but not the assessee and not the courts. Where a circular helps you, you may hold the department to it. Where it hurts you, it cannot override the Act or a judgment. On section 92D, section 92D(1)(ii), section 92D(2), section 92D(3), section 92D(4), section 286, section 286(1), section 286(9), section 271AA, section 271AA(2), section 139(1), section Rule 10DA, section Rule 10DB, section Rule 10D, the practical question is whether the facts of your own notice match the facts of this case closely enough for the same rule to apply.
It cuts both ways and is cited by both sides. Not a judgment. The statutory position is that a constituent entity of an international group must keep and maintain master file information under s.92D(1)(ii) and furnish it under s.92D(4) to the authority prescribed under s.286(1); that under Rule 10DA(2) the furnishing is in Form No. 3CEAA by the s.139(1) return due date; that under Rule 10DA(3) Part A of Form No. 3CEAA must be furnished by the constituent entity even where the sub-rule (1) conditions are not satisfied; that the substantive master file information is required only where both the Rs 500 crore consolidated group revenue condition and the Rs 50 crore international transactions or Rs 10 crore intangible property condition are satisfied; and that a single designated entity may file for the group only if Form No. 3CEAB is conveyed thirty days before the Form No. 3CEAA due date. It arises in Assessment & Scrutiny, Penalty and How Tax Law Is Read matters, on section 92D, section 92D(1)(ii), section 92D(2), section 92D(3), section 92D(4), section 286, section 286(1), section 286(9), section 271AA, section 271AA(2), section 139(1), section Rule 10DA, section Rule 10DB, section Rule 10D of the Income Tax Act 1961, and was decided by Not applicable — statutory text. Before relying on it, read the source linked on this page and check whether it has since been distinguished, overruled or overtaken by an amendment to the Income Tax Act. In practice the steps that follow from it are these. Test Part B on both conditions of Rule 10DA(1) TOGETHER: consolidated group revenue for the accounting year above Rs 500 crore AND either aggregate international transactions above Rs 50 crore or intangible-property transactions above Rs 10 crore. If the group wants one entity to file for all, get Form No. 3CEAB in to the Joint Director referred to in Rule 10DB(1) thirty days before the Form 3CEAA due date, and record the group's designation of that entity. Convert a foreign-currency consolidated group revenue figure at the telegraphic transfer buying rate on the LAST DAY OF THE ACCOUNTING YEAR, as Rule 10DA(7) requires — note that this is a different date from the conversion rule for the country-by-country threshold in Rule 10DB(7). Retain the master file information and documents for eight years from the end of the relevant assessment year, as Rule 10DA(6) requires. Do not conflate this with country-by-country reporting. The master file thresholds in Rule 10DA(1) and the s.286 threshold in Rule 10DB(6) are different numbers tested on different years, and being outside one says nothing about the other.
Validity check could not be completed. Validity check could not be completed. The section text is verified on two departmental pages with different "Year:" stamps (2021 and 2022) printing the text as substituted by Act No. 23 of 2019 with effect from 1 April 2020, and the pre-substitution text is recorded from the Year 2017 and Year 2019 (No. 2) pages. The latest page located is /w/section-92d-20 (Year: 2022), so a later amendment cannot be excluded. The rule text is verified on the departmental rule page and the critical sub-rule (3) was independently located on indiankanoon, but departmental rule pages carry no "Year:" stamp and I did not retrieve the footnotes to Rule 10DA, so I cannot say whether the thresholds in sub-rule (1) have been amended since the rule was made. I found no decision construing Rule 10DA and did not check judicial treatment. No source could be cited for that finding. Checking whether an authority still stands matters as much as knowing what it held: a decision may be overruled on one point and survive on another, or the provision it interprets may have been amended since. Read the source and the editor's note on this page before relying on it in a reply to an Assessing Officer or in an appeal.
SECTION 92D WAS SUBSTITUTED AND THE PAGES FIRST USED FOR THIS ENTRY WERE PRE-SUBSTITUTION. incometaxindia.gov.in/w/section-92d-19 (Year: 2021) and incometaxindia.gov.in/w/section-92d-20 (Year: 2022) both print the section under the heading "Maintenance, keeping and furnishing of information and document by certain persons", with sub-section (1) split into clauses (i) and (ii) and NO proviso, and the Year 2021 page carries the footnote "21. Sub. by the Act. No. 23 of 2019, w.e.f. 1-4-2020." Act No. 23 of 2019 is the Finance (No. 2) Act, 2019. The pages first used — /w/section-92d-16 (Year: 2017) and -18 (Year: 2019 (No. 2)) — print the PRE-SUBSTITUTION text under the older heading "Maintenance and keeping of information and document by persons entering into an international transaction or specified domestic transaction", in which the constituent-entity obligation sits in a proviso to sub-section (1) and sub-section (4) refers to "the person referred to in the proviso to sub-section (1)". Those pages are legislative history and must not be used to state the current position. This entry now states the substituted text and records the pre-substitution words, which govern assessment years 2018-19 and 2019-20. The substantive obligation is unchanged; the cross-references are not, and a current notice or submission should cite s.92D(1)(ii), not a proviso. FIVE FURTHER /w/section-92d SUFFIXES ARE OLDER STILL AND CARRY NO SUB-SECTION (4) AT ALL: -2 (Year 2010), -5 (Year 2003), -8 (Year 2013), -11 (Year 2007) and -14 (Year 2015); the suffix does not track vintage on this section. The tag "Rule 10D" in `sections` is a practice tag: rule 10D is the transaction-level documentation rule referred to in footnote 22 to s.92D(1)(i), and it is not otherwise discussed in this entry. Rule 10DA was transcribed from incometaxindia.gov.in/w/rule-10da, which prints "Income-tax Rules, 1962" and the rule heading "Maintenance and furnishing of information and document by certain person under section 92D"; departmental rule pages carry NO "Year:" stamp, so the rule has not been dated from the page and no amendment history for it is stated here. Rule 10DA(3) was independently corroborated: an exact-phrase search on indiankanoon for "3CEAA" returned its page for rule 10DA carrying the words "constituent entity shall furnish Part A of Form No. 3CEAA even if the conditions specified under sub-rule (1) are not satisfied", which is a check that the sub-rule is genuine and not a fetch-layer invention. This library shows the verification state of every entry openly. This entry has not yet been read in full by a chartered accountant. The summary reflects the sources listed on this page. Read the source before you rely on it in a reply to an Assessing Officer or in an appeal before the Commissioner (Appeals) or the Income Tax Appellate Tribunal.
Not a judgment. The statutory position is that a constituent entity of an international group must keep and maintain master file information under s.92D(1)(ii) and furnish it under s.92D(4) to the authority prescribed under s.286(1); that under Rule 10DA(2) the furnishing is in Form No. 3CEAA by the s.139(1) return due date; that under Rule 10DA(3) Part A of Form No. 3CEAA must be furnished by the constituent entity even where the sub-rule (1) conditions are not satisfied; that the substantive master file information is required only where both the Rs 500 crore consolidated group revenue condition and the Rs 50 crore international transactions or Rs 10 crore intangible property condition are satisfied; and that a single designated entity may file for the group only if Form No. 3CEAB is conveyed thirty days before the Form No. 3CEAA due date.
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