Notification No. 18/2012 — Income-tax (sixth Amendment) Rules, 2012 - Insertion of rule 10AB

What this is

Notification No. 18/2012 was published on 23 May 2012. Its subject is Income-tax (sixth Amendment) Rules, 2012 - Insertion of rule 10AB.

This amends the Income-tax Rules. What it changes is the Rules, not the Act — and a rule can never take away what the section gives.

What it does

By the Income-tax (Sixth Amendment) Rules, 2012, made under section 295 of the Income-tax Act, 1961, the Central Board of Direct Taxes inserts rule 10AB in the Income-tax Rules, 1962 after rule 10A, and inserts clause (f) in sub-rule (1) of rule 10B. Rule 10AB provides that, for the purposes of clause (f) of sub-section (1) of section 92C, the other method for determination of the arm's length price in relation to an international transaction shall be any method which takes into account the price which has been charged or paid, or would have been charged or paid, for the same or similar uncontrolled transaction, with or between non-associated enterprises, under similar circumstances, considering all the relevant facts. The new clause (f) in sub-rule (1) of rule 10B adds "Any other method as provided in rule 10AB" to the methods of determining the arm's length price.

Who it reaches

assessees entering into international transactions with associated enterprises
transfer pricing practitioners selecting the most appropriate method
Transfer Pricing Officers examining an arm's length price determination

The provisions it speaks to

Left, the provision of the Income-tax Act, 1961 as the instrument itself names it. Right, the section of the Income-tax Act, 2025 that the department’s own concordance maps it to — which is where the same ground is now covered.

Under the 1961 Act	Now
s.92C	s.165
s.295	s.533

The instrument, as the Board published it

The words below are the department’s own, reproduced from its published text. Where the department’s copy carried a publisher’s notes after the instrument, those are not reproduced.

Income-tax (sixth Amendment) Rules, 2012 - Insertion of rule 10AB
Notification No. 18/2012 [F. No. 142/5/2012-TPL] S.O. 1169(E), dated 23-5-2012
In exercise of the powers conferred by section 295 of the Income-tax Act, 1961 (43 of 1961), the Central Board of Direct Taxes hereby makes the following rules further to amend the Income-tax Rules, 1962 namely:-
1. (1) These rules may be called the Income-tax (6th Amendment) Rules, 2012.
(2) They shall come into force on the 1st day of April, 2012 and shall apply to Assessment year 2012-13 and subsequent years.
2. In the Income-tax Rules, 1962 (hereinafter referred to as the said rules), after rules 10A, the following rule shall be inserted, namely:-
"Other method of determination of arm's length price
10AB. For the purposes of clause (f) of sub-section (1) of section 92C, the other method for determination of the arms' length price in relation to an international transaction shall be any method which takes into account the price which has been charged or paid, or would have been charged or paid, for the same or similar uncontrolled transaction, with or between non-associated enterprises, under similar circumstances, considering all the relevant facts."
3. In rule 10B of the said rules, in sub-rule (1) after clause (e), the following clause shall be inserted, namely:-
"(f) Any other method as provided in rule 10AB."
■■

What it changes

The rule numbers are the 1962 Rules’ own, as the notification names them. The right-hand column is the department’s own mapping into the Income-tax Rules, 2026, which renumbered nearly everything.

Rule of the 1962 Rules	Now, in the 2026 Rules
Rule 10AB	rule 78
Rule 10A	rule 77
Rule 10B	rule 79

From when

1 April 2012, applying to assessment year 2012-13 and subsequent years.

What to watch

The rules come into force on 1 April 2012 and apply to assessment year 2012-13 and subsequent years.
The other method rests on a price charged or paid, or one that would have been charged or paid, for the same or similar uncontrolled transaction under similar circumstances, so a quotation or offer can be the basis where all relevant facts are considered.
Rule 10B(1) is amended in step, so the other method takes its place among the prescribed methods and remains subject to the most appropriate method test.

Where you meet it

In the transfer pricing study and the accountant's report supporting an international transaction, and in the Transfer Pricing Officer's order determining the arm's length price.

What it names

Rules it names. Rule 10AB, 10B of the Income-tax Rules, 1962. The 1962 Rules were replaced by the Income-tax Rules, 2026, which renumbered nearly everything: a rule number quoted here almost never means the same rule today.

On the same provision

Other instruments in this library that name the same provision of the 1961 Act. They are not necessarily still operative, and a later one may have replaced an earlier one without saying so.

Notification No. 157/2025 [F. No. 500/1/2014-APA-II] / SO 5053(E) — Ministry of Finance 6 November 2025
Notification No. 116/2024 [F. No. 500/1/2014-APA-II] / SO 4571(E) — Ministry of Finance 18 October 2024
Notification No. 46/2023 [F. No. 500/1/2014-APA-II] / SO 2777(E) — Ministry of Finance 26 June 2023
Notification No. 70/2022 [F. No. 500/1/2014-APA-II] / SO 2928(E) — Ministry of Finance 28 June 2022
Notification No. 124/2021 [F. No. 500/1/2014-APA-II] / S.O. 4586(E) — Ministry of Finance 29 October 2021
Notification No. 83/2020 [F.No.500/1/2014-APA-II] / SO 3660(E) — रुजचका िमा, अिर सजचि 19 October 2020

← Notification No. 19/2012 · Notification No. 17/2012 →

What a notification is. A notification is made under a power the Act itself gives, and within that power it is law — unlike a circular, which only binds the department. Its reach is the reach of the enabling provision and no wider, and the date it carries decides from when it works.

Source: the Income Tax Department’s own published text — its page for this instrument.