Rule 124 — Furnishing of report in respect of an international group under section 511. Made under s.511 of the Income-tax Act, 2025.
Rule 124 gives effect to Section 511 of the Income-tax Act, 2025. A rule cannot go beyond the section it serves: where the two seem to differ, the section governs.
The rule works out the country-by-country reporting machinery under section 511 — the authority, the forms, the periods, the revenue threshold and the currency conversion.
Sub-rule (1) makes the income-tax authority for the purposes of section 511 the Joint Director, as may be designated by the Director General of Income-tax (Systems). Sub-rule (2) requires the notification under section 511(1) to be made in Form No. 58, two months prior to the due date for furnishing the report specified under section 511(2).
Sub-rule (3) requires every parent entity or alternate reporting entity resident in India to furnish, for every reporting accounting year, the report referred to in section 511(2) in Form No. 59. Sub-rule (4) fixes the period for furnishing the report under section 511(4) by the constituent entity referred to in that sub-section at twelve months from the end of the reporting accounting year. Sub-rule (5) shortens matters where the parent entity is resident of a country or territory in which there has been a systemic failure that has been intimated to the constituent entity: the period for submission is then six months from the end of the month in which the systemic failure was intimated. Sub-rule (6) requires the information about the designated constituent entity under section 511(5) to be furnished in Form No. 60.
Sub-rule (7) fixes the figure the Act leaves to be prescribed: for the purposes of section 511(8), the total consolidated group revenue of the international group shall be six thousand four hundred crore rupees. Sub-rule (8) supplies the conversion where that revenue, as reflected in the consolidated financial statement, is in foreign currency — the telegraphic transfer buying rate of that currency on the last day of the accounting year preceding the accounting year. Sub-rule (9) requires any revision or correction in the report furnished in Form No. 59 to be made by furnishing an intimation to the Director General of Income-tax (Systems). Sub-rule (10) takes "accounting year", "consolidated financial statement" and "international group" from section 511(10), and "telegraphic transfer buying rate" from rule 207.
Section 511 builds the country-by-country report but leaves the operative numbers and papers to be prescribed: which authority receives what, in which form, by when, and above what size of group the obligation bites at all. The rule supplies each of them. The two shorter periods, and the currency rule fixed to the last day of the preceding accounting year, exist so that groups in the same position are measured the same way and a filing deadline does not depend on which day an exchange rate is taken.
| What | Figure | The condition on it | Where |
|---|---|---|---|
| Time for the notification under section 511(1) | Two months prior to the due date for furnishing the report specified under section 511(2) | Notification made in Form No. 58 | Sub-rule (2) |
| Period for furnishing the report under section 511(4) by a constituent entity | Twelve months from the end of the reporting accounting year | Constituent entity referred to in section 511(4) | Sub-rule (4) |
| Period for submission where a systemic failure has been intimated | Six months from the end of the month in which the systemic failure has been intimated | Parent entity resident of a country or territory where there has been a systemic failure intimated to the constituent entity | Sub-rule (5) |
| Total consolidated group revenue for section 511(8) | Six thousand four hundred crore rupees | Of the international group | Sub-rule (7) |
| Rate of exchange for revenue in foreign currency | The telegraphic transfer buying rate on the last day of the accounting year preceding the accounting year | Where the total consolidated group revenue reflected in the consolidated financial statement is in foreign currency | Sub-rule (8) |
Three separate dates run off different events and are easily confused. The Form No. 58 notification is due two months before the report due date, so it is the earliest step, not an afterthought. The constituent entity's period under sub-rule (4) is twelve months from the end of the reporting accounting year. The systemic failure period under sub-rule (5) runs from the end of the month of intimation, not from the year end, and can therefore fall well outside the ordinary twelve months. The revenue threshold in sub-rule (7) is a figure the rule states outright — six thousand four hundred crore rupees — and where the consolidated financial statement is in foreign currency it is tested after conversion at the telegraphic transfer buying rate on the last day of the preceding accounting year, so a group near the line is measured on a rate fixed before the year even began. A mistake in Form No. 59 is not corrected by filing the form again: sub-rule (9) requires an intimation to the Director General of Income-tax (Systems).
An international group whose consolidated financial statement is drawn in a foreign currency reports revenue that converts, at the telegraphic transfer buying rate on the last day of the preceding accounting year, to Rs 7,100 crore. That is above the six thousand four hundred crore rupees fixed by sub-rule (7), so the reporting obligation applies. Its Indian parent entity furnishes the report in Form No. 59 for the reporting accounting year, having made the section 511(1) notification in Form No. 58 two months before the report was due; when a figure in the report is later found to be wrong, it intimates the correction to the Director General of Income-tax (Systems) rather than re-filing the form on its own motion.
A group entity in India meets it in the Form No. 58 notification, the Form No. 59 report and, where another entity is designated, Form No. 60. An individual taxpayer never meets it; the group's reporting shows up instead in transfer pricing proceedings.
For the purposes of section 511(8), the total consolidated group revenue of the international group shall be six thousand four hundred crore rupees.
The period for furnishing of the report under section 511(4) by the constituent entity, referred to in that sub-section shall be twelve months from the end of the reporting accounting year.