Rule 200 of the Income-tax Rules, 2026

Where this rule sits

Rule 200 gives effect to Section 383 and Section 380 of the Income-tax Act, 2025. A rule cannot go beyond the section it serves: where the two seem to differ, the section governs.

← Rule 199  ·  Rule 201 →

What this rule does

Sub-rule (1) requires an application for an advance ruling under section 383(1) to be made by a resident or a non-resident applicant in Form No. 120, verified in the manner indicated in it and in accordance with this rule.

Sub-rule (2) carries the Table of fees, graded by category and by the amount of the transaction or transactions for which the ruling is sought. For a ruling on the tax liability arising out of a transaction undertaken or proposed to be undertaken by a non-resident applicant under sub-clause (i) of section 380(a), or by a resident applicant under sub-clause (ii) of that clause, the fee is Rs. 200000 where the amount is less than one hundred crore rupees, Rs. 500000 where it is between one hundred crore rupees and three hundred crore rupees, and ten lakh rupees where it is more than three hundred crore rupees. For a ruling on the tax liability of a resident applicant arising out of a transaction undertaken or proposed to be undertaken by a resident applicant under section 380(a)(iii), the Table gives Rs. 500000 where the amount is between one hundred crore rupees and three hundred crore rupees and ten lakh rupees where it is more than three hundred crore rupees. For any other applicant the fee is Rs. 10000 in all cases.

Sub-rule (3) requires the application, the verification appended to it, the annexures and the accompanying statements and documents to be furnished electronically and signed or digitally signed. Where the applicant is a person required to furnish a return of income under the Act, they are to be signed by the person authorised to verify that return under section 265, and furnished electronically under digital signature if the return is required to be furnished under digital signature, and through electronic verification code in any other case. Where the applicant is not required to furnish a return, they are to be signed or digitally signed by a person duly authorised by the applicant for the purpose and holding a valid power of attorney, and may be furnished using digital signature or electronic verification code as specified by the Board.

Sub-rule (4) requires every application in the applicable Form to be accompanied by proof of payment of the fees specified in sub-rule (2).

Why it is there

Section 383 lets a person apply for an advance ruling but does not say in what form, on whose signature or at what price. The rule fixes the form, scales the fee to the size of the transaction and the category of applicant so that a ruling on a very large transaction costs more than one on a small matter, and settles the signature question separately for applicants who file returns and applicants who do not. Requiring proof of payment with the application keeps the fee from being an afterthought.

Who it applies to

• A non-resident applicant seeking a ruling under sub-clause (i) of section 380(a)
• A resident applicant seeking a ruling under sub-clause (ii) or sub-clause (iii) of section 380(a)
• Any other applicant, who pays the flat fee
• The person authorised under section 265 to verify the applicant's return of income
• A person holding a valid power of attorney, where the applicant is not required to furnish a return of income

The figures, and what each one turns on

The forms it prescribes

• Form No. 120 — application for obtaining an advance ruling under section 383(1), verified in the manner indicated in the form

What this means in practice

The fee is not a single figure and is not chosen by the applicant: it turns on the category under section 380(a) and on the amount of the transaction or transactions for which the ruling is sought, and the two upper brackets are the same for entries 1 and 2 of the Table. Entry 2 of the Table, for a resident applicant under section 380(a)(iii), states only the two brackets above one hundred crore rupees, so the Table as it stands gives no separate figure below that amount for that category. Signature is settled by whether the applicant files a return, not by seniority: where a return is required, the section 265 person signs and the mode follows that return's own signing requirement; where no return is required, a person holding a valid power of attorney signs. Everything is electronic — the application, the verification, the annexures and the accompanying documents — and under sub-rule (4) proof of payment of the fee must accompany the application, so an application filed while the fee is arranged separately is not complete.

An example

A non-resident company seeks a ruling on the tax liability arising out of a proposed transaction worth Rs 250 crore, falling under sub-clause (i) of section 380(a). Under Table Sl. No. 1 the amount lies between one hundred crore rupees and three hundred crore rupees, so the fee is Rs. 500000. Because the company is required to furnish a return of income, the application in Form No. 120 is signed by the person authorised to verify that return under section 265 and furnished electronically in the mode that return requires, with proof of payment of the fee attached as sub-rule (4) requires.

Where you meet this rule

An applicant meets it at the point of filing Form No. 120 electronically, and in the fee challan that must accompany it.

The words themselves

What people get wrong

• Paying the flat Rs. 10000. That is Table Sl. No. 3, for any other applicant, and does not apply where the application falls in entry 1 or 2.
• Fixing the fee by the applicant's size. The Table grades it by the amount of the transaction or transactions for which the ruling is sought.
• Filing without proof of payment. Sub-rule (4) requires every application to be accompanied by it.
• Having the application signed by a director or officer as a matter of course. Sub-rule (3)(a) requires the person authorised to verify the return under section 265 where the applicant is required to furnish a return.
• Signing on an informal authorisation where no return is required. Sub-rule (3)(b) requires a person duly authorised and holding a valid power of attorney.