Form 47 Income Tax Rules 2026 pdf download and Key points
FORM NO. 47
[See rule 82(3)]
Certificate of an accountant under section 166
Under the Income-tax Rules, 2026, Form No. 47 is a newly introduced form (with no direct equivalent under the old 1961 rules) governed by Section 166(9) of the Income-tax Act, 2025, and Rule 82 of the Income-tax Rules, 2026.
Here are all the key points regarding Form No. 47:
1. Purpose of the Form Form 47 is a statutory certificate from an accountant that is strictly required to accompany Form No. 46. It officially certifies that the international transactions or specified domestic transactions of an assessee fulfill the specific conditions prescribed in Rule 82(5) for determining the Arm’s Length Price (ALP).
2. Applicability (Who Should File) The form must be filed by an Accountant who has examined the books of accounts and relevant documents of an assessee. It applies in cases where the assessee has exercised the option to determine the Arm’s Length Price for multiple years (three consecutive tax years) in a single proceeding under section 166(9).
3. Frequency and Due Date
- Linkage to Form 46: Form 47 cannot be filed in isolation; it must be furnished along with Form No. 46.
- Due Date: It must be submitted within the exact same window as Form 46—that is, within the period beginning from the end of the third tax year and ending on the 30th day of June succeeding the third tax year.
4. Key Certifications Made in the Form The form requires the accountant to examine the documents maintained under section 171 and explicitly certify the following points for the first (TY), second (TY+1), and third (TY+2) tax years:
- Jurisdiction: None of the Associated Enterprises involved in the transactions is a resident of a jurisdiction that has been notified under section 176.
- Contractual Terms: There has been no change in the contractual terms of the relevant transactions that explicitly or implicitly dictate how responsibilities, risks, and benefits are divided between the parties across the three years.
- Accuracy: The information given by the assessee in the accompanying Form No. 46 for all three tax years is accurate and bona fide.
5. Mode of Filing and Attachments
- Online Only: Form 47 can only be submitted electronically through the Income Tax e-Filing portal. Offline submission is not permitted.
- No Additional Documents: Unlike many other compliance forms, there are no additional physical documents required to be uploaded or filed alongside Form No. 47.