Form 52: Annual compliance report for an advance pricing agreement
Source checked 21 October 2026 · Original author: Finin2min Editorial Desk
Purpose, person and period
Annual compliance report for an advance pricing agreement.
A person covered by an APA furnishes the annual compliance report in Form 52, matching the agreement’s actual profit-level indicator and critical assumptions to the return adjustment.
Period gate: This numbered form belongs to the Income-tax Rules, 2026, effective 1 April 2026. The predecessor 3CEF is a concordance, not permission to change an earlier-year filing into a new-law form. For earlier periods, use the applicable 1961 Act form and saved procedure.
Controlling rule and source pages
Rule 113; . Physical PDF pp 460-464; printed Gazette pp 1992-1996.
Rule 113 — connected rule text
113. Furnishing of annual compliance report. — (1) The assessee shall furnish an annual compliance report to the Principal Chief Commissioner of Income-tax (International Taxation) for each year covered in the agreement. (2) The annual compliance report shall be in Form No. 52. (3) The assessee shall file the annual compliance report for each year covered in the agreement, within thirty days of the due date of filing the income -tax return for th at year, or within ninety days of entering into an agreement, whichever is later and send it to Principal Chief Commissioner of Income -tax (International Taxation). (4) The Principal Chief Commissioner of Income -tax (International Taxation) shall send one copy of annual compliance report to the competent authority of India, one copy to the Commissioner of Income -tax who has the jurisdiction over the income -tax assessment of the assessee and one copy to the Transfer Pricing Officer having the jurisdiction over the assessee.
Completed field illustration
Fictional data, not for filing. A hypothetical signed-APA scenario shows an annual cost-based reconciliation; the agreement itself is an assumption, not an issued document.
| Form field / block | Completed fictional entry |
|---|---|
| Part A: person / PAN / tax year | Example Software India Ltd / synthetic ZZZCE0000Z / 2027-28 |
| Row 8: APA application acknowledgement | MODEL-APA-052; not a real acknowledgement or agreement |
| Row 9: covered transaction | T-1 software-development services; cost-based 20% margin assumed for this model APA |
| Annexure A-1(1): A / B / C / D | Book operating expense Rs 1,00,00,000; additions nil; exclusions nil; adjusted OE Rs 1,00,00,000 |
| E / F / G / H | Book operating revenue Rs 1,15,00,000; APA addition Rs 5,00,000; exclusions nil; adjusted OR Rs 1,20,00,000 |
| I / J: APA profit / book profit | Rs 20,00,000 / Rs 15,00,000 |
| K / L / M: APA margin / book margin / variance | 20% / 15% / 5 percentage points |
| N / adjustment made in ITR | Rs 5,00,000 / Rs 5,00,000, hypothetical return entry |
| Annexure A-2: critical assumptions | Method, business, FAR, AE residence, invoicing and credit terms assumed unchanged and compliant |
| Annexure A-3 / verification | Model segmental ledger and APA-method working / NOT SIGNED |
This illustrates the named fields, not every possible schedule. Use the complete official extract for additional applicable fields, annexures and verification. “Not signed” means no professional certification or authority action has occurred.
Reconcile the example
- D = 1,00,00,000 + 0 - 0; H = 1,15,00,000 + 5,00,000 - 0.
- K-L = 20%-15% = 5%; N = 0.05 × 1,00,00,000 = 5,00,000. A percentage point figure must be divided by 100 when expressed numerically.
- The adjustment required and hypothetical ITR adjustment agree; it is reported once.
File a distinct compliance report for each covered year and each covered transaction as prescribed. This illustration does not establish that an APA exists, that an assumption is true or that a return was filed.
Prepare, furnish and retain
- Use the form identity and period above, then determine the person who prepares, issues or verifies it from Rule 113. An authority-issued order is not an applicant filing.
- Collect the records that support the actual fields in the example; keep any mandatory schedules and annexures specified in the complete source form.
- Reconcile dates, amounts, units and identifiers to the underlying records. Preserve the applicable rule version and any later correcting notification.
- Where the rule prescribes electronic furnishing, use the current official utility/schema and authorised verification. A local PDF does not produce a portal acknowledgement.
- Retain the submitted version, supporting schedules and actual acknowledgement or issued certificate/order, as applicable. This fictional model supplies none of those evidential outcomes.
Download the correct documents
Official Form 52 source extract Filled sample — fictional field illustration
The official extract preserves source pages; later amendments are supplied with affected forms. Read the April corrigendum where its printed-page corrections apply. The filled field illustration is an educational model and cannot be filed.
Primary sources
Questions readers ask
Does this sample prove approval, filing or a professional conclusion?
No. It completes the named fields using synthetic facts. It has no real signature, DSC, approval or acknowledgement.
Can I use the legacy form number for a current tax-year obligation?
Establish the governing period first. A predecessor number is a cross-reference; earlier-year procedures and current-year forms must be kept distinct.