Skip to main contentSkip to content
Income-tax Rules, 2026 | Rule 111 of 333

Rule 111 - Rollback of agreement

Reviewed by CA Nikhil Gupta · Last reviewed 29 August 2026

Local extract available Legacy mapping: 10MA

111Rule number
2394Local text characters
1Linked Forms

Previous Rule · Rules index · Next Rule

Source and status control

Primary authority: Notification No. 22/2026 / G.S.R. 198(E)

Currentness control: Base Rules effective 1 April 2026. Check later amendments, corrigenda and portal implementation before action.

Local statutory extract - official source controls

Rule text held in the production corpus

Roll back of agreement. 111. (1) Subject to the provisions of this rule, the agreement may provide for determining the arm's length price in relation to an international transaction, or specify the manner in which such arm's length price shall be determined during the rollback year (the rollback provision). (2) The rollback provision shall be subject to the following— (a) the international transaction is same as the international transaction to which the agreement (other than the rollback provision) applies; (b) the return of income for the relevant rollback year has been or is furnished by the applicant within the time specified in section 263(1)(c); (c) the report in respect of the international transaction had been furnished within the time specified in clause (b); (d) the applicability of the rollback provision, in respect of an international transaction, has been requested by the applicant for all the rollback years in which the said international transaction has been undertaken by the applicant; and (e) the application seeking rollback in Form No. 51 has been made in accordance with sub-rule (5). (3) Irrespective of anything contained in sub-rule (2), the rollback provision shall not be provided in respect of an international transaction for a rollback year, if— (a) the determination of arm's length price of the said international transaction for the said year has been subject matter of an appeal before the Appellate Tribunal and the Appellate Tribunal has passed an order disposing of such appeal at any time before signing of the agreement; or (b) the application of the rollback provision has the effect of reducing the total income or increasing the loss, as the case may be, of the applicant as declared in the return of income of the said year. (4) Where the rollback provision specifies the manner in which the arm's length price shall be determined in any rollback year, then such manner shall be the same as the manner which has been agreed to be provided for determination of arm's length price of the same international transaction to be undertaken in any tax year to which the agreement applies, not being a rollback year. (5) The applicant may, if he desires to enter into an agreement with a rollback provision, furnish along with the application the request for the same in Form No. 51 with proof of payment of an additional fee of Rs. 5,00,000.

Local extract SHA-256: 7235490b24a6748faa7a8b7850846941898e8150dd21d14300f769d094848c20. This hash authenticates the local extract only; it does not certify that every amendment, table or Gazette footnote has been consolidated.

Rule map

Related sections

Use the title and official text to identify the governing section; no local section reference is asserted.

Related Forms

Form 51

Finin2min implementation framework

Trigger and scope

Determine whether the facts fall within the Rule heading and linked section. Verify commencement and the tax year involved.

Evidence and control

Preserve the return, statement, report, certificate, computation, source records and acknowledgement relevant to this Rule.

Consequence

Non-compliance may affect computation, exemption, deduction, procedural validity, reporting, recovery, appeal or penalty depending on the governing section.

Transaction application

Identify the actor, event date, governing tax year or reporting period, authority, document version and every cumulative condition. Record why each limb is satisfied, disputed or not applicable.

Authority, consent and execution

Confirm legal capacity, authorised signatory, digital-signature requirements, professional certification and portal credentials before filing or relying on the document.

Evidence and retention checklist

Retain source data, approvals, computations, correspondence, filing acknowledgement, payment record, amended filing history and the version of the governing instrument used.

Limitation, forum and remedies

Do not assume a general limitation period. Check the specific Act, Rule, notification, portal window, condonation power, appeal route and judicial treatment applicable to the event date.

Cross-law overlays

Check the Income-tax Act, 2025, transition rules, relevant Schedule, tax treaty, Companies Act, GST, FEMA and accounting treatment where the transaction crosses regimes.

Finin2min Q&A

Is this page the notified Rule?

It contains a local statutory extract, but the linked official source and later amendments control.

What should be verified immediately before use?

Effective date, amendment history, forms or utilities, filing channel, authentication method, due date, fees, transition from the 1962 Rules and any judicial interpretation.

Finin2min | Income-tax Rules, 2026 | Educational and professional reference. The current official law, Gazette, portal and judicial treatment control.

Source and review trail

Use the current official instrument, portal or regulator publication before acting. This panel separates the category authority from page-specific references.

Official starting point
www.incometaxindia.gov.in

Page source links