Income-tax Rules, 2026 | Rule 115 of 333

Rule 115 - Revision of an agreement

Reviewed by CA Nikhil Gupta · Last reviewed 29 August 2026

Local extract available Legacy mapping: 10Q

115Rule number

1664Local text characters

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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

Revision of an agreement. 115. (1) An agreement, subsequent to it having been entered into, may be revised by the Board, if— (a) there is a change in critical assumptions or failure to meet a condition subject to which the agreement has been entered into; or (b) there is a change in law that modifies any matter covered by the agreement but is not of the nature which renders the agreement to be non-binding; or (c) there is a request from the competent authority of the other country requesting revision of the agreement, in case of a bilateral or multilateral agreement. (2) An agreement may be revised by the Board, either suo motu, or on request of the assessee, or the competent authority of India, or the Principal Chief Commissioner of Income-tax (International Taxation). (3) Except when the agreement is proposed to be revised on the request of the assessee, the agreement shall not be revised unless an opportunity of being heard has been provided to the assessee and the assessee is in agreement with the proposed revision. (4) In case the assessee is not in agreement with the proposed revision, the agreement may be cancelled in accordance with rule 116. (5) In case the Board is not in agreement with the request of the assessee for revision of the agreement, the Board shall reject the request in writing giving reason for such rejection. (6) For the purpose of arriving at the agreement for the proposed revision, the procedure provided in rule 109 may be followed, so far as they apply. (7) The revised agreement shall include the date till which the original agreement is to apply and the date from which the revised agreement is to apply.

Local extract SHA-256: 2e337c73cac3c1add6d6e117b18c2be74b97e7f9b7adb8b9197b6b1cc726aeba. This hash authenticates the local extract only; it does not certify that every amendment, table or Gazette footnote has been consolidated.

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Related sections

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Finin2min implementation framework

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Evidence and control

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Consequence

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Transaction application

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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

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Cross-law overlays

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Finin2min Q&A

Is this page the notified Rule?

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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.

Source and review trail

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Official starting point: www.incometaxindia.gov.in

Page source links

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