Newsflash Key Changes in Income Tax Rules, 2026 vis-à-vis Income Tax Rules, 1962 - Transfer Pricing Aspects

We are pleased to share our Newsflash titled “Key Changes in Income-tax Rules, 2026 vis-à-vis Income-tax Rules, 1962 – Transfer Pricing Aspects.”
The Central Board of Direct Taxes (CBDT) has notified the Income-tax Rules, 2026, which are aligned with the Income-tax Act, 2025 and are set to come into force from 1 April 2026. These Rules introduce significant changes aimed at enhancing transparency, strengthening compliance requirements, and improving administrative efficiency in the transfer pricing framework.
This Newsflash provides an overview of the key changes, including:
•    Replacement of Form 3CEB with Form 48 and reporting requirements
•    Associated Enterprise (AE)-wise tabular reporting for international, deemed international and specified domestic transactions
•    Changes in Safe Harbour Rules, including revised margins, thresholds and introduction of new service categories
•    Modernisation of the Advance Pricing Agreement (APA) framework, including changes in forms, timelines and fee structure
•    Introduction of Block Transfer Pricing assessments and enhancements in Annual Compliance Reporting
We trust you will find this update insightful.

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