Section 286 implements country-by-country reporting for international groups. Every constituent entity resident in India of an international group whose parent entity is not resident in India must notify the prescribed authority whether it is the alternate reporting entity, or give details of the parent or alternate reporting entity and their country of residence. Every parent entity or alternate reporting entity resident in India must furnish, for every reporting accounting year, a report within twelve months from the end of that year.
The report gives, for each country or territory, aggregate revenue, profit or loss before income-tax, income-tax paid and accrued, stated capital, accumulated earnings, number of employees and tangible assets other than cash, together with details and main activities of each constituent entity. An Indian constituent entity of a foreign-parented group must itself furnish the report where the parent is not obliged to file, where India has no agreement for exchange of the report with the parent's country, or where a systemic failure of that country has been intimated to it. The section does not apply where the consolidated group revenue of the preceding accounting year does not exceed the prescribed amount.
Operative consequences
Where more than one Indian constituent entity exists, one designated entity may file for all, if this is conveyed in writing to the prescribed authority.
The secondary filing obligation is displaced where an alternate reporting entity files in its country of residence and the conditions in sub-section (5) are met.
The prescribed authority may call for information and documents within thirty days, extendable by a further thirty days on application.
Under s. 271GB, non-filing attracts five thousand rupees a day for the first month and fifteen thousand rupees a day thereafter; failure to respond to the notice attracts five thousand rupees a day; continuing failure after a penalty order attracts fifty thousand rupees a day.
Inaccurate information in the report attracts a penalty of five lakh rupees under section 271GB(4) in the cases listed there.
Status
Section 286 is operative for assessment year 2026-27. It is not time-limited. The Finance Act, 2026 did not amend this section.
The 1961 Act governs assessment year 2026-27 and earlier; the Income-tax Act, 2025 governs tax year 2026-27 onwards. For this subject the 2025 Act provision is s. 511.
Function in the statutory architecture
Section 286 implements country-by-country reporting for international groups. Every constituent entity resident in India of an international group whose parent entity is not resident in India must notify the prescribed authority whether it is the alternate reporting entity, or give details of the parent or alternate reporting entity and their country of residence. Every parent entity or alternate reporting entity resident in India must furnish, for every reporting accounting year, a report within twelve months from the end of that year.
The report gives, for each country or territory, aggregate revenue, profit or loss before income-tax, income-tax paid and accrued, stated capital, accumulated earnings, number of employees and tangible assets other than cash, together with details and main activities of each constituent entity. An Indian constituent entity of a foreign-parented group must itself furnish the report where the parent is not obliged to file, where India has no agreement for exchange of the report with the parent's country, or where a systemic failure of that country has been intimated to it. The section does not apply where the consolidated group revenue of the preceding accounting year does not exceed the prescribed amount.
Operative consequences
Status
Section 286 is operative for assessment year 2026-27. It is not time-limited. The Finance Act, 2026 did not amend this section.
The 1961 Act governs assessment year 2026-27 and earlier; the Income-tax Act, 2025 governs tax year 2026-27 onwards. For this subject the 2025 Act provision is s. 511.