Report from an accountant to be furnished by persons entering into international transaction or specified domestic transaction

Section 172 — REPORT FROM AN ACCOUNTANT TO BE FURNISHED BY PERSONS ENTERING INTO INTERNATIONAL TRANSACTION OR SPECIFIED DOMESTIC TRANSACTION

Section 172 of the Income-tax Act, 2025 corresponds to s. 92E of the Income-tax Act, 1961.

STATUTORY ARCHITECTURE

Section 172 imposes a reporting obligation on every person who has entered into an international transaction or a specified domestic transaction during a tax year. Such a person must obtain a report from an accountant and furnish that report on or before the specified date. The report must be in the prescribed form, duly signed and verified by the accountant in the manner as may be prescribed, and must set forth such particulars as may be prescribed. The section is a single sentence with no sub-sections, and the trigger is simply having entered into a transaction of either kind during the tax year.

KEY ELEMENTS

• Person covered: every person who has entered into an international transaction or a specified domestic transaction during a tax year.
• Obligation (1): obtain a report from an accountant.
• Obligation (2): furnish the report on or before the specified date.
• Form: the report is to be in the prescribed form.
• Authentication: the report is to be duly signed and verified by the accountant in the manner as may be prescribed.
• Content: the report is to set forth such particulars as may be prescribed.

CHANGES FROM THE 1961 ACT

The corresponding provision is s. 92E of the 1961 Act. The two texts are substantively the same. The visible differences are terminological:

• "during a previous year" in s. 92E of the 1961 Act becomes "during a tax year".
• "verified in the prescribed manner" becomes "verified in the manner as may be prescribed".

The persons covered (those entering into an international transaction or specified domestic transaction), the requirement of a report from an accountant, the specified date, the prescribed form and the prescribed particulars all carry over unchanged.

PRACTITIONER NOTES

• The obligation is triggered by entering into even one international transaction or specified domestic transaction during the tax year; the section contains no monetary threshold.
• The section imposes two distinct obligations on the person: obtaining the accountant's report, and furnishing it by the specified date. Obtaining the report without furnishing it does not satisfy the section.
• The report must be signed and verified by the accountant, not by the person who entered into the transaction.
• The form, the manner of verification and the particulars are all left to be prescribed, so the prescribed form governs the content of the report.
• The obligation applies to "every person", so it is not limited to any class of assessee.

CROSS-REFERENCES

• The section names no other section of the 2025 Act. It uses the expressions "international transaction", "specified domestic transaction", "accountant" and "specified date", whose meanings are not stated in the section itself.
• s. 92E of the 1961 Act — the corresponding provision.