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New CBDT rules may focus on risk-based cross-border RPTS
Business Standard
|February 09, 2026
The proposed overhaul of reporting requirements on transfer pricing is one of the most consequential changes in the Central Board of Direct Taxes' (CBDT's) recently released draft Income tax Rules and Forms, according to tax experts.
The revisions are being seen as a signal of a shift towards more targeted, risk-based scrutiny of cross-border related-party transactions (RPTs).
The CBDT has released draft “Income tax Rules and Forms” for public consultation ahead of the Income tax Act, 2025, coming into force on April 1.
The drafts have been uploaded on the e-filing portal and will remain open for stakeholder feedback until February 22, according to a government statement.
Notably, the draft rules significantly reduce delegated legislation, with their number proposed to be cut to 333 from 511, and the number of forms brought down to 190 from 399, following consolidation and removing redundancies.
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