ICAI Seeks Public Comments on Revised Section 92E Transfer Pricing Guidance Note; Deadline September 5

The Institute of Chartered Accountants of India has opened a fresh consultation on its Guidance Note on Report under Section 92E of the Income-tax Act, 1961, a key professional reference for chartered accountants dealing with transfer-pricing reporting. ICAI’s International Taxation Committee issued the exposure draft on 21 August 2026 and has asked members and other stakeholders to send comments by 5 September 2026.

The exercise is intended to update the ninth edition of the Guidance Note, which ICAI issued in October 2022. According to the Institute, the revision is being undertaken to keep the publication current and relevant for members.

What ICAI has issued

ICAI has published an exposure draft incorporating proposed changes to the 2022 edition of the Guidance Note. The Institute has also provided a direct link to the draft document on its official resource server and a separate online form for submitting feedback.

The Guidance Note relates to the reporting obligation under Section 92E of the Income-tax Act, 1961, which is central to the compliance framework for specified international transactions and specified domestic transactions. For practising chartered accountants and transfer-pricing teams, the Guidance Note is an important interpretative and procedural reference when preparing and reviewing the accountant’s report and related disclosures.

What ICAI wants from respondents

ICAI has said comments may be submitted on any aspect of the exposure draft. It has specifically asked respondents to make their feedback precise and useful by identifying the paragraph or group of paragraphs to which the comment relates, providing a coherent rationale and suggesting a clear change.

The Institute has also invited respondents to supplement relevant paragraphs with judicial and regulatory material. ICAI states that comments may include relevant Supreme Court case law as well as circulars or notifications that could improve the revised Guidance Note.

Why the consultation matters for transfer-pricing professionals

A revision of the Section 92E Guidance Note can have practical implications beyond the text of the publication itself. Transfer-pricing reporting involves judgment around documentation, transaction classification, disclosures and the relationship between statutory requirements, rules, judicial developments and administrative guidance. An updated professional publication can therefore affect how practitioners approach reporting positions, working papers, review procedures and client communication.

For firms with active transfer-pricing practices, the consultation window is also an opportunity to flag areas where the existing 2022 guidance may no longer reflect later case law, circulars, notifications or recurring implementation issues seen in practice.

Deadline and action points

- Exposure draft date: 21 August 2026.

- Comment deadline: 5 September 2026.

- Who should consider responding: chartered accountants, transfer-pricing practitioners, tax teams, firms and other stakeholders with experience of Section 92E reporting.

- How to respond: ICAI has provided an online feedback form on the official announcement page.

Professionals planning to comment should review the exposure draft against recent case law and regulatory changes, identify specific paragraphs requiring revision and submit evidence-backed suggestions before the September 5 deadline.

ICAI is not merely seeking general views on transfer pricing; it is asking for paragraph-specific, reasoned feedback on a professional guidance document used in Section 92E reporting. Firms that regularly sign, review or advise on transfer-pricing reports should use the remaining consultation period to assess whether the proposed text addresses current practice issues and whether additional judicial or regulatory references should be incorporated.

Useful official links

ICAI: Exposure Draft - Guidance Note on Report under section 92E of the Income-tax Act, 1961

Key takeaway

The consultation directly affects chartered accountants handling transfer-pricing reporting and has a live September 5, 2026 response deadline.