Section 92F: The Documentation Thresholds (1 Crore and Related)

Section 92F of the Income-tax Act, 1961 is the group-level rung of the Indian documentation-thresholds ladder: the provision that puts the country-by-country reporting (CbCR) duty on the MNE group. Where the group’s consolidated revenue is ₹1,000 crore or more, the relevant entity must prepare and maintain the per-jurisdiction report of the group’s allocation of income, tax and economic activity — the CbCR — with the filing mechanics running through the Rule 10E family. Around it, the documentation thresholds form a ladder the TP team runs every year: the base documentation duty at the 1 crore line, the contemporaneous Local File at the ₹300 million line, and the group-level reports at the ₹1,000 crore line.

What the provision says

In plain English, section 92F says: the group above the line reports the allocation. The MNE group with consolidated revenue of ₹1,000 crore or more reports, for each jurisdiction, the per-jurisdiction data — the revenues (external and related-party), the profit before tax, the income tax paid and currently due, the employees, the tangible assets. The duty runs on the group’s consolidated revenue (the preceding financial year), and it is discharged at the group level: prepared by the ultimate parent entity (or the surrogate parent entity, or the head office of the group in India, where the CbCR is prepared in India), and reaching the other jurisdictions by the exchange of information between competent authorities — the mechanics in the Rule 10E reference and the CbCR guide.

The thresholds ladder

The line	What it governs	The obligation
1 crore — the base line	The entity’s international and specified domestic transactions in the year	The base documentation duty under section 92D — the documents and information that substantiate that the price is at arm’s length — and the accountant’s report (the Form 3CEB) that rides with the return of income
₹300 million (₹30 crore) — the local file line	The same transactions, at the aggregate-value test	The contemporaneous Local File under Rule 10D — prepared within 30 days of the financial year end (by 31 May), maintained for 8 years, produced on the section 282BC notice
₹1,000 crore — the group line	The MNE group’s consolidated revenue (preceding FY)	The CbCR under section 92F (the Rule 10E family — the Form 3CEB / 3CEBA filings) and the Master File under Rule 10DA, maintained by the relevant entity and available on request

The operative requirements

Element	Requirement
The section 92F duty	The MNE group with consolidated revenue of ₹1,000 crore or more reports the allocation of income, tax and economic activity across jurisdictions, per jurisdiction
The relevant entity	The UPE resident in India, else the surrogate parent entity, else the head office of the group in India — the preparer hierarchy that decides who discharges the duty in India
The per-jurisdiction data	The revenues (external and related-party), the profit before tax, the income tax paid, the income tax currently due, the employees, the tangible assets — the CbCR’s standard data set
The constituent’s statement	Where the CbCR is prepared outside India, the Indian constituent entity files the Form 3CEBA (its particulars) with its return — the full report reaches India by exchange
The threshold test	Annual, on the group’s consolidated revenue for the preceding financial year — the crossing year is the year the duty attaches
The base line (1 crore)	The section 92D documentation duty and the Form 3CEB accountant’s report — the entity-level line below the local file line

Key excerpts (the provision’s core, framed)

• The duty in one line: the MNE group with consolidated revenue of ₹1,000 crore or more reports its allocation of income, tax and economic activity across jurisdictions — the group-level documentation threshold, the top rung of the ladder.
• The preparer, not the filer-each: the CbCR is prepared once, at the group level, and reaches the other jurisdictions by exchange — the provision’s design against the ten-jurisdiction filing, and the reason the constituent’s role is the 3CEBA statement, not the full report.
• The same threshold family: the ₹1,000 crore group line governs the CbCR and the Master File together — the group that crosses it carries both group-level documents, on shared segment and country data.

What it means in practice

• The threshold test is the annual first check. Year by year: the entity’s transaction value against the local file line, the group’s consolidated revenue against the ₹1,000 crore line — the duties that attach, and the crossing year that carries the first file. The compliance calendar carries the rows and the dates; the documentation threshold glossary carries the entity-vs- group distinction.
• The entity and the group thresholds are independent. An entity below the local file line can sit inside a group above the group line (the group carries the Master File and the CbCR; the entity carries the 3CEBA statement), and a large entity can sit inside a group below the group line (the entity carries the Local File; the group does not). The tests run separately, on different measures.
• Three documents, one data set. The CbCR rows, the 3CEBA particulars and the Local File / Master File breakdowns are the same group data in three documents — the reconciliation across them is the data-quality discipline, and the row that differs across the three is the scrutiny trigger. The CbCR guide carries the risk treatment; the shared €750 mn / ₹1,000 cr threshold family also feeds the Pillar Two computation, which doubles the data-quality stakes for the in-scope group.
• The threshold gates the duty, not the examination. Below the lines, the in-scope transaction is still priced at arm’s length and examinable under section 92 — the thresholds gate the prepared file, not the pricing rule. The sub-threshold entity is examined on its facts, without the file obligation.

Related docs

• Rule 10E — the CbCR mechanics
• Documentation threshold — the triggers glossary
• CbCR guide — thresholds, filing, data quality
• Section 92 — the controlled transactions provision