Under rule 105 of the Income-tax Rules, 2026, what is the effect of a pre-filing consultation held with an eligible person who is considering an advance pricing agreement?

Rule 105(5) of the Income-tax Rules, 2026 says a pre-filing consultation does not bind the Board or the eligible person to enter into an agreement or to start the agreement process, and is not an application for an agreement. The formal application is a separate step under rule 106 in Form No. 51, so the consultation cannot itself count as one.