The CBDT had earlier (vide Notification No. 03/2022) mandated the electronic furnishing of Form 10F by non-resident taxpayers availing tax treaty benefits on their Indian incomes.

To comply with the above requirement, relevant taxpayers would have to create an account on the Indian Government’s income-tax portal, which in turn necessitated obtaining a PAN (tax ID) in India.

This requirement practically defeated the benefit available to non-resident taxpayers under the Indian income-tax law, whereby earning of certain types of incomes does not require furnishing of PAN to the payers and does not resulting in higher tax withholding.

In order to address the hardship caused by the above, the CBDT has now relaxed the mandatory e-filing of Form 10F upto 31 March 2023. Relevant taxpayers are however required to manually furnish Form 10F to the payers in India, in line with existing practices.

https://incometaxindia.gov.in/communications/notification/notification-e-filing.pdf