Section 286 of the Income-tax Act, 1961, mandates the furnishing of a Country-by-Country (CbC) report by multinational enterprises (MNEs) that are part of an international group. This section applies to Indian entities that are the ultimate parent entity or the alternate reporting entity of an international group with a consolidated revenue exceeding a specified threshold, currently set at INR 5,500 crore. The CbC report is a compliance requirement under the Base Erosion and Profit Shifting (BEPS) Action Plan 13, aimed at enhancing transparency in tax matters. The report must include aggregate information relating to the global allocation of income, taxes paid, and certain indicators of the location of economic activity among tax jurisdictions in which the group operates. The burden of proof lies with the reporting entity to ensure the accuracy and completeness of the information provided. This section is significant as it helps tax authorities assess transfer pricing risks and other BEPS-related risks.