Transfer pricing cases: Form 3CEB, ITR and master file by 30 November 2026

Transfer pricing rules make sure that prices charged between related entities – an Indian subsidiary and its foreign parent, or two group units enjoying different tax benefits – are at arm's length. Taxpayers covered by these rules file an accountant's report in Form 3CEB under Section 92E of the Income-tax Act, 1961, and get one extra month to file their return.

In September 2026 the CBDT extended the tax audit report date to 21 October 2026 and the return date for audit cases to 21 November 2026. That extension did not cover transfer pricing cases. For them, FY 2025-26 (AY 2026-27) dates stay as they were.

Due dates for FY 2025-26

Other audit cases – companies and firms without TP transactions – have until 21 November 2026. See our tax audit guide for those dates.

Who must file Form 3CEB

• International transactions with an associated enterprise: any value. Purchase or sale of goods, services, royalty, interest on group loans, guarantees, cost recharges and share issues to a foreign parent can all be covered.
• Specified domestic transactions (Section 92BA): only when their aggregate value in the year exceeds ₹20 crore – for example, transactions between units where one claims a profit-linked deduction.
• Associated enterprise: broadly, entities linked through control, management or capital – a parent, subsidiary or fellow subsidiary. The tests in Section 92A should be checked for each relationship.
• Who signs: a chartered accountant certifies Form 3CEB; the taxpayer approves it on the e-filing portal before it is treated as filed.

Master file thresholds

• Part A of Form 3CEAA: every constituent entity of an international group.
• Part B (full master file): where consolidated group revenue exceeds ₹500 crore and either international transactions exceed ₹50 crore or transactions in intangibles exceed ₹10 crore.
• More than one Indian entity: the group designates one entity to file and intimates it in Form 3CEAB (due 31 October 2026).

Penalties

Example: an Indian subsidiary pays ₹3 crore to its foreign parent for software support but has no benchmarking study. The documentation penalty alone can be 2% × ₹3,00,00,000 = ₹6,00,000 – before any adjustment to the price itself. Late filing of the return also brings interest under Section 234A and the fee under Section 234F.

If Form 3CEB is still pending

• File Form 3CEB now, before the return. A return filed without the required report invites a defect notice.
• Keep the documentation under Rule 10D ready – functional analysis, comparable search and the method chosen (TNMM, CUP, cost plus and so on).
• Match the transactions in Form 3CEB with the financial statements and the tax audit report (Form 3CD).
• Pay balance tax as self-assessment tax and file the return by 30 November 2026. A belated return can be filed up to 31 December 2026, but with fee and interest and loss of carry-forward of most losses – see our guide to belated and revised returns.

Common errors in Form 3CEB

• Missing transactions: reimbursements of expenses, cost allocations, corporate guarantees and outstanding receivables from group entities are often left out because no invoice was raised.
• Wrong associated enterprise details: the name, address and nature of relationship should match group records and the financial statements.
• Values that do not tie: amounts in Form 3CEB should reconcile with the books, the related party note in the accounts and Form 3CD; differences are a common reason for scrutiny.
• Method without support: the most appropriate method stated in the report should be backed by the comparable analysis kept on file.
• Not approving on the portal: the report is filed only after the taxpayer accepts it in the e-filing account.

A careful review of these points before filing saves time if the case is later picked up for transfer pricing assessment.

From Tax Year 2026-27: the new Act

The Income-tax Act, 2025 applies from 1 April 2026. Transfer pricing continues with new section numbers, and the accountant's report becomes Form No. 48. FY 2025-26 reports and returns are still filed under the 1961 Act. For the wider picture, read what has changed under the new Income-tax Act.

How we help

We support Indian subsidiaries, branch offices and NRI-owned businesses with Form 3CEB, transfer pricing documentation and return filing. See our services for NRIs and foreign companies doing business in India and tax and statutory audit.

General information as on 10 November 2026, based on the Income-tax Act, 1961 and the CBDT's September 2026 extension for audit cases. Facts of each case differ; check the current position on the e-filing portal or take professional advice before you act.

Frequently asked questions