Quick answer
What is Form 3CEB and who must file it?
Form 3CEB is the transfer pricing report under section 92E, signed by a practising chartered accountant, for anyone who entered into an international transaction or a specified domestic transaction during the year. For AY 2026-27 it is widely reported as due on 31 October 2026, with the return due on 30 November 2026.
- Report for FY 2025-26 still filed as Form 3CEB
- Becomes Form 48 from tax year 2026-27
- Any international transaction with an associated enterprise triggers it
- Must be prepared and signed by a practising CA
What is Form 3CEB in transfer pricing?
Form 3CEB is the report a chartered accountant gives on your dealings with associated enterprises, such as a foreign parent, a sister company abroad or, for specified domestic transactions, certain related Indian parties. It states each transaction, the method used to test the price and whether the price was at arm's length.
Transfer pricing rules exist so that profit is not shifted out of India by charging related parties too much or too little. Sections 92 to 92F of the 1961 Act set the rules, and section 92E requires the accountant's report. The taxpayer must also keep transfer pricing documentation, and the report relies on it.
Under the Income-tax Act 2025, section 172 takes the place of section 92E and the report is Form 48. The Income Tax Department's own file for the new form is titled "Form 48 (erstwhile Form 3CEB)".
Who needs a transfer pricing audit and Form 3CEB?
You need a transfer pricing audit and Form 3CEB if, during the year, you had any international transaction with an associated enterprise, or specified domestic transactions above the threshold. There is no rupee floor for international transactions: one small invoice to a group company abroad is enough.
| Situation | Form 3CEB needed? |
|---|---|
| Indian subsidiary buys goods or services from its foreign parent | Yes, international transaction |
| Indian company provides software or support services to a group company abroad | Yes |
| Loan, guarantee or interest paid to or received from a foreign associated enterprise | Yes |
| Royalty or management fee paid to a foreign group company | Yes |
| Reimbursement of expenses with a foreign associated enterprise | Yes, still an international transaction |
| Specified domestic transactions with related parties | Only if the aggregate exceeds ₹20 crore in the year (reported) |
| Trade only with unrelated foreign customers | No, not with an associated enterprise |
Thresholds as reported by TaxGuru (secondary), checked October 2026. Whether two parties are associated enterprises depends on section 92A tests on control and shareholding; confirm with your CA.
Need help with form 3CEB transfer pricing report? Talk to a chartered accountant in Delhi today. First call is free.
What is the Form 3CEB due date for AY 2026-27?
For FY 2025-26 (AY 2026-27), the Form 3CEB report is reported as due on 31 October 2026 and the income tax return for transfer pricing cases on 30 November 2026. CBDT Circular 07/2026 moved the general tax audit dates, but practitioners read it as not changing the transfer pricing dates.
Plan backwards from the report date: the study, the audited accounts and the tax audit report all need to be ready first. Our ITR due dates guide lists every return date for the year.
| Filing | Due date | Status |
|---|---|---|
| Form 3CEB (transfer pricing report) | 31 October 2026 | Not extended, per secondary sources |
| Tax audit report (Form 3CA/3CB with 3CD) | 21 October 2026 | Extended by CBDT Circular 07/2026 |
| Income tax return, transfer pricing cases | 30 November 2026 | No change announced |
| Income tax return, other audit cases | 21 November 2026 | Extended by CBDT Circular 07/2026 |
Sources: CBDT Circular 07/2026 dated 28 September 2026; transfer pricing dates from TaxGuru (secondary). Check the e-filing portal for any later order.
What changes for Form 3CEB under the Income-tax Act 2025?
For tax year 2026-27 onwards, Form 3CEB is replaced by Form 48 under section 172 of the Income-tax Act 2025. Reports for FY 2025-26 are still filed in Form 3CEB under the 1961 Act, even though they are uploaded after 1 April 2026.
Official guidance describes Form 48 in six parts, with separate parts for international transactions, specified domestic transactions and the arm's length price. Secondary sources map the rule from Rule 10E of the 1962 Rules to Rule 85 of the Income-tax Rules 2026. The underlying ideas, associated enterprise, arm's length price and the accepted methods, carry over.
Practical effect: next year your CA will work on a new utility and the notice wording will cite section 172, not 92E. Keep this year's working papers in a form that can be mapped to the new parts.
What documents does the CA need for Form 3CEB?
Your CA needs the transfer pricing study, intercompany agreements, a ledger-wise list of every transaction with each associated enterprise, invoices, the group structure and the audited financial statements. Without a documented benchmarking study, the CA cannot certify the arm's length price.
| Document | Used for |
|---|---|
| Group structure chart with shareholding percentages | Identifying associated enterprises |
| Intercompany agreements (services, loans, licences, cost sharing) | Terms and nature of each transaction |
| Ledger extract of all related party transactions for the year | Values reported in the form |
| Invoices, debit and credit notes with group entities | Testing amounts and dates |
| Transfer pricing study with benchmarking and method selected | Arm's length price conclusion |
| Audited financial statements and tax audit report | Reconciliation with the books |
| Form 15CA/15CB copies for remittances abroad | Cross-check of payments |
| Previous year's Form 3CEB and any assessment orders | Consistency and open issues |
How is Form 3CEB filed: step by step
Form 3CEB is filed online on the income tax e-filing portal. The taxpayer assigns the form to the CA, the CA uploads it with a digital signature, and the taxpayer then accepts it. The filing is complete only after that acceptance.
- 1
Prepare the study
Collect transaction data and complete the transfer pricing documentation and benchmarking before the year-end accounts are final.
- 2
Assign the CA on the portal
The taxpayer logs in and assigns Form 3CEB to the chartered accountant using the CA's membership number.
- 3
CA reviews and drafts
The CA tests each transaction, agrees figures to the books and drafts the report with the required particulars.
- 4
CA uploads with DSC
The CA uploads the form using a digital signature certificate registered on the portal and generates a UDIN.
- 5
Taxpayer accepts
The taxpayer reviews the uploaded report and accepts it. A company must use its digital signature.
- 6
File the return
File the income tax return by the transfer pricing due date, reporting the same transaction values.
What is the penalty for not filing Form 3CEB?
Failure to furnish the Form 3CEB report can attract a penalty of ₹1 lakh under section 271BA of the 1961 Act. The officer may waive it if you show reasonable cause under section 273B. Separate, larger penalties apply for failing to keep or produce transfer pricing documentation.
The bigger risk is an adjustment. If the officer refers your case to a transfer pricing officer and the price is found to be off arm's length, your income is increased and tax, interest and penalty follow. A clean report and a defendable study are the best protection. If you have already received a notice, see our income tax notice reply page.
Penalty amount as reported by TaxGuru (secondary source). Under the 2025 Act the penalty provisions are renumbered.
How do you choose a CA for a transfer pricing audit?
Choose a practising chartered accountant with transfer pricing experience in your type of transaction, verified on ICAI's CA Connect, who can finish the study well before the report date. Ask who will prepare the benchmarking and which databases they use.
- Verify membership and certificate of practice on ICAI CA Connect.
- Ask for a written engagement letter with scope, timeline and deliverables.
- Share last year's report and any transfer pricing order so open points are carried forward.
- Check that the CA will issue a UDIN for the report, as explained on our CA certificate page.
- Agree early on how intercompany invoices will be raised for the coming year.
Can CA in Delhi file my Form 3CEB?
No. Form 3CEB is attest work reserved for practising chartered accountants, and under ICAI's Code of Ethics 2026 CA firms cannot accept reserved work through aggregator listings. This page is information only, so there are no fees or bookings for this report.
Our directory of chartered accountant firms in Delhi is a factual listing, and the firms there can help with non-reserved work such as bookkeeping and intercompany invoicing. The tax audit page covers the related section 44AB report, and foreign-owned companies in the south of the city can read our CA in South Delhi page.
Frequently asked questions
What is the last date to file Form 3CEB for AY 2026-27?
Secondary sources put it at 31 October 2026, with the return for transfer pricing cases due on 30 November 2026. CBDT Circular 07/2026 extended only the general audit dates. Confirm on the e-filing portal in case a later order changes this.
Is there a minimum amount for Form 3CEB?
Not for international transactions with associated enterprises: any value triggers the report. Specified domestic transactions are covered only when their aggregate in the year exceeds ₹20 crore, as reported by practitioners.
What is the new form number for Form 3CEB?
Form 48 under section 172 of the Income-tax Act 2025, from tax year 2026-27. The FY 2025-26 report is still Form 3CEB.
Is a transfer pricing certificate the same as Form 3CEB?
In everyday use, yes. People call the Form 3CEB report a transfer pricing certificate because the CA certifies the particulars and the arm's length price. The legal name is the accountant's report under section 92E.
Can Form 3CEB be revised?
A revised report may be possible in limited cases, for example to correct errors, subject to the portal and rules. Discuss it with your CA before the return is filed, because the return should match the final report.
Does a start-up with a foreign parent need Form 3CEB?
Yes, if it has any transaction with the parent or another group company, including share-related reimbursements, cost recharges or loans. Many Delhi start-ups with foreign holding companies need the report even in loss years.
Who signs Form 3CEB?
A chartered accountant in practice signs and uploads it with a digital signature, and the taxpayer accepts it on the portal. The CA should also generate a UDIN for the report.
Is Form 3CEB needed if I filed a tax audit report?
Yes. The tax audit report under section 44AB and Form 3CEB are separate. A company with related party transactions abroad usually files both, along with the return.
What if I miss the Form 3CEB date?
File as soon as possible and keep evidence of the reason for delay. A penalty under section 271BA can be imposed, but section 273B allows relief for reasonable cause.