Form 3CEB Filing: Transfer Pricing Report by a Chartered Accountant

Form 3CEB is the report a chartered accountant gives under section 92E of the Income-tax Act, 1961 and Rule 10E. It lists every international transaction with an associated enterprise and every specified domestic transaction in the year, with the method used to test each one. The accountant also certifies whether the documentation required by Rule 10D has been kept.

It is filed on the income-tax e-filing portal by the accountant and then accepted by the taxpayer. It must be in before the return, because the return reports the Form 3CEB acknowledgement.

From tax year 2026-27 the report becomes Form 48 under section 172 of the Income-tax Act, 2025, as listed in the Income Tax Department's guidance on forms under the Income-tax Rules, 2026. FY 2025-26 is still reported in Form 3CEB.

Who must file Form 3CEB

• Any person with an international transaction with an associated enterprise during the year, whatever its value
• Any person with specified domestic transactions above ₹20 crore in aggregate
• It applies to companies, LLPs, firms and individuals alike, and whether the business made a profit or a loss
• Indian subsidiaries, branches and project offices of foreign groups are the most common filers

Due date

Form 3CEB is due one month before the due date of the return under section 139(1). For transfer pricing cases the return is due on 30 November, so Form 3CEB for FY 2025-26 is due on 31 October 2026, unless CBDT extends it. The TP study has to exist by the same date. Documentation put together after the report is filed is not contemporaneous. Our Form 3CEB due date guide has the full calendar and a last-ten-days checklist.

What the form contains

• Part A: details of the taxpayer and of each associated enterprise, with the nature of the relationship
• Part B: each international transaction by type, with the value as per books, the value as computed, and the method used
• Part C: specified domestic transactions, in the same format
• The accountant's opinion on whether documentation under Rule 10D has been kept and whether the particulars are true and correct

Transactions that must be reported

Purchase and sale of goods or fixed assets; services rendered and received; royalties, licence fees and other intangibles; loans, interest and guarantees; cost-sharing and reimbursements; capital financing such as share issues; business restructuring; and deemed international transactions with third parties whose terms an associated enterprise decided. Transactions with no consideration are reported too.

Common mistakes we fix

• Group companies left out because they are not in the related party note
• Values that do not match the audited accounts or the remittances in Form 15CA
• Reimbursements and free services or loans not reported
• A method stated in the form that is different from the one in the TP study
• Deemed international transactions missed

Penalties

Not furnishing Form 3CEB attracts a penalty of ₹1,00,000 under section 271BA. Missing documentation can cost 2% of the transaction value under section 271AA, and failing to report an international transaction is misreporting under section 270A, with a penalty of 200% of the tax on the adjustment.

If your transactions need full documentation, see our transfer pricing services for the TP study and benchmarking, or master file and CbC filing if you belong to an international group.