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Form 3CEB Filing Guide: Clause-wise Requirements & the 31 October Deadline
This Form 3CEB filing guide covers Form 3CEB, the accountant’s report under Section 92E of the Income-tax Act, 1961, required for taxpayers who enter into international transactions, deemed international transactions or specified domestic transactions covered by the transfer pricing provisions. For FY 2025-26, the report is due by 31 October 2026 and the income tax return due date is 30 November 2026.
Key Takeaways
- Form 3CEB is the accountant’s report required under Section 92E for transfer pricing transactions.
- For FY 2025-26, Form 3CEB is due by 31 October 2026 where the ITR due date in this case is 30 November 2026. The CBDT extension announced on 28 September 2026 (tax audit report to 21 October 2026 and ITR to 21 November 2026) covers non-transfer-pricing audit cases only and hence does not change these dates.
- International transactions have no minimum threshold for Section 92E reporting but specified domestic transactions are subject to the applicable ₹20 crore threshold.
- Form 3CEB contains 26 clauses with Parts A, B and C, covering basic details about assesse, list of associated enterprises, description of transactions, amount involved in international transactions and specified domestic transactions, method of calculating arm’s length price.
- Failure to furnish Form 3CEB can attract a ₹1,00,000 penalty under Section 271BA, although relief under Section 273B is available for reasonable-cause.
- From Tax Year 2026-27, the accountant’s report for transfer-pricing transactions is prescribed in Form 48 under the Income-tax Act, 2025. For FY 2025-26 (AY 2026-27), the existing Form 3CEB framework continues to apply.
- Form 48 default: From Tax Year 2026-27, failure to furnish the accountant’s report attracts a time-graded fee under Section 428(d) of the Income-tax Act, 2025 (₹50,000 for a delay up to one month; ₹1,00,000 thereafter) in place of the earlier penalty.
1. What is Form 3CEB?
Form 3CEB is a report from an accountant required under Section 92E for international transactions and specified domestic transactions.
The report is furnished by an accountant after examining the assessee’s accounts, records and information provided.
In this report the accountant has to give opinion whether ‘proper information and documents as are prescribed’ have been kept by the assesse in respect of the international transactions and specified domestic transactions entered into by him.
Source: Official Form 3CEB & Rule 10E of the Income-tax Rule, 1962
2. Who is the accountant for Form 3CEB?
Section 92F read with explanation to section 288(2) defines who will be the ‘accountant’ for the purpose of Form 3CEB. An accountant means a Chartered accountant registered under Chartered accountants act, 1949 and having a valid certificate of practice.
However, it excludes certain persons: in the case of a company, a person not eligible for appointment as its auditor under Section 141(3) of the Companies Act, 2013; and in other cases, the assessee itself, its partners/members, relatives and employees, among others.
For Form 48, “accountant” is defined in Section 2(1) read with Section 515(3)(b) of the Income-tax Act, 2025.
Source: Section 288 of the Income-tax Act, 1961
3. Who Needs to File Form 3CEB?
Any person entering into an international transaction (Section 92B) with an associated enterprise, or a deemed international transaction under Section 92B(2), must obtain the accountant’s report under Section 92E. This may include a company, LLP, partnership firm, individual, AOP or other person.
There is no minimum threshold for international transactions. So, even a ₹1,000 software licence fee paid to an AE must be reported mandatorily.
Form 3CEB also applies where the assesseeenters into a specified domestic transaction (SDT) (Section 92BA) exceeding ₹20 crore in a financial year.
Source: Section 92E of the Income-tax Act, 1961
4. What Kind of Transactions Require Form 3CEB Filing?
Any assessee who enters into international transactions, deemed international transactions or specified domestic transactions as per Income tax law must furnish Form 3CEB.
International transactions include any transaction between two or more Associated Enterprises (where at least one party is a non-resident) involving:
- Purchase, sale, lease or transfer of tangible property
- Purchase, sale, lease or transfer of intangible property
- Provision or receipt of services
- Financing transactions
- Loans and advances
- Guarantees
- Cost-sharing or allocation arrangements,
- Business restructuring or reorganization
- Any other Transaction having a bearing on the profits, income, losses or assets
The precise classification depends on the facts of the transactions.
Deemed International Transactions (DIT)
Section 92B (2) extends transfer pricing provisions to transactions entered between resident assesse and an unrelated third party. This happens in following cases:
- where there was a prior agreement between that third person and a non-resident Associated Enterprise (AE) of such resident taxpayer.
- When the non resident associated enterprise decides the terms of the contract.
These deemed transactions must also be reported in Form 3CEB regardless of value.
Specified domestic transactions
SDTs covered under Section 92BA are subject to ₹20 crore aggregate threshold.
These comprise:
(i) inter-unit transfers of goods or services between an eligible undertaking of the taxpayer as per Sections 80A(6), 80-IA(8) or 10AA and its other businesses;
(ii) business transacted with closely connected persons that produces more than ordinary profits to an eligible business under Section 80-IA(10) or 10AA, or to a person opting for the concessional tax regime under Section 115BAB(6) or 115BAE(4).
Sections 115BAB and 115BAE are concessional tax-rate regimes, not tax exemptions.
Businesses should know about Smart Transfer Pricing Strategies for Business Growth.
5. Form 3CEB Due Date for FY 2025-26
Form 3CEB must be furnished on or before the specified date as per Section 92E.
The Income Tax Department explains the meaning of the specified date under Section 92F (iv) as one month before the Section 139(1) return due date. Therefore, the Form 3CEB deadline is 31 October 2026 for taxpayers whose transfer-pricing income tax return is due on 30 November 2026.
Hence, the assessee must formally furnish the Form 3CEB report on or before 31 October.
FY 2025-26 TP compliance timeline
| Compliance | TP Due date for FY 2025-26(AY 2026-27) |
| Form 3CA/3CB-3CD -Tax audit report under Section 44AB (where Section 92E report is required) | 31 October 2026 |
| Form 3CEB | 31 October 2026 |
| Income-tax return | 30 November 2026 |
The income tax compliance dates should always be checked again for any extension issued by the Government. For AY 2026-27, the CBDT press release dated 28 September 2026 extended the tax audit report and ITR due dates only for non-transfer-pricing audit cases (to 21 October 2026 and 21 November 2026 respectively); the transfer-pricing dates above remain unchanged unless separately notified.
Source: Section 92F of the Income-tax Act, 1961
6. Form 3CEB vs Form 48: Which Form Applies?
The transfer pricing report depends on the year being reported.
Form 3CEB continues to apply to FY 2025-26 (AY 2026-27) because that year remains ruled by the Income-tax Act, 1961. For Tax Year 2026-27, the TP accountant’s report is Form 48, prescribed under Section 172 of the Income-tax Act, 2025 read with Rule 85 of the Income-tax Rules, 2026.
Form 48 is the successor to Form 3CEB.
FY 2025-26 reports furnished after 1 April 2026 continue to be governed by the Income-tax Act, 1961 by virtue of the repeal and savings provisions in Section 536 of the Income-tax Act, 2025. This should be cited when advising on late-filing exposure under Section 271BA.
| Basis | Form 3CEB | Form 48 |
| Applicable period | FY 2025-26 (AY 2026-27) and earlier periods under 1961 Act | Tax Year 2026-27 onwards |
| Legal provision | Section 92E(Income-tax Act, 1961) & Rule 10E (Income-tax Rules, 1962) | Section 172 (Income-tax Act, 2025) & Rule 85 (Income-tax Rules, 2026) |
| Clauses Structure | 26 reporting clauses in its annexure:Clauses 1-9 in Part AClauses 10-20 in Part BClauses 21-26 in Part C | Six reporting parts (A-F) in Form 48:1. Part A – Particulars of the assessee 2. Part B – Aggregate amount of international transactions and SDTs (auto-populated from Parts C and D)3. Part C – International transactions including DIT4. Part D – Specified domestic transactions5. Part E – Determination of arm’s length price 6. Part F – Documentation information where transaction value exceeds the specified amount |
| Due date linkage | One month before the due date of return under Section 139(1) (For FY 2025-26 it is 31 October 2026 since ITR is due on 30 November 2026) | At least one month before the due date of return under Section 263(1)(c) of the Income-tax Act, 2025 |
| Consequence of default | Penalty of ₹1,00,000 under Section 271BA; reasonable-cause relief under Section 273B | Fee under Section 428(d) (Section 447 penalty omitted by Finance Act, 2026): ₹50,000 for delay up to one month; ₹1,00,000 thereafter. Reasonable-cause relief under Section 470 covers penalties, so relief against the fee is doubtful |
| “Accountant” | Explanation to Section 288(2), Income-tax Act, 1961 (via Section 92F) | Section 2(1) read with Section 515(3)(b), Income-tax Act, 2025 |
| Companion tax audit report | Form 3CA/3CB-3CD | Form 26 |
| First / current due date | 31 October 2026 (FY 2025-26) | 31 October 2027 for Tax Year 2026-27 (subject to notified due dates) |
Source: Income tax Department – The Simplified Tax Form Series Form 48
7. What is an Associated Enterprise?
An Associated Enterprise (AE) is an enterprise that has a direct or indirect relationship with another enterprise through participation in management, control or capital, or where specified conditions such as 26% voting power, loans, guarantees, board control or other prescribed conditions are fulfilled as per Section 92A(2).
Source: Section 92A(2) of the Income-tax Act, 1961
8. ALP Methods under Section 92C
Arm’s Length Price (ALP) method must be reported for each transaction in Form 3CEB along with arm’s-length value. Section 92C read with Rule 10B prescribes six methods for calculating ALP. The Most Appropriate Method (MAM) is selected based on the nature of the transaction and the functions performed, along with other relevant factors.
| ALP Method | Method Explanation |
| Comparable Uncontrolled Price (CUP) | Compares the price charged in a controlled transaction with the price charged in a comparable uncontrolled transaction under similar conditions. |
| Resale Price Method(RPM) | Considers resale price to an independent customer and works backward by deducting an appropriate gross margin and expenses. |
| Cost Plus Method(CPM) | Cost incurred plus an appropriate mark-up. |
| Transactional Net Margin Method(TNMM) | Compares net profit margin derived from controlled transaction with comparable uncontrolled transactions. |
| Profit Split Method(PSM) | Used for highly integrated transactions or those involving unique intangibles; the combined profit is split based on each enterprise’s relative contribution (contribution or residual analysis). |
| Other Method Rule 10AB | Uses another prescribed approach based on the price charged or that would have been charged in a comparable uncontrolled transaction under similar circumstances. |
Source: Section 92C & Rule 10B & Rule 10AB
9. Clause-wise Requirements of Form 3CEB
The following table gives clause-wise reporting of Form 3CEB including what each clause covers and the information required to be reported.
| Clause | Part | Clause Name | Details to report |
| 1 | A | Name of the assessee | Name along with branch name if examination is in respect of the branch |
| 2 | A | Address | Address same as communicated to Income tax departmentAlso report the Registered address of the company |
| 3 | A | PAN or Aadhaar | PAN or Aadhaar number |
| 4 | A | Nature of business/activity | Business/activity code and description |
| 5 | A | Status | State the type of person as per Section 2 (31) of the Income-tax Act, 1961 |
| 6 | A | Previous year | Previous year ended 31 March |
| 7 | A | Assessment year | Relevant AY |
| 8 | A | International transactions | Aggregate value as per books |
| 9 | A | Specified domestic transactions | Aggregate value as per books |
| 10 | B | Associated enterprises | AE, relationship and business description |
| 11 | B | Tangible property | Description of Goods/property, quantity, AE, book value, ALP, method of determining ALP |
| 12 | B | Intangible property | Description of Intangible, nature of transaction, amount as per books and ALP, ALP method |
| 13 | B | Services | Service description, AE, amount, ALP method |
| 14 | B | Lending/borrowing | AE, nature of Financing arrangement, currency, interest rate, amount as per book and ALP, ALP method |
| 15 | B | Guarantees | AE, nature of Guarantee arrangement, currency, amount of fee/compensation, ALP method |
| 16 | B | Securities | AE, Securities or shares, nature of transaction, consideration, ALP method |
| 17 | B | Mutual agreement/arrangement | AE, description, amount as per books and ALP, ALP method |
| 18 | B | Business restructuring/reorganisation | Nature, agreement, terms, AE and ALP method |
| 19 | B | Other international transactions(Transaction having bearing on profits, income, losses or assets) | AE, description, amount and method |
| 20 | B | Deemed international transactions | Name of party, transaction description, amount and ALP method |
| 21 | C | List of Associated enterprises for SDTs | AE name, address, PAN, relationship and business description |
| 22 | C | Inter-unit transfers by assessees referred under Sections 80A (6), 80-IA (8) and 10AA | Detail of goods and services, Amount and ALP details |
| 23 | C | More-than-ordinary profitsSDTs covered by Section 80-IA (10)/10AA | Entity name, description of transaction, Amount as per book and ALP & ALP method |
| 24 | C | Section 115BAB (6) transactions | Entity name, description of transaction, Amount as per book and ALP & ALP method |
| 25 | C | Section 115BAE (4) transactions | Entity name, description of transaction, Amount as per book and ALP & ALP method |
| 26 | C | Other SDTsnot covered above | Entity name, description of transaction, Amount as per book and ALP & ALP method |
Clauses 8 and 9 to be cross-checked with audited financials.
Source: ICAI Guidance Note on Report under Section 92E
10. What Should Be Checked for Form 3CEB Part B – International Transaction?
Before finalising Part B of Form 3CEB, it is important to make sure that the figures reported in the form match the actual transactions recorded in the books. A simple reconciliation can help avoid issues that can arise later.
- Agreements: Go through the intercompany agreements to confirm the nature and terms of the transactions reported in Form 3CEB.
- Invoices: Make sure the amounts reported are supported by invoices and other accounting records.
- Foreign currency transactions: Reconcile foreign currency transactions with the books and forex records.
- Related-party disclosures: Cross-check the transactions reported in Form 3CEB with the related-party disclosures notes in the financial statements.
- Transfer pricing study: Reconcile the transactions, amounts and methods reported in Form 3CEB with the transfer pricing documentation and underlying records.
Master Brains’ Form 3CEB and transfer pricing compliance services include transaction reconciliation, clause-wise review and e-filing support.
11. Illustrative Form 3CEB Example: Service Fee Paid to a Foreign Parent
ABC India Pvt. Ltd. pays USD 6,00,000 (₹5 crore as recorded in its books) to its foreign parent, ABC Global Ltd., Singapore, for technical services.
In Form 3CEB-Clause 13, ABC India should report:
- AE details: Name – ABC Global Ltd., Singapore and its address.
- Nature of transaction: Description of technical services provided by the AE.
- Transaction value: ₹5 crore as per the books and the amount computed having regard to the arm’s length price (ALP),
- ALP method: TNMM applied on an aggregated basis with ABC India as the tested party, since the service fee is closely linked to its operations and reliable comparables are available. Alternatively, ABC Global may be selected as the tested party if the facts and availability of reliable data support that selection.
Practical note: For Tax Year 2026–27, the revised reporting framework under the Income-tax Act, 2025 introduces Form 48 in place of Form 3CEB. The applicable reporting requirements, including relevant margin and comparable disclosures, should therefore be checked under the prescribed form and rules for that tax year.
12. Comparison: Form 3CEB vs Transfer Pricing Study
| Basis | Form 3CEB | Transfer Pricing Study |
| Purpose | Accountant’s report on the transactions covered by transfer pricing provisions. | Analyses and supports the arm’s length price. |
| Legal basis | Section 92E of the Income-tax Act, 1961 read with rule 10E | Section 92D read with Rule 10D. |
| Responsibility | Certified by a CA; furnished by the taxpayer on the e-filing portal | Maintained by the taxpayer (usually prepared with the help of a TP advisor) |
| Focus | What transactions took place and their values with the method of determining ALP. | Why is the transaction price at arm’s length? |
| Contents | List of AE and details of international transactions/SDTs, ALP methods used | (FAR) Functional analysis, comparability search, filters and arm’s-length range computation |
| Threshold | International Transactions: applicable for all international transactions.Specified domestic transactions: Above ₹20 crore aggregate | As per Rule 10D detailed documentation is required when: International transactions: exceeds ₹1 crore Specified domestic transactions: exceeds ₹20 croreBelow ₹1 crore: the taxpayer must still substantiate, on the basis of material available, that income from international transactions is computed at arm’s length (proviso to Rule 10D(2)). |
| Filing mode | Furnished electronically by the taxpayer through the Income Tax e-Filing portal, after verification by a practising Chartered Accountant. | It is not separately filed with the Income Tax Department. It is maintained by the taxpayer and produced when requested. |
Source: Section 92D & Rule 10D
13. Form 3CEB Filing Process on the Income Tax Portal
Form 3CEB is filed electronically through the Income Tax e-Filing Portal. The process of filing Form 3CEB is:
Step 1: Appoint and Assign the Accountant
The taxpayer must appoint an eligible Chartered Accountant through My Chartered Accountant under the Authorised Partners section on the Income Tax e-filing portal. Then, they must go to e-File>Income Tax Forms, select Form 3CEB and assign it to the appointed CA by selecting the Assessment Year (2026-27).
Step 2: CA Accepts the Assignment
Once assigned, Form 3CEB appears in the CA’s Worklist under For Your Action section. The CA can accept or reject the assignment. After accepting the assignment, the CA begins the preparation and examination process.
Step 3: Prepare and Verify the Form 3CEB Information
The CA, working with the assessee’s finance team, gathers and reviews the information required for Form 3CEB.
Step 4: CA Uploads and Authenticates Form 3CEB
After completing working and checks, the CA uploads the Form 3CEB through the CA’s portal login and authenticates the report using the Digital Signature Certificate (DSC). The submitted report then moves to the taxpayer’s e-Filing Worklist for acceptance.
Step 5: Taxpayer Reviews and Accepts the Report
The assessee can access the submitted Form 3CEB under Worklist→ For Your Action section. They should review the particulars reported by the CA and then accept the form electronically.
Step 6: UDIN Generation
The CA will generate UDIN from the ICAI portal and update the same from the CA’s portal corresponding to the relevant Form 3CEB.
Step 7: Retain the Filing Records
After acceptance, the taxpayer should retain the Form 3CEB filing acknowledgement and supporting documents for future reference.
In our experience, the most common gap is the mismatch between the TP workings, TP study, Form 3CEB, financial statements and the figures reported in the ITR. CA Neha Agarwal, FCA and founder of Master Brains advises TP consultants to reconcile these numbers in depth before filing. This simple check can help prevent avoidable TP compliance issues.
14. Common Form 3CEB Mistakes
1. Missing non-invoiced transactions
Do not overlook items such as unbilled charges, ESOPs, corporate guarantees or interest-free loans that may qualify as international transactions. Check the general ledger carefully to identify all related-party transactions.
2. Waiting until the 3CEB deadline
Do not wait until the last week of October to prepare Form 3CEB. Complete the transfer pricing analysis, benchmarking and CA certification well before the Form 3CEB deadline i.e., 31 October.
3. Mismatch in reported figures
Reconcile the figures reported in Form 3CEB match the amounts reported in Form 3CD (tax audit report under Section 44AB) and the audited financial statements. Investigate and document any differences arising from scope, classification, timing or accounting treatment.
4. No signed intercompany agreements
Entering into related-party transactions without a signed intercompany agreement can leave terms unclear and difficult to substantiate during a transfer pricing process. Where a signed agreement is unavailable, retain other contemporaneous evidence supporting the transaction’s nature, terms, actual conduct and commercial rationale.
5. Choosing the wrong transaction category
Selecting the wrong transaction category and clause on the e-filing portal is a big mistake. Dig into the terms of the intercompany agreement for correct categorization.
15. Form 3CEB Compliance Checklist
Before filing, check:
| Step | Check | What to verify |
| 1 | Entity details | Name, PAN, address, status and AY |
| 2 | AEs | Complete and correctly identified |
| 3 | International transactions | Complete transaction listing |
| 4 | SDTs | Applicability as per Section 92BA and ₹20 crore threshold |
| 5 | Transaction values | Reconciled with books |
| 6 | Agreements | Review intercompany agreements and other supporting evidence, as applicable |
| 7 | ALP | Method with a good basis and well accepted |
| 8 | 3CEB clauses | Correct clause mapping |
| 9 | Financial statements | Reconcile related-party disclosures with Form 3CEB and explain material differences |
| 10 | ITR | Form 3CEB details consistent with ITR |
| 11 | Transfer Pricing Documentation | Review what are documentation requirements as per Section 92D / Rule 10D |
| 12 | Filing | Form furnished keeping the due date in mind (31 October 2026) |
Is your audited (non-TP) business’s ITR filing now due on 21 November 2026, as extended from 31 October 2026? Get the filing details, deadlines and requirements right with our ITR Filing for Audited Businesses guide.
16. What is the Penalty for Late or Non-Filing of Form 3CEB?
When Form 3CEB is applicable to the assessee, it should be filed by 31 October of the assessment year (31 October 2026 for AY 2025-26).
If Form 3CEB from an accountant is not furnished by the due date of 31 October, a penalty of ₹1,00,000 may be imposed under Section 271BA of the Income-tax Act, 1961.
However, the penalty is not automatic in every case. Section 273B provides relief where the taxpayer can actually show that there was a reasonable cause for the non-compliance of Section 92E and Form 3CEB.
Missed the 31 October 2026 Deadline for Form 3CEB? What to Do
File Form 3CEB as soon as possible and document the reason for the delay. Section 273B can provide relief from the ₹1,00,000 penalty under Section 271BA where the taxpayer proves reasonable cause for the failure.
Position from Tax Year 2026-27 (Form 48)
The Finance Act, 2026 omitted the Section 447 penalty under the Income-tax Act, 2025 and replaced it with a fee under Section 428(d): ₹50,000 where the delay is up to one month and ₹1,00,000 thereafter. Since Section 470 (the successor to Section 273B) applies to penalties, a reasonable-cause defence may not be available against this fee, so the Form 48 due date should be treated as a hard deadline.
Other transfer pricing penalties, such as those for documentation failures, are covered in our article Penalties for Transfer Pricing Non-Compliance- Transfer Pricing in India.
Source: Section 271BA of the Income-tax Act, 1961
Section 273B of the Income-tax Act, 1961
17. Is 31 October 2026 the ITR Deadline or the Form 3CEB Deadline?
31st October, 2026 is the deadline for filing 3CEB report. Form 3CEB is due one month before the due date of the income-tax return under Section 139(1). Therefore, ITR for TP cases is due on 30 November 2026.
For AY 2026-27, the CBDT press release dated 28 September 2026 extended the tax audit report due date for normal (non-TP) audit cases to 21 October 2026 and the ITR due date to 21 November 2026. Transfer-pricing cases are not covered: Form 3CEB and the tax audit report remain due on 31 October 2026, and the ITR on 30 November 2026.
| CASE | Tax Audit Report (Form 3CA/3CB-3CD) | FORM 3CEB | Income-tax Return |
| Normal Tax-Audit Case (No Transfer Pricing) | 21 October 2026 (extended from 30 September 2026) | NA | 21 November 2026 (extended from 31 October 2026) |
| Transfer-Pricing Case (Section 92E Applies) | 31 October 2026 (not extended) | 31 October 2026 | 30 November 2026 (not extended) |
Source: CBDT Press Release dated 28 September 2026. CBDT indicated that a formal notification would follow; check the final notification for any change in coverage of transfer-pricing cases.
18. Related Transfer Pricing Forms
| Purpose | FY 2025-26 Income-tax Act, 1961 | Tax Year 2026-27 Income-tax Act, 2025 |
| Accountant’s report | Form 3CEB | Form 48 |
| Safe Harbour | Forms 3CEFA, 3CEFB, 3CEFC | Form 49 |
| Master File | Forms 3CEAA, 3CEAB | Forms 56, 57 |
| CbCR | Forms 3CEAC, 3CEAD, 3CEAE | Forms 58, 59, 60 |
See who must file CbCR in India, when it’s due and penalty on non-compliance of CbCR.
Frequently Asked Questions on Form 3CEB
1. Who must file Form 3CEB – is there any minimum transaction threshold?
A taxpayer who enters into an international transaction with an associated enterprise covered by Section 92B must obtain and furnish Form 3CEB under Section 92E. There is no general minimum monetary threshold for international transactions. Form 3CEB applies to specified domestic transactions when the ₹20 crore aggregate threshold is breached.
2. What is the due date for Form 3CEB for FY 2025-26?
Form 3CEB is due one month before the due date of the income-tax return under Section 139(1). Therefore, where the ITR is due on 30 November 2026 for transfer pricing cases, Form 3CEB is due on 31 October 2026.
3. What do Parts A, B and C of Form 3CEB cover?
Part A (Clauses 1-9) covers general taxpayer particulars and aggregate transaction information. Part B (Clauses 10-20) covers international transactions with associated enterprises. Part C (Clauses 21-26) covers specified domestic transactions and their arm’s length pricing particulars.
4. Is Form 3CEB required when there are only specified domestic transactions?
Yes, if the aggregate value of specified domestic transactions breaches the threshold of ₹20 crore in a financial year. This threshold applies to the aggregate value of qualifying specified domestic transactions covered by the transfer pricing provisions.
5. What is the penalty for not filing Form 3CEB?
Section 271BA provides for a ₹1,00,000 penalty for failure to furnish the accountant’s report required under Section 92E. For Form 48 under the Income-tax Act, 2025 (Tax Year 2026-27 onwards), this penalty is replaced by a fee under Section 428(d) of ₹50,000 (delay up to one month) or ₹1,00,000 (thereafter).
6. What is Form 48, and does it replace Form 3CEB for FY 2025-26?
No. Form 48 does not replace Form 3CEB for FY 2025-26. FY 2025-26 (AY 2026-27) continues under the Income-tax Act, 1961, where Form 3CEB applies under Section 92E and Rule 10E. Form 48 applies from Tax Year 2026-27 under Section 172 of the Income-tax Act, 2025.
7. Can Form 3CEB be filed after 31 October?
Yes, a delayed Form 3CEB may still be furnished, but the delay can attract a ₹1,00,000 penalty under Section 271BA. Section 273B provides relief where the taxpayer proves reasonable cause for the failure. The report should therefore be furnished as soon as possible after the missed deadline.
8. Is Form 3CEB required if there are no transactions with associated enterprises?
No. Form 3CEB is not required if there is no international transaction (including outstanding balances or receivables with an AE – Explanation (i)(c) to Section 92B) and no SDT above ₹20 crore. However, an outstanding receivable does not automatically become an international transaction merely because it appears in the accounts. In PCIT vs. Kusum Health Care Pvt. Ltd., Delhi High Court (ITA No. 765/2016), the Court clarified that the mere appearance of a receivable in the accounts does not automatically make it an international transaction.
Practical note: Kusum Health Care concerned whether outstanding receivables constitute a separate international transaction warranting an ALP adjustment; it did not decide Form 3CEB applicability. Where an AE balance (for example, an opening receivable or loan) subsists with no current-year transaction, the conservative approach is to report it under Clause 14, since Explanation (i)(c) to Section 92B covers receivables and other debts arising during the course of business.
Therefore, TP advisors should review the underlying transaction before determining Form 3CEB applicability.
9. Who can sign Form 3CEB?
Only a Chartered Accountant holding a valid certificate of practice can sign Form 3CEB. However,Explanation to Section 288(2) excludes certains persons from being eligible to sign the report such as; in the case of a company, a person not eligible for appointment as its auditor under Section 141(3) of the Companies Act, 2013; and in other cases, the assessee itself, its partners/members, relatives and employees, among others. Form 3CEB must be furnished by the taxpayer and verified & signed by the accountant. The taxpayer should make sure that the report is completed, verified and filed electronically within the due date.
10. What is the difference between Form 3CEB and Form 3CD?
Form 3CEB is a report under Section 92E regarding international and specified domestic transactions, as a part of transfer pricing compliance.
Form 3CD is the tax audit report required to be filed under Section 44AB. It reports prescribed particulars of an assessee’s business or profession.
11. Does Master Brains prepare and e-file Form 3CEB along with the transfer pricing documentation?
Yes. Master Brains can provide professional Form 3CEB preparation, clause-wise reporting, transaction reconciliation, transfer pricing documentation review and e-filing support, based on the taxpayer’s transactions and applicable requirements.
Get Form 3CEB Ready Before 31 October
Form 3CEB is the most important part of transfer pricing compliance.
Master Brains provides complete Form 3CEB and transfer pricing compliance support, including transaction identification, clause-wise review, documentation checks, reconciliation and filing assistance.
Do you have a Form 3CEB compliance requirement for FY 2025-26?
Call/WhatsApp: +91-8595867402
Email: masterbrains.office@gmail.com
Submit your query through the Master Brains contact form.
Sources & References
- Income Tax Department – Official Form 3CEB
- Income Tax India – Section 92E of the Income-tax Act, 1961
- Definitions under Section 92F of the Income-tax Act, 1961
- Section 288 of the Income-tax Act, 1961
- Section 92A of the Income-tax Act, 1961
- Section 271BA of the Income-tax Act, 1961
- Section 273B of the Income-tax Act, 1961
- Rule 10E of the Income-tax Rule, 1962
- Income tax Department – The Simplified Tax Form Series Form 48
- Section 92C & Rule 10B
- Section 92D & Rule 10D
- Section 92B of the Income-tax Act, 1961
- ICAI Guidance Note on Report under Section 92E
- Rule 10AB of the Income-tax Rules, 1962
- Section 428 of the Income-tax Act, 2025 (as amended by the Finance Act, 2026)
- Section 536 of the Income-tax Act, 2025 (Repeal and savings)
- CBDT Press Release dated 28 September 2026 – extension of due dates for AY 2026-27
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Chartered Accountant and Founder of Master Brains. Experience in Direct Taxes (Agarwal Sanjay and Associates, Delhi) and Indirect Taxes (Deloitte India, Bangalore).
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