Transfer Pricing Report (Form 48, formerly 3CEB) Deadline Guide

What Is the Transfer Pricing Accountant's Report?

Transfer pricing compliance in India centres on the annual accountant's report. For tax year 2026-27 onwards that report is Form No. 48 (formerly Form 3CEB), prescribed by rule 85 of the Income-tax Rules, 2026 and furnished under section 172 of the Income-tax Act, 2025. For FY 2025-26 and earlier years the report was Form 3CEB under Rule 10E of the Income-tax Rules, 1962, furnished under section 92E of the Income-tax Act, 1961. Every entity that has entered into international transactions or specified domestic transactions (SDTs) with an associated enterprise must obtain the report from a practising Chartered Accountant.

Which of the two a filing made after 1 April 2026 in respect of FY 2025-26 must use is not settled by the notified rules — the Income-tax Rules, 2026 contain no repeal-and-savings provision. Check the form actually enabled on the e-filing portal before filing, and take professional advice. The deadline is not in doubt: the report for FY 2025-26 is due by October 31, 2026, one month ahead of the November 30, 2026 income tax return deadline that applies to companies required to furnish a transfer pricing report.

The report is the Tax Department's primary tool for identifying related-party transactions that may not be at arm's length price. It discloses the nature, value, and method used to determine the arm's length price for each transaction. A missing or late report not only attracts a charge — a flat penalty of INR 1,00,000 under section 271BA of the Income-tax Act, 1961 for FY 2025-26 and earlier years, and a fee under section 428(d) of the Income-tax Act, 2025 from tax year 2026-27 — but also signals the Assessing Officer to scrutinise your transfer pricing arrangements more closely.

Filing Deadline for FY 2025-26 (AY 2026-27)

The deadline for filing the transfer pricing accountant's report for FY 2025-26 (Assessment Year 2026-27) is October 31, 2026. This is one month before the income tax return (ITR) filing deadline of November 30, 2026 that applies to companies required to furnish a transfer pricing report. From tax year 2026-27 that one-month gap sits in the rule itself: rule 85(2) of the Income-tax Rules, 2026 requires the report to be furnished at least one month prior to the due date for furnishing the return of income under section 263(1)(c) of the Income-tax Act, 2025. Under the 1962 Rules the date came from the "specified date" machinery of the 1961 Act instead.

Key Timeline

Note: The CBDT occasionally extends these deadlines. Monitor the compliance calendar for any extensions.

Who Must File the Accountant's Report?

The report is mandatory for any person who has entered into:

International Transactions

Any transaction between two or more associated enterprises, where at least one is a non-resident, regardless of the transaction value. There is no minimum threshold for international transactions. Even a single cross-border payment of INR 1 to an associated enterprise triggers the reporting requirement.

Common international transactions for foreign-owned companies include:

• Payment of management fees, royalties, or technical service fees to the parent company
• Purchase or sale of goods, raw materials, or finished products with group entities
• Shared service charges or cost contribution arrangements
• Loans, guarantees, or interest payments between group companies (including external commercial borrowings)
• Reimbursement of expenses incurred by the parent on behalf of the Indian subsidiary
• Use of brand names, trademarks, or intellectual property from the parent

Specified Domestic Transactions (SDTs)

Transactions between related domestic parties are covered if the aggregate value exceeds INR 20 crore in a financial year. SDTs include transactions under Sections 80A, 80-IA, 10AA, and Chapter VI-A where specified conditions are met; the earlier limb covering payments to related parties under Section 40A(2)(b) was removed from Section 92BA by the Finance Act 2017.

Associated Enterprise: The 26% Voting Power Test

Two enterprises are considered associated if one participates in the management, control, or capital of the other, directly or indirectly. The primary quantitative test is holding of 26% or more of the voting power in one enterprise by the other.

Additional criteria under Section 92A that establish the associated enterprise relationship include:

• One enterprise guarantees 10% or more of the borrowings of the other
• More than half the board of directors or members of one enterprise are appointed by the other
• One enterprise's commercial activities are wholly dependent on IP rights held by the other
• 90% or more of raw materials and consumables are supplied by the other enterprise or persons specified by it
• The manufacturing is carried out as per the know-how, patents, or designs furnished by the other enterprise

For wholly owned subsidiaries of foreign companies, the associated enterprise relationship is automatic. The parent company, all fellow subsidiaries worldwide, and the Indian entity form part of the same associated enterprise group.

What the Report Contains

Form No. 48 and Form 48 are each in three parts — assessee particulars first, then the international-transaction and specified-domestic-transaction disclosures:

Part A: General Information

Basic particulars of the assessee — name, address, PAN, nature of business, and the aggregate value of international transactions and specified domestic transactions entered into during the year.

International Transactions

For each international transaction, the CA must report:

• Name and address of each associated enterprise involved
• Description and nature of the transaction (goods, services, loans, IP, etc.)
• Total transaction value in INR
• The method used to determine arm's length price (CUP, TNMM, CPM, RPM, PSM, or other method)
• The arm's length price and the actual transaction price
• Whether any adjustment is required

Specified Domestic Transactions

Similar disclosures to the international-transaction part, but for domestic transactions between related parties exceeding the INR 20 crore aggregate threshold.

The CA signing the report must independently verify that the transfer pricing documentation maintained under Section 171 of the Income-tax Act, 2025 (section 92D of the Income-tax Act, 1961) supports the arm's length characterisation of each transaction. The list of documents is prescribed by rule 84 of the Income-tax Rules, 2026 for tax year 2026-27 onwards, and was prescribed by Rule 10D of the Income-tax Rules, 1962 for earlier years.

Transfer Pricing Methods Recognised in India

India recognises six methods for computing the arm's length price, and your accountant's report must specify which method was applied for each transaction:

TNMM is by far the most frequently applied method in India. The method compares the net profit margin of the tested party with margins of comparable independent companies. For guidance on selecting the right approach, see our overview of transfer pricing basics for foreign subsidiaries.

Penalties for Non-Compliance

India's transfer pricing penalty framework is multi-layered and cumulative. Missing the accountant's report deadline is just the starting point. The table below sets out the framework of the Income-tax Act, 1961, which governs tax years beginning before April 1, 2026:

For tax years beginning on or after April 1, 2026, the Income-tax Act, 2025 recasts the Section 271BA penalty as a fee under section 428(d) — INR 50,000, rising to INR 1,00,000 — while the 2% documentation penalties continue under sections 457 and 442 of the 2025 Act (sections 271G and 271AA of the 1961 Act).

Consider a subsidiary with international transactions worth INR 50 crore. If the company fails to maintain TP documentation and also fails to file the accountant's report, the combined penalties under Sections 271BA, 271G, and 271AA could exceed INR 2 crore, in addition to any tax adjustment on the arm's length price shortfall.

Read about the most common compliance failures in our guide to 7 transfer pricing mistakes that trigger a tax audit.

Step-by-Step Filing Process

The accountant's report must be filed electronically on the Income Tax e-filing portal. Here is the practical process:

Step 1: Appoint a Chartered Accountant (April-May)

Engage a CA with transfer pricing expertise. The CA must hold a valid Certificate of Practice and should ideally have experience in your industry. Many multinational subsidiaries use their statutory auditor, but a separate TP specialist is recommended for complex arrangements.

Step 2: Prepare Transfer Pricing Documentation (May-July)

Compile contemporaneous TP documentation. For tax year 2026-27 onwards the list is prescribed by rule 84 of the Income-tax Rules, 2026 under section 171 of the Income-tax Act, 2025; Rule 10D of the Income-tax Rules, 1962 prescribed it for earlier years. It runs to:

• Ownership structure and organisational chart of the multinational group
• Description of business operations and industry analysis
• Functional, asset, and risk (FAR) analysis for each associated enterprise
• Details of all international transactions and SDTs, with invoices and agreements
• Selection and application of the most appropriate method
• Benchmarking study with comparable company data
• Financial statements of the tested party and comparable companies

Keep it. Rule 84(8) of the Income-tax Rules, 2026 requires this information and these documents to be retained for nine years from the end of the relevant tax year. That is not a one-year extension: the predecessor, Rule 10D(5) of the 1962 Rules, ran eight years from the end of the relevant assessment year, and because the anchor has moved back a year the outer date is unchanged — the drafting was re-based, not lengthened.

Step 3: CA Review and Certification (August-September)

The CA conducts an independent review of your TP documentation, verifies the arm's length analysis, and prepares the report. Allow at least 4-6 weeks for this process.

Step 4: E-Filing on the IT Portal (October)

The CA uploads the report through the Income Tax e-filing portal (incometax.gov.in). The company must first add the CA as an authorised representative on the portal. After upload, the company's authorised signatory (typically a director with a digital signature certificate) must accept and submit the form.

Step 5: File Income Tax Return (by November 30)

Once the accountant's report is filed, the company files its ITR by November 30, 2026, referencing it. The ITR must be consistent with the arm's length prices reported in the report.

Safe Harbour Rules: When You May Not Need Full TP Analysis

India's safe harbour rules under section 92CB of the Income-tax Act, 1961 (section 167 of the Income-tax Act, 2025) allow eligible taxpayers to declare transfer prices at specified margins without conducting a full benchmarking analysis. If the safe harbour option is elected and the declared margins meet the prescribed thresholds, the transaction is accepted as arm's length without scrutiny.

Safe harbour provisions are available for specific transaction types, including IT and ITES services, contract R&D, and intra-group loans. However, filing the accountant's report remains mandatory even when safe harbour is opted for. The safe harbour election is reported separately — in Form 3CEFA for FY 2025-26 and earlier tax years, and in Form No. 49 under the Income-tax Rules, 2026 for tax year 2026-27 onwards.

Advance Pricing Agreements: Eliminating TP Disputes

For companies with large, recurring international transactions, an Advance Pricing Agreement (APA) with the CBDT can eliminate transfer pricing uncertainty for up to 5 years (with a 4-year rollback). India's APA programme has signed 1,034 APAs since inception — including a record 219 in FY 2025-26 alone, per the CBDT — covering sectors like IT, manufacturing, and financial services.

While an APA does not eliminate the accountant's report filing requirement, it significantly reduces the risk of TP adjustments and penalties. Under the Income-tax Rules, 2026 the application is made in Form No. 51 (formerly Form 3CED) under rule 106, accompanied by a flat fee of INR 20 lakh (rule 106(1) and (4)). That flat fee replaces the graduated INR 10 lakh / INR 15 lakh / INR 20 lakh ladder that Rule 10-I of the Income-tax Rules, 1962 set by transaction value, so a group with international transactions below INR 100 crore now pays INR 20 lakh where it would once have paid INR 10 lakh — a real increase for mid-size applicants, not a renumbering. The fee is not refunded if the application is withdrawn (rule 107(2)). For transactions of a continuing nature the application must be filed before the first day of the first tax year it covers; for other transactions, before the transaction is undertaken (rule 106(3)). A renewal is made as a fresh application in Form No. 54 under rule 119, using the same procedure and fee, except that pre-filing consultation is not required.

Common Mistakes to Avoid

• Treating reimbursements as non-transactions: Cost reimbursements between group entities are international transactions and must be reported in the accountant's report. The tax department routinely challenges reimbursements as disguised service fees.
• Ignoring guarantee commissions: Corporate guarantees provided by a parent company for the Indian subsidiary's borrowings are deemed international transactions. The arm's length guarantee fee must be determined and reported.
• Using stale benchmarking data: The benchmarking study must use the most current available financial data of comparable companies. Using data more than 2 years old invites adjustment.
• Missing the SDT threshold: Companies often overlook that related domestic transactions exceeding INR 20 crore in aggregate also require reporting in the accountant's report.

For professional transfer pricing support, including TP documentation, benchmarking studies, and filing the accountant's report, contact our advisory team.

Key Takeaways

• The accountant's report is due one month before the income tax return — October 31, 2026 for FY 2025-26 (AY 2026-27)
• From tax year 2026-27 the report is Form No. 48 (formerly Form 3CEB) under rule 85 of the Income-tax Rules, 2026; for FY 2025-26 and earlier years it was Form 3CEB under Rule 10E of the Income-tax Rules, 1962. Which form an FY 2025-26 filing made after 1 April 2026 must use is not settled by the notified rules — check the form actually enabled on the e-filing portal before filing, and take professional advice
• Every international transaction with an associated enterprise triggers the filing requirement, with no minimum value threshold
• Penalties are cumulative: for FY 2025-26 and earlier years, INR 1 lakh for late filing (section 271BA of the 1961 Act) plus 2% of transaction value for documentation failures (sections 271G and 271AA); from tax year 2026-27, a fee under section 428(d) of the 2025 Act and the same 2% charges under sections 457 and 442
• Begin TP documentation immediately after the March 31 year-end; engage a specialised CA by April-May for adequate preparation time. Keep the documentation for nine years from the end of the tax year (rule 84(8) of the Income-tax Rules, 2026)
• Safe harbour rules and APAs can reduce compliance burden but do not eliminate the accountant's report filing requirement; an APA application now carries a flat INR 20 lakh fee in Form No. 51 (rule 106 of the Income-tax Rules, 2026)