What is Form 3CEB?

Form 3CEB is the Accountant's Report required under Section 92E of the Income-tax Act. It must be obtained from and certified by a Chartered Accountant, and reports every international transaction and specified domestic transaction entered into with associated enterprises during the financial year, along with the method used to determine the arm's length price for each.

When is it due?

  • Form 3CEB must be filed electronically on or before 31 October of the relevant assessment year for most taxpayers subject to transfer pricing — ahead of the extended income tax return due date applicable to entities with international/specified domestic transactions.
  • It must be filed even if the return of income has not yet been finalised, as it is a separate statutory filing linked to, but distinct from, the tax return.

Your annual TP documentation checklist

  1. Map related-party transactions — identify every transaction with an associated enterprise, domestic or cross-border, above the ₹1 crore / ₹20 crore thresholds.
  2. Update the functional analysis — confirm functions, assets and risks for each entity haven't materially changed since the prior year.
  3. Refresh the benchmarking study — re-run or roll forward comparability searches with current-year financial data.
  4. Reconcile intercompany agreements — ensure written agreements match actual conduct and current pricing.
  5. Prepare the Local File / TP study report — document the analysis and conclusion for each transaction category.
  6. Obtain Form 3CEB certification — have your Chartered Accountant review and certify the report.
  7. Check Master File & CbCR applicability — reassess thresholds each year as group revenue changes.
  8. File on time — submit Form 3CEB electronically before the due date, well ahead of the return filing deadline.
Documentation prepared after a TP audit notice is far weaker evidence than documentation prepared contemporaneously — tax authorities and appellate forums alike give far more weight to real-time analysis.

Penalties for missing the deadline

  • Failure to furnish Form 3CEB: penalty of ₹1 lakh under Section 271BA.
  • Failure to maintain documentation: penalty of 2% of the value of the international/specified domestic transaction under Section 271AA.
  • Failure to report a transaction, or furnishing incorrect information: further 2% penalty exposure, in addition to any tax adjustment and interest arising from a subsequent TP audit.

How we help

We run this checklist for our clients every year as a structured, calendarised process — not a last-minute scramble in October — so documentation, benchmarking and certification are complete well before the statutory deadline.