—Guide
Form 3CEB: The Annual Transfer Pricing Report Explained
What Form 3CEB is, who needs it, what it certifies, its due date relative to the income-tax return, and the penalties for missing it.
Every company with international transactions with group companies needs a Chartered Accountant's report on them, filed every year before the income-tax return. It's Form 3CEB — and it's the document the tax department starts from when examining transfer pricing. This guide explains it.
Note: this describes the requirement under the Income-tax Act, 1961. The Income-tax Act, 2025, applicable from tax year 2026-27, continues it under renumbered provisions and forms.
Who Needs It
Any taxpayer that has entered into an international transaction with an associated enterprise, or a specified domestic transaction above the threshold, during the year. There's no minimum value for international transactions — even a single transaction requires the report.
What It Contains
- Details of the taxpayer and its associated enterprises.
- Each international transaction — its nature, value, and the method used to determine the arm's length price.
- Specified domestic transactions, where applicable.
- The accountant's opinion on whether proper documentation has been kept and whether the particulars are true and correct.
Due Date
Form 3CEB is due one month before the due date for filing the income-tax return. For companies with international transactions, whose returns are due by 30 November, that generally means by 31 October.
What It Depends On
The accountant relies on the transfer pricing documentation — the TP study — and the audited accounts. Both need to be ready well before the deadline.
Penalties
Failing to furnish the report can attract a penalty. Separate penalties apply for failing to maintain documentation, or failing to report a transaction.
Common Mistakes
- Missing transactions like reimbursements, guarantees or cost allocations.
- Wrong identification of associated enterprises.
- Values that don't reconcile to the accounts.
- Filing late because the TP study wasn't ready.
Getting Help
Think Filing prepares TP documentation and issues Form 3CEB certifications for companies with international transactions.